Shops in Northern Ireland expected to fall foul of new EU labelling requirements due to kick in this Sunday

That is the view from Neil Johnston of the Northern Ireland Retail Consortium (NIRC), who indicated that smaller businesses which lack the resources of a major supermarket are likely to struggle with the fresh red tape.

He predicts there'll be "a lot of shelves in smaller stores that are not compliant" with the complex array of new rules covering meat, milk, and cream from GB.

Labels saying "not for EU" will be required on all "prepacked" GB meat for sale in the Province, and some dairy products too.

Meanwhile, shopkeepers must put up posters telling customers "those retail goods are only intended for sale to the final consumers in Northern Ireland and are not to be subsequently moved to a member state".

Some have already started to appear in Tesco ahead of the deadline, and in some Centra shops.

However, trying to untangle exactly which foodstuffs this applies to is fiendishly difficult, and gives an insight into the baffling nature of much of the post-Brexit arrangements.

Besides plain meat, for example, among the other meat-related foods which must now be labelled "not for EU" are "compound products", which the government says "includes chicken kievs and cheeseburgers".

But, it adds, this does not include "lasagne, pork pies, or pepperoni pizza".

Instead those items are classed as "composite products".

The government has a website giving guidance about which products must be labelled.

If you search that webpage for what a "compound product" is, it takes you to another long and technical page which does not once mention the term, and instead talks only about "compound ingredients".

As to what a "composite product" is and how it differs from a "compound product", the government's guidance page says: "Composite products are products that contain both products of plant origin and processed products of animal origin for human consumption."

It is a little bit clearer which dairy products are covered.

The government has produced a list of about 50 – mainly milk, cream, sour cream, creme fraiche, and cottage cheese.

These rules are encoded in EU regulation 2023/1231, which was passed in June.

Under these rules, not only must "not for EU" be written on the product packet itself, but "a sufficient number of posters shall be visibly displayed in the vicinity of the retail goods, informing the consumers that those retail goods are only intended for sale to the final consumers in Northern Ireland and are not to be subsequently moved to a member state".

Taken literally, the phrase "are not to be subsequently moved to a member state" suggests that buying a pack of sausages in Newry and eating them in Dundalk is a breach of the rules.

The Department for the Environment, Agriculture, and Rural Affairs (DAERA) was asked how that is supposed to be enforced, and what the penalties would be.

It referred the News Letter to its Westminster counterpart, The Department for Environment, Food and Rural Affairs (DEFRA). It had not responded at time of writing.

Neil Johnston of the Northern Ireland Retail Consortium (NIRC), which represents big-name supermarkets as opposed to smaller businesses, says that many of the rules were only published two months ago and he has been "in constant engagement over the interpretation" ever since.

Despite the uncertainty, his members are "relatively happy that we'll be able to continue the same broad range of choice and value as we do today", though "there may be some issues around some products".

But, he adds, he only represents major-league firms, and "obviously it's a lot easier for larger retailers than the small guys".

"If you're a small enterprise, family-run maybe with 101 things to worry about, and you don't have a big back office, it's easy to see how come Sunday there'll be a lot of shelves in smaller stores that are not compliant.

"But what we've been told is this is about a 'journey to compliance'; nobody is actually going to be coming down like a ton of bricks on Sunday.

"It'll fall to DAERA to enforce it ultimately. What we're hoping is that on Day One it's about making best efforts to comply."