2020-16: United Kingdom: Multiple Commodities: BREXIT changes from 1 Jan 2021 affecting Great Britain and Northern Ireland

Date of issue: 24 December 2020

Date of effect: Immediate

Reference Number: MAA2020-16


  • Industries—Industry bodies – Dairy Australia, Dairy Export Industry Consultative Committee, Seafood Export Consultative Committee, Australian Food and Grocery Council, Australian Honey Bee Industry Council
  • Export establishments
  • Licensed exporters
  • Department of Agriculture, Water and the Environment —Central and Regional offices


This Market Access Advice provides information on changes to trade with the United Kingdom of Great Britain and Northern Ireland (UK) following the Brexit transition period which ends on 31 December 2020.

Summary of key points

  • Certain changes relate specifically to the Northern Ireland Protocol, which was agreed between the UK and EU in 2019, and will come into effect at the end of the Brexit transition period. Under the terms of this Protocol, from 1 January 2021, Northern Ireland will remain part of the EU’s customs and Sanitary and Phytosanitary (SPS) territories. This means that for some commodities, Northern Ireland and Great Britain (comprising of England, Scotland and Wales) may be subject to different rules for SPS and marketing standards over time.
  • As Northern Ireland will continue to use the EU regulations and systems for imports there are unlikely to be any impacts on trade in products which are shipped directly to Northern Ireland. The UK Government has published advice regarding transit or trans-shipment through the UK.
  • For Great Britain (England, Scotland and Wales) the department is advised that the existing EU regulations and standards are captured in UK legislation and therefore no immediate changes are expected to those standards. However, there will be changes to replace reference to the EU with Great Britain in health certificates for products destined for England, Scotland and Wales.
  • Exporters should be aware of possible delays to the processing of imports at the UK border as new arrangements are implemented from 1 January 2021.

Establishment Registration

  • The UK will continue to recognise the status of establishments currently approved by the EU to import animal products into the UK.


  • As noted above, revised templates for export health certificates for England, Scotland and Wales will be amended to refer to Great Britain rather than the EU. The UK has advised that current EU model certificates issued for product shipped up to and including 31 March 2021 will be accepted. The department will, as a matter of priority, commence work to revise these certificates in EXDOC in order to meet the 31 March 2021 deadline. In the interim the department will also continue to work with our UK counterparts with the aim to move to paperless eCert as soon as practicable.
  • Due to the Northern Ireland Protocol, exports to Northern Ireland must continue to meet EU SPS rules and marketing standards including the relevant EU model certificate. Companies are encouraged to verify that their shipments have the correct certification prior to their shipments leaving Australia, noting the restrictions around the replacement of health certificates for the EU.


  • Great Britain will apply UK regulations and systems. Pre-notification on the UK Import of Products, Animals, Food and Feed System (IPAFFS) must be provided by GB import agents and cannot be raised by exporters directly.
  • Northern Ireland will continue to use the EU regulations and import systems from 1 January 2021. Your import agents should be aware that the EU TRACES system must continue to be used to provide pre-notification of imports to Northern Ireland (Belfast Port and Belfast International Airport).

Labelling of pre-packaged food – address in the UK

  • Food placed on the market in Great Britain must display the name and address of the UK Food Business operator (FBO) responsible for the information presented on the label.
  • Food placed on the market in Northern Ireland will need an FBO address in either the EU or Northern Ireland.
  • Pre-packaged food intended to be sold in Great Britain should be correctly labelled by 30  September  2022.
  • The Manual of Importing Country Requirements (Micor) will be updated to reflect this market access advice. Please note that the new Micor update service is now in place. Users can subscribe to a weekly email for each commodity that lists all the changes that have been made to that commodity in the preceding week.

Further information

Contact exportstandards@awe.gov.au if you have any queries.

The information provided in this advice is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.

Last reviewed: 24 December 2020
Thanks for your feedback.
Thanks! Your feedback has been submitted.

We aren't able to respond to your individual comments or questions.
To contact us directly phone us or submit an online inquiry

Please verify that you are not a robot.