UK Packaging Labelling Requirements After Brexit: What's Changed and What Brands Must Know

On 31 December 2020, the UK left the EU single market. Since then, UK product and packaging regulations have been diverging from EU regulations on a category-by-category basis. For brands selling into the UK — whether they are UK-based manufacturers or overseas exporters — the regulatory landscape is no longer identical to the EU.

This guide covers the key UK labelling requirements and changes post-Brexit for food, cosmetics, and regulated products, with particular attention to where UK rules now differ from EU rules that may be more familiar to brands that sell into both markets.

The General Principle: Retained EU Law

At the point of Brexit, the UK enacted the European Union (Withdrawal) Act 2018, which converted all EU regulations into UK domestic law as "retained EU law." This means that, at the moment of Brexit, UK packaging regulations were identical to EU regulations.

However, since then, the UK has begun amending these retained regulations and introducing new UK-specific requirements. The pace of divergence is uneven — some areas remain largely aligned with the EU (food contact materials, general safety), while others have diverged significantly (cosmetics, UKCA product marking, food information).

The practical implication: do not assume that an EU-compliant label is automatically UK-compliant. Check each requirement category separately.

Food Labelling: The UK Food Information Regulations

UK food labelling is governed by the Food Information Regulations 2014 (as amended), which retain the core requirements of EU Regulation 1169/2011 (EU Food Information for Consumers Regulation) but with UK-specific amendments.

Mandatory Labelling Elements for Food Sold in Great Britain (England, Scotland, Wales)

The following information must appear on pre-packaged food:

• Name of the food: The legal name of the food (not a marketing name). For common foods, there is a standard legal name (e.g., "pasteurised semi-skimmed milk"). For novel or compound foods, a descriptive name must be provided.
• List of ingredients: In descending order of weight at the time of manufacture. Compound ingredients (those with their own ingredient list) must show their own components in brackets.
• Allergen declaration: The 14 major allergens listed in UK food law (equivalent to EU: cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame seeds, sulphur dioxide/sulphites above 10mg/kg or 10mg/L, lupin, molluscs) must be emphasised in the ingredient list — typically by bold text, italics, or a contrasting colour. The FSA-recommended method in Great Britain is bold text.
• Net quantity: In metric units (grams, kilograms, millilitres, litres). For products sold by count, the number of items.
• Date marking: Either "best before" (quality indicator — safe after this date, may be reduced quality) or "use by" (safety indicator — unsafe after this date). The format and requirements differ. "Use by" is mandatory for highly perishable foods; "best before" for others.
• Storage conditions: Where relevant (e.g., "refrigerate after opening," "store below 25°C").
• Name and address of the food business operator: The responsible UK food business operator — either the manufacturer, packer, or retailer in the UK. Since Brexit, this must be a UK address (or Northern Ireland address for Northern Ireland-specific requirements — see below).
• Country of origin: Required for beef, pork, sheep, goat, and poultry meat; fresh fruit and vegetables; olive oil; honey; wine; fish; and eggs. Voluntary for other categories but recommended for provenance marketing.
• Instructions for use: Where required for safe use.
• Alcohol content: For drinks with more than 1.2% ABV.
• Nutrition declaration: Mandatory for most pre-packaged foods. Must declare: energy (kJ and kcal), fat, saturates, carbohydrate, sugars, protein, and salt — per 100g or 100ml. Voluntary additional nutrients (fibre, vitamins, minerals) may be added.

UK-Specific Change: Calorie Labelling on Out-of-Home Food

From April 2022, large businesses (250+ employees) in England that sell food out-of-home (restaurants, cafes, takeaways, supermarket cafes) must display calorie information on menus and food labels. This requirement does not currently apply to Scotland or Wales. It affects in-store prepared food and some shelf-stable products sold in out-of-home contexts.

Northern Ireland: A Special Case

Northern Ireland remains subject to EU food labelling rules (EU Regulation 1169/2011) under the Windsor Framework (formerly the Northern Ireland Protocol). Products sold exclusively in Great Britain (England, Scotland, Wales) follow UK rules. Products sold in Northern Ireland or crossing into the Republic of Ireland follow EU rules. Products sold across both jurisdictions need to comply with both — which is typically achievable with a single label that meets the more demanding requirements.

Address Requirements Post-Brexit

Food labels must carry the name and address of a UK food business operator. "UK address" means an address in England, Scotland, Wales, or Northern Ireland. An EU address is no longer compliant for products sold in Great Britain. This is a practical issue for EU-based manufacturers who previously used an EU address — they now need a UK importer of record to appear on the label.

