Preparing for Natasha’s Law.
What operators need to know.
We’ve created a simple guide to help you check if your business is affected by the new allergen labelling requirements along with information detailing what you need to do to comply with the new rules…
About Natasha’s Law
Almost five years after the tragic death of Natasha Ednan-Laperouse, and following a tireless campaign by her parents, Natasha’s Law, will come into effect in a matter of weeks.
From October 2021, any business that produces prepacked for direct sale (PPDS) food will be required to label it with the name of the food and a full ingredients list, with allergenic ingredients emphasised within the list.
Does Natasha’s Law apply to my business?
The new law will apply to all food which is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected.
It can include food that consumers select themselves (e.g. from a display unit), as well as products kept behind a counter and some food sold at mobile or temporary outlets.
Packaging can either be partly open or fully enclosing the food item, meaning the product can’t be altered without opening or changing the packaging, and is ready for sale.
Food that isn't PPDS
Any food that is not in packaging or is packaged after being ordered by the consumer.
These are types of non-prepacked food and do not require a label with name, ingredients and allergens emphasised. Allergen information must still be provided, but this can be done through other means, including verbally.
Food packed by one business and supplied to another business.
This is prepacked food and already must have full labelling, including the name of the food and a full ingredients list, with allergenic ingredients emphasised within it.
Examples of PPDS food
Prepacked for direct sale (PPDS) food can include the following:
Sandwiches and bakery products which are packed on-site before a consumer selects or orders them
Fast food packed before it is ordered, such as a burger under a hot lamp where the food cannot be altered without opening the packaging
Products which are pre-packaged on-site ready for sale, such as pizzas, rotisserie chicken, salads and pasta pots
Burgers and sausages pre-packaged by a butcher on the premises ready for sale to consumers
Samples of cookies given to consumers for free which were packed on-site
Foods packaged and then sold elsewhere by the same operator at a market stall or mobile site
PPDS food provided in schools, care homes or hospitals and other similar settings will also require labelling.
Check if your business sells PPDS food with the FSA’s allergen and ingredients food labelling tool.
What needs to be on the labels?
The label needs to show the name of the food and the ingredients list (including all sub ingredients) with the 14 allergens required to be declared by law emphasised within it. These need to be in line with the legal requirements that apply to naming the food and listing ingredients.
Any of the 14 declarable allergens – celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame seeds, soya, sulphur dioxide and sulphites – will need to be clearly visible on the label and emphasised every time they appear in the ingredients list. This can be done using bold type, capital letters, contrasting colours or through underlining.
Where to start?
You will need to identify all PPDS foods within your business requiring allergen labels, review the sales performance of each product and determine whether you wish to continue to offer these to consumers.
If your list of PPDS food products is manageable, you will need to create a process for capturing and maintaining accurate ingredient information, producing product labels and managing ingredient changes due to supplier changes or substitutions.
You may wish to temporarily reduce the volume of PPDS food products you offer while you establish your allergen labelling processes.
You should also discuss Natasha’s Law and the importance of allergen labelling with your teams to ensure they understand the reasons for the change in law, as well as the potentially life-saving consumer benefits.
How we can help...
We know just how hard it’s been for all businesses over the past year, not least hospitality businesses. With everyone focusing on reopening and surviving, so many businesses have understandably been unable to look ahead to allergen labelling.
But the most important thing is, you still have time – and we really can help!
Our team at Regency Purchasing Group developed MENUIQ, an advanced recipe and menu management system that provides food and drink operators with an effective tool to smoothly manage and share allergen data.
MenuIQ receives real-time product and price data direct from suppliers, produces fully compliant food labels and will alert you immediately should supplier ingredients change. The system will also create and publish interactive customer menus, accessed via a QR code, with allergen and nutrition filters, allowing your consumers to make informed choices.
