The Export of Sauces to the United Kingdom Legal Requirements & Standards

  • Product Description and Classification
  • Mandatory Requirements
  • What Additional Requirements Do Buyers Often Have?
  • What Are the Requirements for Niche Markets?
  • Which Quality Support Organizations in Lebanon Can Help Me?
  • Reference

Product Description and Classification

Sauces and pastes mainly consist of a combination of ingredients to form a harmonious taste. A sauce changes a dish by adding flavors, texture, viscosity and moistness to food. It can be based on (or include) a variety of ingredients such as the juice of fruits and vegetables, vegetable oil, herbs, wine, aromatics, dairy, honey, vinegar, nuts and molasses. The sauce can balance the flavors between salt, bitter, sweet, sour and umami, depending on the dish that is being prepared. Also the sauces can differ based on the texture and consistency ranging from thin sauces to thickened sauces.

Sauces include ready-to-eat sauces, gravies, and dressings, and mixes to be reconstituted before consumption. The ready-to-eat products are divided into subcategories for emulsified and non-emulsified products, whereas the mixes are divided into subcategories that encompass both emulsified and non-emulsified sauce mixes :
  • Emulsified sauces and dips (e.g., mayonnaise, salad dressing, onion dips), such as sauces, gravies, dressing-based sauces and dips, at least in part, in a fat- or oil-in-water emulsion—examples include salad dressing (e.g., French, Italian, Greek, ranch style), fat-based sandwich spreads (e.g., mayonnaise with mustard), salad cream, and fatty sauces and snack dips (e.g., bacon and cheddar dip, onion dip).
  • Non-emulsified sauces (e.g., ketchup, cheese sauce, cream sauce, brown gravy) include water, coconut milk, and milk-based sauces, gravies, and dressings, such as barbecue (BBQ) sauce, tomato ketchup, cheese sauce, Worcestershire sauce, Asian thick Worcestershire sauce (tonkatsu sauce), chili sauce, sweet and sour sauce, and white sauce (milk-based sauce, with little added fat and flour)
  • Mixes for sauces and gravies are concentrated products, usually in powdered form, to be mixed with water, milk, oil, or other liquid to prepare a finished sauce or gravy, including mixes for cheese sauce, hollandaise sauce, and salad dressing (e.g., Italian or ranch dressing) Clear sauces (e.g., fish sauce) include thin, non-emulsified clear sauces that may be water based and used as condiments or ingredients rather than as finished gravy. Examples include oyster sauce and Thai fish sauce (nam pla).
The most known dips in Lebanon include Hummus, Mutabal, Garlic paste, Muhamarra, Tarator, Labneh-based dip, while sauces may be concentrated around lemon, olive oil, pomegranate molasses, yogurt, tomato, honey, vinegar, pepper and herbs among others. This report uses the combined nomenclature code 2103 ‘Sauces and preparations therefor; mixed condiments and mixed seasonings; mustard flour and meal, whether or not prepared, and mustard’.

Combined Nomenclature Number Product 210310 Soya sauce 210320 Tomato Ketchup and other tomato sauces 210330 Mustard flour and meal and prepared mustard 210390 Other

Mandatory Requirements

The Department for Environment, Food & Rural Affairs is the main authority that is concerned with international trade of food in the UK, while the Food Standard Agency is the government department aiming to protect consumers in England, Wales and Northern Island. When exporting food to the UK, most products that are not from animal origins may enter any port, however, it is important to contact the port before sending the products. The food should meet the general food safety legal requirements, under Regulation 178/2002, it must not be injurious to health and unfit for human consumption. It identifies food containing animal products as food that includes meat, poultry, fish, eggs, dairy products and honey, while products that have no animal content contain fruit, vegetables, cereals, certain bakery products, herbs, spices, mineral water and fruit juices.

When importing trade samples of food in the UK, mainly to test marketing, quality assurances or research and development, they may enter the country freely, if they do not include animal-based products. Samples must be edible and free from contamination. The importers should make sure that their products are legal and safe before purchasing from producers or importing them in the country.

While there is no legal requirement for importers to test the samples, public analysts are available to test food samples and make sure they comply with food safety requirements by undertaking chemical analysis and/or by arranging for microbiological examination.

