Last updated: 9 September 2024

There are specific requirements for Northern Ireland retailers labelling certain agri-food products under the Northern Ireland Retail Movement Scheme.

Individual labels

Under NIRMS, some food products require individual product labels with the words ‘Not for EU’. These requirements will be introduced in 3 phases from October 2023 to July 2025. This includes products imported into Great Britain from the EU and products from the rest of the world that can move under NIRMS.  

Only products moving into Northern Ireland under NIRMS will need to meet the labelling requirements.

Phase 1: Labelling requirements from 1 October 2023

All meat products and some dairy products that are moving from Great Britain to Northern Ireland under NIRMS need to be individually labelled. You should read the descriptions of phase 1 products in this guidance. You can also look at the full list of commodity codes that are in scope for phase 1. This list may change or be updated in the future. Any dairy product that is not included in this list must be labelled in Phase 2.

Read more about phase 1 of the NI Retail Movement Scheme.

Phase 2: Labelling requirements from 1 October 2024

From 1 October 2024, as well as the phase 1 products, all milk and dairy products moving to Northern Ireland under NIRMS need to be individually labelled. Find the full list of commodity codes that are in scope for phase 2. This list is subject to change and may be updated in the future. You should refer to the descriptions in this guidance.

Read more about phase 2 of the NI Retail Movement Scheme.

Phase 3: Labelling requirements from 1 July 2025

From 1 July 2025, composite products, fruit, vegetables, ​​​​fish, ​​and some other products moving to Northern Ireland under NIRMS will also need to be individually labelled.  

Not all products moved under NIRMS need to be individually labelled. There is an exception list below of products that do not need to be individually labelled under NIRMS. If products are individually labelled, you do not need to label the box or have appropriate signage.

Read more about phase 3 of the NI Retail Movement Scheme.

Exceptions: food products that do not need individual labels

You will not need to individually label the following products, (although box and retail premises labelling requirements apply):

• products sold loose or by weight on the sales premises at the consumer’s request  
• products processed and sold on the sales premises by a retailer, at the consumer’s request, for direct consumption 
• products that are for sale in a factory canteen, institutional canteen, restaurant, or other similar food service operator, and are intended for eating on the spot in Northern Ireland

Shelf-stable composite products include:

• Confectionery (including sweets) and white chocolate, not containing cocoa, and confectionery (including sweets), chocolate and other food preparations, spreads, and preparations for making beverages, containing cocoa 
• pasta, noodles and couscous, not mixed or filled with meat products 
• prepared foods obtained by the swelling or roasting of cereals or cereal products, prepared foods obtained from unroasted cereal flakes or from mixtures of unroasted cereal flakes and roasted cereal flakes or swelled cereal 
• bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products and chips and crisps 
• olives stuffed with fish 
• extracts, essences and concentrates of coffee, tea or maté and preparations with a basis of any of these products 
• roasted chicory and other roasted coffee substitutes, and extracts, essences and concentrates of these products 
• soup stocks and flavourings packaged for the final consumer, including miso containing a small amount of fish soup stock, and soy sauce containing a small amount of fish soup stock 
• food supplements that are packaged for the final consumer and contain ​​​small (in total less than 20%) ​amounts of animal products or glucosamine, chondroitin or chitosan 
• liqueurs and cordials

Products which meet UK public health standards and do not require certification or controls at agri-food points of entry under the Official Controls Regulation. These products include:

• processed or canned fruit and vegetables (including ​​fruit juices)​​     ​ 
• frozen peas 
• dried herbs and spices 
• flavourings 
• plant-based milks such as oat, almond and soy milk 
• jam 
• peanut butter 
• maple syrup and other syrups 
• olive oil 
• vinegar 
• tomato ketchup or other fruit and vegetable condiments 
• jars of pasta sauce 
• nuts and seeds 
• popcorn, crackers and crisps 
• tomato soup 
• frozen chips 
• tea bags, dried tea leaves, and coffee 
• cereals 
• flour 
• rice 
• natural sugar 
• wine 
• soft drinks 
• ​​​​​beer and cider​​​​​​ 
• ​​​spring water, mineral water and other bottled waters​​

Deregulated fruits are also exempt from individual labels: 

• pineapples 
• bananas 
• coconuts 
• dates 
• durians 

The list of products that are exempt from individual labelling could change over time.

