Find out how businesses that hold or seek authorisations for GM food or feed or animal feed additives, or export animal feed to the EU, will be affected if there is a no-deal Brexit.
Guidance on what you need to do to prepare for the rules and processes that will apply if we leave the EU with no deal. This guidance is aimed specifically at UK businesses:
- holding or seeking authorisations for genetically modified (GM) food or feed
- holding or seeking authorisations for animal feed additives
- exporting animal feed products to the EU
- that have applications to update the list of feed for particular nutritional purposes (PARNUTS) pending at the time of Brexit
- that represent companies that are based in non-EU countries which rely on UK representation for EU trade
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This page tells you what to do if there is a no-deal Brexit. It will be updated if anything changes, including if a deal is agreed.
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Your business will need to be established in the EU or European Economic Area (EEA), or have a representative that is established in the EU or EEA if you wish to trade in the EU. The EEA includes Iceland, Liechtenstein and Norway. The role of the representative is to provide assurance that the non-EU establishment complies with EU legislation. The following guidance explains what you need to do.
Appointing a representative
When appointing a representative, your UK businesses should ensure that the potential representative is based in one of the 27 EU countries, or an EEA country, and that they are able to provide the necessary assurance to act as such. When appointed, the representative needs to submit a request to the appropriate competent authority in the EU country or EEA state in which they are based. You should obtain confirmation that they have done so and, finally, that the competent authority has informed the European Commission.
UK businesses holding EU authorisations for GM food or feed, or for animal feed additives
If you are holding EU authorisations for GM food or feed, or for animal feed additives, you will need to designate a representative established in the EU or EEA. You will need to provide details of the representative to the European Commission. This could be a branch of your business which is established in the EU or EEA or another business. Changes to holder-specific authorisations for GM food or feed, or for feed additives, require amendments to EU legislation which would need to be in place by exit day. Businesses in the process of such changes need to approach the European Commission as soon as possible.
UK exporters of feed products to the EU
Exporters of feed products to the EU will require representation in the EU or EEA. As a guide only, current UK procedures on becoming a representative are available on the Food Standards Agency (FSA) website. EU countries will each have their own systems for this and businesses should consult with the relevant competent authority in the EU country for further advice on gaining recognition for their representative. The requirement for non-EU country representation would apply to all feed products exported to the EU.
The requirement for non-EU country representation would apply to all feed products. This follows the European Commission’s announcement of a revised interpretation of Regulation (EC) 183/2005, Article 24. The FSA is currently seeking clarity on this interpretation, but companies should nevertheless anticipate this revised interpretation and consider designating a representative within the EU or the EEA.
Other businesses in the scope of this guidance
UK businesses that have applied for EU authorisation of GM food or feed; feed additives; or updates to the list of PARNUTS, and whose application is still being processed, if they wish for the application(s) to continue, will need to designate a representative established within an EU country or the EEA. The business would also need to provide details of the representative to the European Commission. For feed additives, this applies to both generic authorisations and those linked to a specific authorisation holder.
UK businesses acting in the role of a representative(s) for establishments in non-EU countries to enable them to export feed product to the EU, will need to inform the establishments they represent that they will no longer be able to act as their representative and advise them that they will need to appoint a representative based in an EU country or the EEA.
How the UK government is working with interested parties
The FSA has contacted key stakeholders to notify them of these requirements and will keep them updated on developments.
If you require more information or have questions on this guidance, please email the FSA: firstname.lastname@example.org
All the information provided here is meant for guidance only. You should consider whether you need separate professional advice before making specific preparations.