All UK imports of animal origin products require health certificates, while plant products that could introduce pests require a phytosanitary certificate.

In case you’re directly exporting to the UK, your company must be registered in the United Kingdom or the exporter should deal with a register exporting company or a certified custom broker.

Several steps are needed in order to export to the United Kingdom, but before you get help, you’ll need:

  • Evidence of the goods you’re importing or exporting, or goods you intend to import or export, for example invoices or contracts
  • A full description of the goods you import or export
  • To check the goods, you intend to import are eligible if you’re using simplified declaration processes
  • your Economic Operators Registration and Identification number (EORI number)
You’ll need to check with the person or business doing customs for you whether you need to provide anything else.

You’ll need to confirm in writing the terms and conditions of your representation and keep a copy of this agreement for your own records.

Apply for EORI Number:

EORI stands for “Economic Operators Registration and Identification number”. Businesses and people wishing to trade must use the EORI number as an identification number in all customs procedures when exchanging information with Customs administrations. The EORI number acts as a means of providing security and statistics in international trade and is used by customs authorities when exchanging information between themselves and with government departments.
You need an EORI number that starts with GB to import goods into England, Wales or Scotland. You'll need a new one if you have an EORI that does not start with GB. If you move goods to or from Northern Ireland you may need one that starts with XI. In addition, you’ll need your EORI number if you:

  • Appoint someone to deal with customs for you and are ‘established’ in the country you’re importing to or exporting from
  • Make customs declarations
  • Use customs systems, such as the CHIEF system and the Import Control System Northern Ireland (ICS NI)
  • Apply for a customs decision
For ID and GB number please check Get and EORI Number.

You can find lists of custom agents and registered organization that works on facilitating and importing products to the United Kingdom.

In terms of guidance for traders on importing certain foodstuffs, the trade information page provides guidance and advice on labelling, packaging, chemical safety, additives and organic products for food categories.

The imports of table sauces, which do not contain products of animal origin, should meet the same or equivalent food hygiene and compositional standards and procedures as food produced in Great Britain. Normally, these products do not require a health certificate to be imported in the country.

While they may not need a hygiene or health certificate, some foods could require trade-related licenses, and may be subject for quotas. For such information, please check the Rural Payments Agency's website.

Also, some sauces could contain flavourings, colourings or sweeteners. Some of these may not be approved in the UK. As such, you can contact the food additives team for more information.

In addition, the UK Integrated Online Tariff can help you identify the types of licenses you need to export your products from Lebanon to the UK.

Further, the Food Hygiene Policy team provides answers to inquiries related to food hygiene in the UK.

In parallel, imports of certain foods under the sauces, pickles, preserves and chutney products that contain nuts, dried fruits or spices are subject to special conditions due to contamination risk by aflatoxins. Such products can only enter Great Britain through specific airports and ports that have border control posts. Also, the contaminants legislation puts a limit for the 3-monochloropropanediol (3-MCPD) in soy sauce and similar sauces and hydrolysed vegetable protein (HVP). Information on such contamination can be found on chemical contaminants page as well as the page on mycotoxins. You can also contact the chemical contaminants team. For additional information about pesticides and maximum residue levels, the Health and Safety Executive, Britain’s national regulator for workplace health and safety, provide industry guidance on the usage of pesticide.

The Food Standards Agency provides guidance for importing sauces containing products of animal origin. However, it is important to note that currently all food products of animal origin from Lebanon such as dairy, meat, honey, eggs among others, are not allowed to enter the UK.


Tips

  • Having a market entry strategy is important in order to decide if you want to export yourself, or rely on an importer in the country, and to know which licenses or registration process you might require
  • For the procedures, you can check the step-by-step guidelines provided by the government
  • Make sure that the food is safe as per the requirements of the Regulation 178/2002
  • Check the requirements for sweeteners, additives, colouring and additives by contacting the food additives team
  • Get the published information on chemical contaminants
  • Make sure whether you need any certificates, and if your product is subject to quotas by checking the Rural Payments Agency's website
  • Check the types of licenses you need to export your products from Lebanon to the UK by using the UK Integrated Online Tariff
  • Explore the UK Market Report for information on the trade agreement between Lebanon and the UK, as well as general legal requirements to export food products to the UK

Packaging and Labelling


In terms of packaging, food contact materials are controlled by retained UK law, which is rigorous in controlling plastic materials and articles for food.
The National 2012 regulations identify which breaches constitute an offence, and thus incur a penalty and what constitutes a competent authority.
Food Contact Materials are articles and materials that come into contact with food during its production, processing, storage, preparation or serving, such as containers for the transportation of food, packaging materials, Kitchenware and tableware.