Box label requirements

Where products are not individually labelled with the words ‘Not for EU’, there are requirements to label the box or crate. 

As more products are individually labelled in phases 2 and 3, the requirement for box labelling of those products will cease. 

It is recognised that businesses move products in different ways. Therefore, this requirement should be implemented in the most pragmatic way possible, such as: 

• labelling of shrink wrap which is not removed until products are unloaded at stores where appropriate, for example because products are not stored in boxes or crates
• if products are not stored in boxes, crates or shrink wrap, you can label the cage. 
• you do not need to label the tray that protects products or prevents leakage if the box is labelled
• during transportation a cage can function as a box if it is a fully enclosed container until it arrives in Northern Ireland. This means that cages must be securely wrapped with tape with the words ‘Not for EU’ to function as ‘boxes’

The Government will ​continue to ​engage with retailers on the practical methods that can be used to meet this requirement.

Labelling for retailer premises in Northern Ireland

Where products do not have an individual product label, retail premises in Northern Ireland must make sure there is appropriate visibility to customers in store that these goods are not to be sold in the EU. This requirement is in effect from 1 October 2023. 

These requirements apply to all retail establishments in Northern Ireland. 

Food products that do not have an individual product label and have moved under NIRMS should have shelf-level labels with the words ‘Not for EU’. 

Businesses may have a range of different ways of displaying and indicating the price of products and can take this into account when labelling a shelf. This can include:

• the individual price tag on the shelf
• a separate label next to the price tag on the shelf

The government will continue to engage with industry on the practical ways in which these requirements can be met. 

Retail premises must display posters in their stores, so that customers are aware that goods moved to Northern Ireland under NIRMS are intended for consumption in the United Kingdom ​and are​ not to be sold or consumed in the EU. 

Posters may be in paper or digital format. Retail premises can create their own posters with the relevant information. The positioning and number of posters is at the discretion of individual stores. ​​​The government has provided poster templates which retailers may choose to use instead of creating their own​.​​​​ 

Catering operators do not need to label shelves for food products that are intended to be eaten on the spot in Northern Ireland. This includes food products in a factory canteen, institutional canteen, catered event, or restaurant.​​ 

​​Retail premises are responsible for ensuring that these arrangements are in place.​

30-day transition period

The UK government recognises that there will already be products on the market in Northern Ireland when each new phase comes into effect. Therefore, there will be a 30-day transition period at the start of each phase. This means that goods that are already on the market will not need to be re-labelled and will be able to be sold during the transition period. 

After each transition period ends, relevant goods will need to be labelled with the words ‘Not for EU‘ both on boxes and individual products in line with these requirements.​​  

​​Phase 2 products that were moved into Northern Ireland before 1 October 2024 will not need an individual product label until 31 October 2024. 

Phase 3 products that were moved into Northern Ireland before 1 July 2025 will not need an individual product label until 31 July 2025.

Technical requirements for product labelling

The labels can be written, printed, stencilled, marked, embossed, impressed on or attached to the product, box or shelf. The labels can be adhesive labels (stickers) or sticky tape, but they must not be easily removable. 

The label must be easy to see, clear to read and unlikely to fall off or be easily removed. It should not be hidden or covered by any other writing or pictures. 

On boxes, crates, and products, you can put the label anywhere. It can be incorporated into individual packaging as long as it does not cover any other required information. 

You only need to label the outer packaging of a multipack.

Products should be marked in line with existing UK labelling requirements.

Enforcing the labelling requirements

Authorities will carry out proportionate risk-based and intelligence-led checks to ensure that these requirements are in place.

Last updated: 9 September 2024

Individual labels are required on all prepacked meat, prepacked meat products, meat packed on sales premises, and some dairy products moving between Great Britain and Northern Ireland under NIRMS. 

‘Prepacked’ means packed for the final consumer, so that the contents cannot be altered without opening or changing the packaging. 

‘Processing’ refers to any action that substantially alters the original product. This includes heating, smoking, curing, maturing, drying, marinating, extraction, extrusion, or a combination of any of those processes. 

Compound products are products that contain more than one product of animal origin (POAO) and no plant products other than those for flavouring. Compound products are included in phase 1 if they contain products in the phase 1 list. For example, a pâté that has a duck and a dairy product, or a steak with a butter pellet would be compound products and part of phase 1. This is because they only contain meat and dairy as the main ingredients and have a small amount of plant products for flavour. 