Cosmetics Labelling: UK Cosmetics Regulation

The UK Cosmetics Regulation (Retained EU Law) requires the following on cosmetic product labels:

• Name and address of the Responsible Person (RP) in the UK: Since Brexit, cosmetics sold in Great Britain require a UK-based Responsible Person — a legal entity established in the UK (England, Scotland, Wales) that takes regulatory responsibility for the product. An EU RP is not compliant for Great Britain. (Northern Ireland again follows EU rules and requires an EU RP or NI-based RP.)
• Nominal content: Net weight or volume
• Date of minimum durability: Either a best-before date (for products with durability under 30 months) or the Period After Opening (PAO) symbol (an open jar with a number of months, e.g., "12M") for products with durability over 30 months
• Precautions for use: Any special instructions for safe use
• Batch number: For traceability
• Country of origin (for products manufactured outside the UK)
• Function of the product: If not clear from its presentation
• List of ingredients: Using INCI names, preceded by "Ingredients:" in descending order of concentration with ingredients below 1% listable in any order (same rule as EU)

UK Cosmetics: Divergence from EU

The UK has committed to maintaining broadly equivalent cosmetic regulations to the EU, but some divergence has occurred:

Product notification: In the EU, cosmetics must be notified on the EU Cosmetics Product Notification Portal (CPNP) before being placed on the market. In the UK, cosmetics must be notified on the Office for Product Safety and Standards (OPSS) Submit a Cosmetic Product Notification Service. These are separate portals requiring separate notifications.

Prohibited and restricted substances: The UK list of prohibited and restricted substances is retained from EU Annex II, III, and IV at the point of Brexit. Updates made to the EU annexes since January 2021 are not automatically incorporated into UK law — the UK updates its lists separately. Currently, the lists are broadly similar but may diverge over time.

The UKCA Mark

The UKCA (UK Conformity Assessed) mark is the UK equivalent of the CE mark for products that require regulatory conformity marking — electrical equipment, medical devices, personal protective equipment, toys, and certain other regulated products.

Key point: UKCA does not apply to most food, cosmetics, or general consumer goods packaging. It applies specifically to product categories that previously required CE marking under EU product safety directives. If your product required CE marking before Brexit, it likely now requires UKCA marking for sale in Great Britain.

The CE mark is still accepted in Great Britain for a transitional period, but this grace period is being phased out by category. Check the current status for your specific product category via the OPSS guidance.

Packaging Waste Regulations: Extended Producer Responsibility (EPR)

The UK introduced Extended Producer Responsibility (EPR) for packaging under the Environment Act 2021, with full implementation beginning in 2025. Under EPR:

• Brands (producers) that place packaged goods on the UK market above the applicable threshold (currently: 50+ tonnes of packaging per year AND turnover above £2 million) must register with the Environment Agency (England), SEPA (Scotland), NRW (Wales), or NIEA (Northern Ireland)
• Registered producers must report packaging data (type, weight, material) annually
• Producers pay fees to fund the collection and recycling of packaging materials — the fee structure is designed to incentivise use of more recyclable packaging materials

The EPR regime is separate from the Plastic Packaging Tax (PPT), which levies a charge (£217.85 per tonne from April 2024) on plastic packaging manufactured in or imported into the UK that contains less than 30% recycled plastic content by weight.

Practical implication: Brands selling into the UK above the EPR thresholds need to understand their packaging composition data (material types and weights) and their reporting obligations. Packaging designers who can supply material weight and composition data as part of project documentation make compliance significantly easier for brand owners.

Labelling for Regulated Products Sold in Both the UK and EU

Brands that sell in both markets face a dual-compliance requirement. The practical approaches:

Bilingual or multi-information labels. A single label that carries both UK-compliant information (UK RP address, UKCA if required) and EU-compliant information (EU RP address, EU notification reference) — with the market-specific information in smaller type beneath the primary declaration. This is the approach used by many brands at lower packaging volumes where producing two separate labels is cost-inefficient.

Two label versions. Separate label artwork for UK and EU markets. More expensive (two label SKUs, more complex inventory management) but cleaner from a regulatory presentation perspective. Appropriate for higher-volume brands.

The "rest of world" label. Some brands produce a label compliant with both UK and EU requirements (using the most demanding specification from each) and apply it to all markets. This approach reduces complexity but may include information not required in some markets.

FAQ

Does my EU-compliant product need a completely new label for the UK? Not necessarily a completely new label, but some elements will need to change. The most common changes required: EU RP address must be supplemented or replaced with a UK RP address (or UK importer address for food); the CPNP cosmetic notification reference is not applicable in the UK (OPSS notification is separate); some product category-specific requirements may differ. Review your existing label against the specific requirements for your product category in the UK regulations.

What address do I put on UK food packaging if I'm a non-UK manufacturer? You must show the name and address of a food business operator established in the UK. This is typically a UK-based importer or distributor who takes on the legal responsibility of placing the food on the UK market. Many food importers offer this service (as "importer of record") as part of their commercial arrangement.

Is there guidance on the specific format of UK food labels? Yes — the Food Standards Agency (FSA) publishes detailed technical guidance on food labelling in the UK, available on the FSA website. The guidance covers each mandatory element, format requirements (minimum character height, placement rules), and category-specific rules. For cosmetics, the OPSS publishes guidance on the UK Cosmetics Regulation.