Specific regulation of food contact materials cover plastic monomers and additives, active/intelligence materials, recycled plastic processes, regenerated cellulose film. You can find these laws and guidance on the Food contact materials authorisation guidance. For more information, you can contact the Food Contact Materials team.
Labeling Requirements:

Labels must be easy to read and understand and visible.
You must show the following information:
  • the name of the food
  • a ‘best before’ or ‘use by’ date
  • any necessary warnings
  • net quantity information
  • a list of ingredients (if there is more than 1)
  • the country or place of origin, if required
  • the lot number or use-by date
  • any special storage conditions
  • instructions for use or cooking, if necessary
If you’re selling food in Great Britain (England, Wales and Scotland), you must also include the name and address of the UK or EU business responsible for the information on the food. If the business is not in the UK or EU, you must include the name and address of the importer. You must put the net quantity in grams, kilograms, millilitres or litres on the label of:
  • packaged food over 5g or 5ml
  • packaged herbs and spices
Solid foods packed in a liquid (or an ice glaze) must show the drained net weight.
The net quantity must be close enough to the name of the food that you can see all this information at the same time. This also applies to the alcoholic strength for alcoholic drinks.
You must also show these if they apply to your product:
  • a warning for drinks with an alcohol content above 1.2%
  • a warning if the product contains Genetically-Modified ingredients, unless their presence is accidental and 0.9% or less
  • a warning if the product has been irradiated
  • the words ‘packaged in a protective atmosphere’ if the food is packaged using a packaging gas

Quality Requirements


According to the Department for Environment, Food & Rural Affairs, food compositional standards apply to products which consumers expect to be of certain quality, or foods that are at risk of being substituted by a lower quality alternative.

In terms of international standards, all entities tend to revert back to the Codex Alimentarius, which provides international food standards, guidelines and codes of practice to ensure quality and safety of foods and agricultural products in international trade, despite being a voluntary good practice and not mandatory. In general, food standards in the UK tend to go beyond the Codex international standards.

For the making of sauces, Codex Alimentarius provides standards for canned applesauce, fish sauce, a regional standard for chilli sauce, processed tomato concentrates, humus with tehena, red hot pepper paste, among others.

These standards can help you in producing an internationally accepted product. You can contact the Department for Environment, Food and Rural Affairs for more information about international standards.

Tips

What Additional Requirements Do Buyers Often Have?

Food Safety Certification


When importing food from outside the EU to the UK, the products are required to comply with UK and EU safety, hygiene, food composition regulations and labeling. The hazard analysis and critical control point after the primary production phased (HACCP), which is an internationally recognized method to identify and manage risks related to food safety, is used. There are several international institutions providing such certificates that ensure food safety across the supply chain. Non-EU producers must have an equivalent system in place.
Compliance with such additional standards will make it easier for sauces products to enter the UK market, and help them gain competitive advantages relative to their competitors. Moreover, certifications concerning general quality and food safety management systems from recognized and trustworthy sources demonstrate the supplier’s commitment to high and consistent quality and safety.

Similarly, buyers may ask for a Global Food Safety Initiative (GFSI) recognized certification. You can find some of the most common certifications in the food industry:
You can also check the complete list of GFSI recognized certification programs, for additional information.
Although the various food safety certification systems are based on similar principles, some buyers prefer one specific standard over the other.

What Are the Requirements for Niche Markets?