Find out how to identify compound products.

Prepacked meat

‘Meat’ is defined as the edible parts of any animal intended for human consumption. ‘Prepacked meat’ includes chilled, frozen, dried, and ambient meat.

Meat includes but is not limited to:

• red meats – lamb, beef, pork, steak, minced meat, veal, venison 
• game meats – rabbit, hares, rodents, game birds 
• ‘exotic’ meats which are intended for human consumption - kangaroo, ostrich 
• any domestic bovine species including bison and bubalus species 
• other domestic species of ‘red meats’ including swine, ovine, caprine and domestic solipeds 
• poultry including chickens, turkey, any farmed domestic birds, and any farmed wild birds 
• any wild game, including wild birds or wild land mammals, that are hunted for consumption, whether they are truly wild or kept in wild-like conditions to be hunted 
• any lagomorphs which live in the wild and are hunted for consumption 
• animal blood 
• meat preparations 
• fresh meat 
• any other products produced from parts of animals, including gelatine (sweets with gelatine do not need to be individually labelled as they are shelf-stable products)
• processed meat such as chicken nuggets – for example, chicken wings or breasts, any meat mince, steaks and joints, burgers, sliced meats, breaded chicken such as fillets, dippers or nuggets, duck or goose fat, pâté, and sausages including cocktail sausages

Prepacked meat products

These are meat products which have undergone an action that substantially alters the initial product, including heating, smoking, curing, maturing, drying, marinating, extraction, extrusion or a combination of those processes. 

These products could be fresh, chilled, frozen, deep-frozen or thawed.

Meat packed on sales premises

This is meat which is prepared and packed before sale to a consumer, such as:

• meat and animal origin products which are butchered on site, packaged and sold on the shop floor, like cuts of steak or lamb, fresh poultry or cuts of game
• meat products which are processed and packaged on site, like fresh mince products or burgers
• meat on supermarket deli or butcher counters where the product is packaged before sale

Some dairy products (including both prepacked and packed on sales premises)

This includes:

• pasteurised milk, buttermilk or cream products
• cottage cheese, quark cheese or raw (unprocessed) cheese, of any animal origin
• crème fraiche and sour cream

Last updated: 9 September 2024

From 1 October 2024, in addition to the phase 1 products, all milk and dairy products moving to Northern Ireland under the Retail Movement Scheme will need to be individually labelled at product level.

Dairy products are processed products resulting from the processing of raw milk or any products produced from further processing of other dairy products. Dairy products include:

• all milk, buttermilk or cream
• whey
• butter
• butteroil
• caseins
• anhydrous milk fat (AMF)
• cheese
• yogurt
• kefir
• koumiss
• viili or fil
• smetana
• fil
• rjaženka
• rūgušpiens
• flavoured dairy products 
• ice cream made solely from dairy products, stabilisers and flavourings
• UHT milk and products made from UHT milk 
• thermised milk and products made from thermised milk

Phase 2 does not include composite products that contain products from this list. For example, a chilled pizza with processed cheese would come into force in phase 3. 

However, it is not a composite product if a plant product adds special characteristics to a POAO, like flavour, sweetness or acts as a thickening or decorative agent. Therefore, it needs to be individually product labelled. For example, if herbs are added to cheese or fruit is added to yoghurt, or a breaded cheese such as mozzarella sticks, the products are still dairy products as the plant product only adds flavour. 

Compound products which include dairy products combined with another POAO product such as dairy or fish, require labelling in phase 2. For example, fish with a separate sauce or prawns packaged with a dairy dip.

Last updated: 9 September 2024

From 1 July 2025, additional food products that move through NIRMS must be individually labelled. This includes pet food, unprocessed fruit and vegetables, fish, eggs, honey and composite products, such as pizza. 

Composite products are products that contain both products of plant origin and processed products of animal origin (POAO) for human consumption. For example, composite products include:

• lasagne
• pork pies
• scotch eggs
• pepperoni pizza
• ice creams that are a mix of dairy products and plant products not used for flavouring (such as oils)

Phases 1 and 2 do not include composite products. The labelling requirements for composite products come into force in phase 3.

