Wine and spirit legislation is not included in the UK-EU Sanitary and Phytosanitary (SPS) agreement currently under negotiation. As a result, businesses moving wines or spirits from GB into retail premises in Northern Ireland under the Northern Ireland Retail Movement Scheme (NIRMS) will need to comply with stricter ‘Not for EU’ labelling requirements.

From 19 October, businesses will no longer be able to label a wrapped pallet or cage as ‘Not for EU’ for wine and spirit drinks moved to NI under NIRMS. Each case will need to be labelled ‘Not for EU’, rather than each pallet. This change is reflected in updated Gov.uk guidance, ‘Labelling requirements for certain products moving from Great Britain to retail premises in Northern Ireland under the Northern Ireland Retail Movement Scheme (NIRMS)’.

Defra has confirmed that there will be no extension, transition period or grandfathering for existing stock in storage. The EU Commission has determined that full compliance with the Windsor Framework, as drafted, is integral to progress on a UK-EU SPS agreement and wider reset discussions.

Enforcement arrangements remain unclear. Defra cannot guarantee a relaxed enforcement approach or transitional grace period from 19 October but has noted that businesses able to demonstrate proactive progress are more likely to support a pragmatic regulatory approach.

Members should remember that NIRMS is not mandatory when shipping products from GB to NI. Alternative options may include using the red lane, moving goods under the UK Internal Market Scheme (UKIMS), shipping under bond into NI or routing goods into NI via the EU.