Organic Products


The organic food and drink market is growing in the UK, and was the fourth largest in Europe as of 2019, worth EUR2.68bn. Supermarkets and specialist retailers are the most important sales channels for such products. To market sauces products as organic in the UK, all organic products must have a valid certificate of inspection. You will need an interim manual GB organic import system; contact the approved organic bodies to request the forms for the manual organic import system. To certify the product organic outside the UK, the authorities provide a list of organizations and third countries that could certify organic products to import in the UK. For products packed in the UK, Soil Association offers organic certification. When labeling a product as organic, this means that at least 95% of the product’s agricultural ingredients are organic and other ingredients, additives and processing aids should be listed as per the organic regulation. To label the product as organic, register with a UK organic control body. The importer should include the control body code number on the label, as well as a statement of agricultural origin. Putting the EU organic logo is optional, and its usage requires that the product meets the EU organic labeling requirements and include an EU statement of origin. For more information about the UK organic regulations as well as about the organic labeling check the Guidance on organic food: labeling and advertising rules.

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Tips

Sustainability Certification


PwC’s Consumer Intelligence indicated that about 80% of consumers in the UK are more likely to buy from companies that are responding to their environmental impac. In addition, they are concerned with packaging and many consumers want to get rid of plastic packaging when possible. In fact, sustainability has become a new way to conduct business rather than an attractive feature to add. This is pushing producers to conduct a comprehensive life-cycle review of their product. Furthermore, transparency has become critical to proving the sustainable choices the company is taking.

The definition of sustainability varies across a product’s supply chain. Some producers increasingly focus on reducing CO2 emissions, whereas others focus on waste reduction, in the processing of foods as well as in the packaging. Currently, the most famous certification schemes focus on environmental impacts and ethical aspects. Several sustainability private certifications, standards, audits, and initiatives are already well known. Some focus on social and ethical impacts, such as FairTrade, SMETA, Ethical Trading Initiative, amfori BSCI, BCorp, or Fair for Life. Others focus on a wider range of environmental issues such as < a target="_blank" href="http://www.rainforest-alliance.org/">Rainforest Alliance or ISO 14000, while some only deal with CO2 emissions such as Carbon Footprint Certification.

Other entities provide certification schemes that cover a wide range of features, such as the FSCC 22000 Scheme, requiring the ISO 22000, sector-specific pre-requisite programs (ISO/TS standards and BSI PAS), and specific requirements to ensure consistency, integrity, and governance management of the scheme. Also, the IFS International Featured Standards focus on food safety and quality management systems, and governance and commitment, among other aspects of transparency and control for hazards. The ISO 26000 Social Responsibility provides guidance for companies committed to social responsibility and sustainability. In addition, SGS supports companies in having processes and systems that comply with quality, health, and safety requirements as well as environmental and social responsibility. You can check a list of ecolabels in the UK on the Ecolabel Index.
According to a survey conducted by Deloitte, 62% of surveyed consumers in Britain are more likely to shop from businesses that care about the safety and wellbeing of their employees. As such, purchasers might anticipate suppliers to comply with the codes of conduct regarding social responsibility, which are often based on the ILO labor standards. Some companies require adherence to their code of conduct or one or more of the common standards, such as the Supplier Ethical Data Exchange (SEDEX), Ethical Trading Initiative (ETI), and/or Business Social Compliance Initiative’s (BSCI) code of conduct.

Corporate responsibility initiatives also affect you as a supplier. Common requirements include signing a code of conduct for suppliers, in which you declare that you conduct your business in a responsible manner. More specifically, you declare that you (and your suppliers) observe such measures as respecting local environmental and labor laws and avoiding corruption. These aspects are also investigated further in company audits performed by potential buyers.