Last updated: 9 September 2024

There are specific requirements for Northern Ireland retailers labelling certain agri-food products under the Northern Ireland Retail Movement Scheme.

Individual labels

Under NIRMS, some food products require individual product labels with the words ‘Not for EU’. These requirements will be introduced in 3 phases from October 2023 to July 2025. This includes products imported into Great Britain from the EU and products from the rest of the world that can move under NIRMS.  

Only products moving into Northern Ireland under NIRMS will need to meet the labelling requirements.

Phase 1: Labelling requirements from 1 October 2023

All meat products and some dairy products that are moving from Great Britain to Northern Ireland under NIRMS need to be individually labelled. You should read the descriptions of phase 1 products in this guidance. You can also look at the full list of commodity codes that are in scope for phase 1. This list may change or be updated in the future. Any dairy product that is not included in this list must be labelled in Phase 2.

Read more about phase 1 of the NI Retail Movement Scheme.

Phase 2: Labelling requirements from 1 October 2024

From 1 October 2024, as well as the phase 1 products, all milk and dairy products moving to Northern Ireland under NIRMS need to be individually labelled. Find the full list of commodity codes that are in scope for phase 2. This list is subject to change and may be updated in the future. You should refer to the descriptions in this guidance.

Read more about phase 2 of the NI Retail Movement Scheme.

Phase 3: Labelling requirements from 1 July 2025

From 1 July 2025, composite products, fruit, vegetables, ​​​​fish, ​​and some other products moving to Northern Ireland under NIRMS will also need to be individually labelled.  

Not all products moved under NIRMS need to be individually labelled. There is an exception list below of products that do not need to be individually labelled under NIRMS. If products are individually labelled, you do not need to label the box or have appropriate signage.

Read more about phase 3 of the NI Retail Movement Scheme.

Exceptions: food products that do not need individual labels

You will not need to individually label the following products, (although box and retail premises labelling requirements apply):

• products sold loose or by weight on the sales premises at the consumer’s request  
• products processed and sold on the sales premises by a retailer, at the consumer’s request, for direct consumption 
• products that are for sale in a factory canteen, institutional canteen, restaurant, or other similar food service operator, and are intended for eating on the spot in Northern Ireland

Shelf-stable composite products include:

• Confectionery (including sweets) and white chocolate, not containing cocoa, and confectionery (including sweets), chocolate and other food preparations, spreads, and preparations for making beverages, containing cocoa 
• pasta, noodles and couscous, not mixed or filled with meat products 
• prepared foods obtained by the swelling or roasting of cereals or cereal products, prepared foods obtained from unroasted cereal flakes or from mixtures of unroasted cereal flakes and roasted cereal flakes or swelled cereal 
• bread, cakes, biscuits, waffles and wafers, rusks, toasted bread and similar toasted products and chips and crisps 
• olives stuffed with fish 
• extracts, essences and concentrates of coffee, tea or maté and preparations with a basis of any of these products 
• roasted chicory and other roasted coffee substitutes, and extracts, essences and concentrates of these products 
• soup stocks and flavourings packaged for the final consumer, including miso containing a small amount of fish soup stock, and soy sauce containing a small amount of fish soup stock 
• food supplements that are packaged for the final consumer and contain ​​​small (in total less than 20%) ​amounts of animal products or glucosamine, chondroitin or chitosan 
• liqueurs and cordials

Products which meet UK public health standards and do not require certification or controls at agri-food points of entry under the Official Controls Regulation. These products include:

• processed or canned fruit and vegetables (including ​​fruit juices)​​     ​ 
• frozen peas 
• dried herbs and spices 
• flavourings 
• plant-based milks such as oat, almond and soy milk 
• jam 
• peanut butter 
• maple syrup and other syrups 
• olive oil 
• vinegar 
• tomato ketchup or other fruit and vegetable condiments 
• jars of pasta sauce 
• nuts and seeds 
• popcorn, crackers and crisps 
• tomato soup 
• frozen chips 
• tea bags, dried tea leaves, and coffee 
• cereals 
• flour 
• rice 
• natural sugar 
• wine 
• soft drinks 
• ​​​​​beer and cider​​​​​​ 
• ​​​spring water, mineral water and other bottled waters​​

Deregulated fruits are also exempt from individual labels: 

• pineapples 
• bananas 
• coconuts 
• dates 
• durians 

The list of products that are exempt from individual labelling could change over time.

