The government is implementing one of the biggest allergen legislation reforms ever this year. The newly-formed Natasha’s Law will make it a legal necessity for all food businesses to include full ingredient labelling on pre-packaged food.

The new allergen legislation, announced by the Department for Environment, Food and Rural Affairs, is to be brought in after the death of Natasha Ednan-Laperouse in 2016, who fatally purchased a sandwich that contained ingredients she was allergic to.

Natasha’s Law, introduced by former environmental secretary Michael Gove, will apply to both England and Northern Ireland. The new law means that all food companies that prepare fresh food on site will have to clearly show the entire ingredient list of all the products on sale to customers.

How will these changes impact the industry?

The trade body for the hospitality sector acknowledged the important issues that led to the introduction of Natasha’s Law. However, they also said that the new food labelling practices could be “impractical and potentially hazardous”.

Voicing her concern, Kate Nicholls, Chief Executive of UK Hospitality, said: “We are worried that full ingredient labelling is going to prevent the kind of dialogue we need to promote. Some smaller businesses may struggle with the unwieldy new legislation. It is almost certainly going to lead to much less choice for customers. There is also a risk that the new measures, which will not circumvent cross-contamination and will be open to mislabelling, will only promote a dangerous reliance on labelling.”

However, Heather Hancock, Chair of the Food Standards Agency, said the new allergen legislation would give better protection for allergy sufferers, explaining “I warmly welcome the Secretary of State’s announcement: this is an important step forward in our ambition for the UK to become the best place in the world for people living with food hypersensitivities. We know that the impact of food allergy and intolerance on quality of life can be as great or even greater than almost all other foodborne diseases.  While it is impossible to eliminate the risks entirely, we believe the Secretary of State’s announcement of this change in the rules will mean better protection for allergic consumers.”

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What is the definition of pre-packed food for direct sale (PPDS)?

The Food Standards Agency (FSA) classes PPDS as food that has been made, packed and sold on the same premises. This includes packaged sandwiches or salads made by staff earlier in the day and placed on a shelf for purchase.

Currently, they don’t need to carry allergen labels or information. This is because the customer can speak directly to the person who made the food. This has led people mistakenly assuming that the food does not contain any allergens.

What does this mean for businesses?

These allergen legislation changes could have a big impact on small and large businesses.

Any food business that prepares or wraps food on their premises must provide full ingredient labelling that includes highlighting allergens.

This will be no mean feat for food businesses, particularly smaller ones. Businesses will have two years before Natasha’s Law comes into force – giving you just enough time to work out how you’ll comply with the law before it is enforced.

No matter the size of your business, you’ll need to develop a system of labelling that allows you to list full ingredients in a way that is both legally compliant and simple to carry out. You should trial your system to check it is effective, easily maintained and accurate.

To do this, staff will need to be suitably trained in the system and in allergenic contamination controls, so they have the knowledge and understanding to ensure allergenic ingredients are correctly recorded and that allergens are not accidentally introduced during preparation.

How will this affect the food industry?

Big businesses are likely to go for an electronic labelling system. This is because they will be working to set recipes and will want their labels to be branded.  While very efficient for large businesses, such systems can be extremely expensive for small businesses.

This means small to medium sized food businesses may end up using handwritten labels.  However, this can be time-consuming as the full ingredients must be labelled.

Our allergen management software in Alert65 – our cloud-based Food Safety solution – can help. It lets you log which of the 14 prescribed allergens are present within each menu item or product, so you stay compliant, as well as providing you with a summary of that information for your customers and guests.

How can we help you adjust to these changes?

Once the exact requirements of the forthcoming legislation are known, we can help you to accurately label Prepacked for Direct Sale (PPDS) foods.

We’ll be incorporating checks on the labelling of these foods into our regular client audits and provide advice and guidance on how to get it right. You’ll need advice immediately from a Food Safety expert to get your business compliant, as any changes must be in place by 2021.

Exactly how businesses will have to change to achieve full ingredient labelling on foods prepared, wrapped and sold on the same premises will be clearer once the exact content of the new allergen legislation is known and FSA guidance is released.

However, it’s safe to say that businesses of all sizes will need to start getting a plan in place.

Do you need help with your allergen management or would like us to assess your current provisions? Be proactive about making these changes. Get in contact with a member of our team today.





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