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Tips

  • Share with consumers your approach towards sustainability; you can highlight it through the packaging of the product, on your website (about us page), or on social media by sharing your story and how you take into account your community throughout the production process.
  • Pay attention to packaging as more consumers are concerned about excessive packaging and waste.
  • Aim for getting sustainability certificates provided by reputable organizations like FairTrade, Rainforest Alliance, or ISO 14000.
  • Use sustainable approaches not only to satisfy consumers but also to improve production efficiency and to cut costs. Consider using sustainability services and tools such as Fair Match Support to track, analyze, and improve your sustainability. Get familiar with social and ethical standards on the International Trade Centre’s Sustainability Map portal. You can use ISO 26000 guidance to improve your business’s sustainability.
  • In selecting suppliers, some UK buyers and retailers are focusing more on suppliers and exporters who have adopted appropriate codes of conduct related to labor and human rights, as well as to the environment. Key references at the international level include the UN Global Compact and ISO 26000 on Social Responsibility.
  • The implementation of a management system (e.g. ISO 14000 for environmental aspects; ISO 45001 for occupational health and safety; or SA 8000 for social conditions) is a complementary strategy for addressing sustainability and, possibly, for gaining a competitive advantage on the Canadian market.
  • Before implementing such systems, however, it is important to consult current or potential buyers to determine the extent to which they require and/or appreciate such standards.

Ethnic Certification


Multiculturalism in the UK is offering producers and untapped market potential in the Islamic dietary laws (Halal) segment, which propose specific restrictions on diets. If you want to focus on the Islamic ethnic niche markets, consider implementing Halal certification schemes.

Vegan


Vegan sauces continue to gain momentum in the UK, especially in terms of mayo and flavored mayo. Consider becoming vegan certified in case you offer such products. Check the Vegetarian Society’s trademarks in the UK, as well as the trademark of The Vegan Society. The Vegan Business Tribe provides insights on how to get certified, as well as names of entities that have such processes in multiple countries.

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Gluten-Free


87% of gluten-free shoppers surveyed by Coeliac UK indicated a reduction in the number of available gluten-free products in the UK . As such, this segment provides also a potential for innovative products, and you can aim for a gluten-free certification, which is provided by institutions like SGS and SAI Global.

Which Quality Support Organizations in Lebanon Can Help Me?

The Lebanese Agricultural Research Institute (LARI) is a governmental organization under the Minister of Agriculture’s supervision. The institute conducts applied and basic scientific research for the development and advancement of the agricultural sector in Lebanon. Extension services for farmers include management of soil fertility, water consumptive use, plant pest, and disease control, crop rotation, and animal disease treatment and prevention, among others.

The Lebanese Standards Institution (LIBNOR) is a public institution attached to the Ministry of Industry. It was established on July 23, 1962 by a law giving it solely the right to prepare, publish, and amend national standards, as well as to grant the Lebanese Conformity Mark NL. Lebanese standards are prepared by technical committees formed by LIBNOR, which include setting the dimensions, conventions, symbols, and the definition of products’ quality, as well as the methods of testing and analysis. They also include the codes of practice for professional and structural work.

The Industrial Research Institute (IRI) is registered as a Lebanese nonprofit institution. It provides, on an international scientific level, reliable services in testing and analysis and grants certificates of quality or conformity with standards and purchase specifications. It also provides specialized technological, management, and economic consulting services to existing industries and industrial development schemes.

The Chamber of Commerce, Industry, and Agriculture of Beirut and Mount Lebanon (CCIA-BML) is a non-profit private organization operating under Decree-Law 36/67. The Lebanese Chambers are the sole providers of consular services, including certification of origin and authentication of commercial documents. Also, the chambers conduct training, develop partnerships, and organize matchmaking events and exhibitions, among other services. The CCIA-BML operates the Lebanese Training Center, which provides managerial and technical training for Lebanese enterprises. In addition, the Chamber of Commerce, Industry, and Agriculture of Tripoli and North Lebanon provides quality control center laboratories, among other services.

Reference

  • Import goods into the UK: step by step, UK Government
  • Imports to Great Britain, Food Standards Agency
  • The Principle of Sauce Making, The Culinary Pro
  • General Standards for Food Additives, CODEX STAN 192-1995, CODEX ALIMENTARIUS
  • What is the demand for natural food additives on the European market?, CBI Ministry of Foreign Affairs
  • Food Hygiene Controls, Brexit Information
  • Food Labelling and packaging, UK Government
  • The Impact of ESG on the UK Food & Drink Sector, 2021 Insight from the Industry, food & drink federation
  • Gluten-free shoppers report food scarcity and soaring prices, The Grocer
  • Organic food: labelling and advertising rules, UK Government
  • Three in five consumers have used more local stores and services to support them during lockdown, Deloitte