Box label requirements

Where products are not individually labelled with the words ‘Not for EU’, there are requirements to label the box or crate. 

As more products are individually labelled in phases 2 and 3, the requirement for box labelling of those products will cease. 

It is recognised that businesses move products in different ways. Therefore, this requirement should be implemented in the most pragmatic way possible, such as: 

• labelling of shrink wrap which is not removed until products are unloaded at stores where appropriate, for example because products are not stored in boxes or crates
• if products are not stored in boxes, crates or shrink wrap, you can label the cage. 
• you do not need to label the tray that protects products or prevents leakage if the box is labelled
• during transportation a cage can function as a box if it is a fully enclosed container until it arrives in Northern Ireland. This means that cages must be securely wrapped with tape with the words ‘Not for EU’ to function as ‘boxes’

The Government will ​continue to ​engage with retailers on the practical methods that can be used to meet this requirement.

Labelling for retailer premises in Northern Ireland

Where products do not have an individual product label, retail premises in Northern Ireland must make sure there is appropriate visibility to customers in store that these goods are not to be sold in the EU. This requirement is in effect from 1 October 2023. 

These requirements apply to all retail establishments in Northern Ireland. 

Food products that do not have an individual product label and have moved under NIRMS should have shelf-level labels with the words ‘Not for EU’. 

Businesses may have a range of different ways of displaying and indicating the price of products and can take this into account when labelling a shelf. This can include:

• the individual price tag on the shelf
• a separate label next to the price tag on the shelf

The government will continue to engage with industry on the practical ways in which these requirements can be met. 

Retail premises must display posters in their stores, so that customers are aware that goods moved to Northern Ireland under NIRMS are intended for consumption in the United Kingdom ​and are​ not to be sold or consumed in the EU. 

Posters may be in paper or digital format. Retail premises can create their own posters with the relevant information. The positioning and number of posters is at the discretion of individual stores. ​​​The government has provided poster templates which retailers may choose to use instead of creating their own​.​​​​ 

Catering operators do not need to label shelves for food products that are intended to be eaten on the spot in Northern Ireland. This includes food products in a factory canteen, institutional canteen, catered event, or restaurant.​​ 

​​Retail premises are responsible for ensuring that these arrangements are in place.​

30-day transition period

The UK government recognises that there will already be products on the market in Northern Ireland when each new phase comes into effect. Therefore, there will be a 30-day transition period at the start of each phase. This means that goods that are already on the market will not need to be re-labelled and will be able to be sold during the transition period. 

After each transition period ends, relevant goods will need to be labelled with the words ‘Not for EU‘ both on boxes and individual products in line with these requirements.​​  

​​Phase 2 products that were moved into Northern Ireland before 1 October 2024 will not need an individual product label until 31 October 2024. 

Phase 3 products that were moved into Northern Ireland before 1 July 2025 will not need an individual product label until 31 July 2025.

Technical requirements for product labelling

The labels can be written, printed, stencilled, marked, embossed, impressed on or attached to the product, box or shelf. The labels can be adhesive labels (stickers) or sticky tape, but they must not be easily removable. 

The label must be easy to see, clear to read and unlikely to fall off or be easily removed. It should not be hidden or covered by any other writing or pictures. 

On boxes, crates, and products, you can put the label anywhere. It can be incorporated into individual packaging as long as it does not cover any other required information. 

You only need to label the outer packaging of a multipack.

Products should be marked in line with existing UK labelling requirements.

Enforcing the labelling requirements

Authorities will carry out proportionate risk-based and intelligence-led checks to ensure that these requirements are in place.

Last updated: 9 September 2024

Individual labels are required on all prepacked meat, prepacked meat products, meat packed on sales premises, and some dairy products moving between Great Britain and Northern Ireland under NIRMS. 

‘Prepacked’ means packed for the final consumer, so that the contents cannot be altered without opening or changing the packaging. 

‘Processing’ refers to any action that substantially alters the original product. This includes heating, smoking, curing, maturing, drying, marinating, extraction, extrusion, or a combination of any of those processes. 

Compound products are products that contain more than one product of animal origin (POAO) and no plant products other than those for flavouring. Compound products are included in phase 1 if they contain products in the phase 1 list. For example, a pâté that has a duck and a dairy product, or a steak with a butter pellet would be compound products and part of phase 1. This is because they only contain meat and dairy as the main ingredients and have a small amount of plant products for flavour. 

Find out how to identify compound products.

Prepacked meat

‘Meat’ is defined as the edible parts of any animal intended for human consumption. ‘Prepacked meat’ includes chilled, frozen, dried, and ambient meat.

Meat includes but is not limited to:

• red meats – lamb, beef, pork, steak, minced meat, veal, venison 
• game meats – rabbit, hares, rodents, game birds 
• ‘exotic’ meats which are intended for human consumption - kangaroo, ostrich 
• any domestic bovine species including bison and bubalus species 
• other domestic species of ‘red meats’ including swine, ovine, caprine and domestic solipeds 
• poultry including chickens, turkey, any farmed domestic birds, and any farmed wild birds 
• any wild game, including wild birds or wild land mammals, that are hunted for consumption, whether they are truly wild or kept in wild-like conditions to be hunted 
• any lagomorphs which live in the wild and are hunted for consumption 
• animal blood 
• meat preparations 
• fresh meat 
• any other products produced from parts of animals, including gelatine (sweets with gelatine do not need to be individually labelled as they are shelf-stable products)
• processed meat such as chicken nuggets – for example, chicken wings or breasts, any meat mince, steaks and joints, burgers, sliced meats, breaded chicken such as fillets, dippers or nuggets, duck or goose fat, pâté, and sausages including cocktail sausages

Prepacked meat products

These are meat products which have undergone an action that substantially alters the initial product, including heating, smoking, curing, maturing, drying, marinating, extraction, extrusion or a combination of those processes. 

These products could be fresh, chilled, frozen, deep-frozen or thawed.

Meat packed on sales premises

This is meat which is prepared and packed before sale to a consumer, such as:

• meat and animal origin products which are butchered on site, packaged and sold on the shop floor, like cuts of steak or lamb, fresh poultry or cuts of game
• meat products which are processed and packaged on site, like fresh mince products or burgers
• meat on supermarket deli or butcher counters where the product is packaged before sale

Some dairy products (including both prepacked and packed on sales premises)

This includes:

• pasteurised milk, buttermilk or cream products
• cottage cheese, quark cheese or raw (unprocessed) cheese, of any animal origin
• crème fraiche and sour cream

Last updated: 9 September 2024

From 1 October 2024, in addition to the phase 1 products, all milk and dairy products moving to Northern Ireland under the Retail Movement Scheme will need to be individually labelled at product level.

Dairy products are processed products resulting from the processing of raw milk or any products produced from further processing of other dairy products. Dairy products include:

• all milk, buttermilk or cream
• whey
• butter
• butteroil
• caseins
• anhydrous milk fat (AMF)
• cheese
• yogurt
• kefir
• koumiss
• viili or fil
• smetana
• fil
• rjaženka
• rūgušpiens
• flavoured dairy products 
• ice cream made solely from dairy products, stabilisers and flavourings
• UHT milk and products made from UHT milk 
• thermised milk and products made from thermised milk

Phase 2 does not include composite products that contain products from this list. For example, a chilled pizza with processed cheese would come into force in phase 3. 

However, it is not a composite product if a plant product adds special characteristics to a POAO, like flavour, sweetness or acts as a thickening or decorative agent. Therefore, it needs to be individually product labelled. For example, if herbs are added to cheese or fruit is added to yoghurt, or a breaded cheese such as mozzarella sticks, the products are still dairy products as the plant product only adds flavour. 

Compound products which include dairy products combined with another POAO product such as dairy or fish, require labelling in phase 2. For example, fish with a separate sauce or prawns packaged with a dairy dip.

Last updated: 9 September 2024

From 1 July 2025, additional food products that move through NIRMS must be individually labelled. This includes pet food, unprocessed fruit and vegetables, fish, eggs, honey and composite products, such as pizza. 

Composite products are products that contain both products of plant origin and processed products of animal origin (POAO) for human consumption. For example, composite products include:

• lasagne
• pork pies
• scotch eggs
• pepperoni pizza
• ice creams that are a mix of dairy products and plant products not used for flavouring (such as oils)

Phases 1 and 2 do not include composite products. The labelling requirements for composite products come into force in phase 3.