Natasha’s Law came into effect on 1 October 2021. This blog from CMC catering explores how schools prepared for the new requirements and any challenges that have been faced in the last 6 months.

The UK Food Information Amendment, also known as Natasha’s Law, requires food businesses to provide full ingredient lists and allergen labelling on foods pre-packaged for direct sale (PPDS) on the premises. The legislation was introduced to protect allergy sufferers and give them confidence in the food they buy.

The consequences of an allergic reaction and anaphylaxis are potentially serious or even deadly – as was sadly the case with Natasha Ednan-Laperouse. This tragic incident demonstrates just how important clear food labelling can be. Unfortunately, incidences of misunderstanding, miscommunication and assumptions can have serious and fatal consequences for allergy sufferers.

According to the new rules, PPDS food must clearly display the following information on the packaging:

  • Name of the food
  • Full ingredients list, with allergenic ingredients emphasised, e.g. in bold, italics or a different colour)

Reflecting on preparing for Natasha’s Law

Ahead of Natasha’s Law being implemented, schools were already aware of their obligation to ensure that accurate ingredient and allergen information is passed to the consumer.

Schools could use the Food Standards Agency’s ‘Food allergen labelling and information: Technical guidance’ to determine if they sold PPDS food. The FSA then published information specific to industry types in July 2021. Although this was a little late in the day, with schools finished for the Summer by this time, the guidance was still welcomed. The guidance helped to determine the when, where and how of operations, with some schools choosing to do away with packaging as much as they could – which had the added bonus of being good for the environment. Then it was down to planning for the products that were classed as PPDS foods.

Catering managers had to be aware that the new legislation applied to all types of food sold and not just sandwiches, for example:

  • Sandwiches packaged by the food business (school) and sold or offered from the same premises.
  • Fast food which is wrapped or packaged before a customer selects or orders it, e.g. burgers, sausage rolls, paninis.
  • Bakery products which are packaged before a customer selects them.
  • Any potted items with lids on, e.g. salads, jellies, mousses, fruit pots, yoghurt/granola pots.
  • Free issues or hospitality of cakes if they are packaged at the premises.
  • Food packaged and sold by the same business at a separate outlet, e.g. conveyed meals.

Challenges since the implementation of Natasha’s Law

The main issues have been around the understanding of the guidance. Many schools that CMC works with have their own menus and service that are specific to them, meaning that a “one size fits all" approach does not work. The definition of "packaging" could be hard to understand as, for example, this includes something wrapped in clingfilm which schools may not have automatically assumed was classed as packaging.

It was also understandable that younger pupils may not be able to make informed decisions about the food provided and would be even less likely to read or understand the labels. The changes to PPDS labelling, however, mean that any food that is packed on the same site before being ordered by the consumer needs to be labelled in line with Natasha’s Law regardless of whether the consumer can read or not.

Where there has been objection about the cost of labels or printing ink, our advice is that failure to comply with Natasha’s Law is a criminal offence which can lead to significant fines and imprisonment. In addition, there could be personal injury claims for failing to label PPDS, and the obvious – potential loss of life.

Looking ahead

It would be wrong to assume that all work related to Natasha’s Law is now done. Schools need to make sure that they regularly review their practices to ensure they continue to comply with the legislation.

It is vitally important when working with allergen systems that information is updated in real time and not as an afterthought. Here’s some guidance on ensuring that this happens:

  • Get used to ordering the same products from the same suppliers – if you are considering switching brands, remember that you will need to change your labels too.
  • Have a process in place if suppliers make swaps as you must ensure that information is transferred straight away, e.g. if your baker delivers Hovis instead of Kingsmill, you ensure the correct ingredients are displayed.
  • Proactively plan for malfunctions of printing equipment – can you send allergen information to another printer if your allocated one is not working? Do you have spare ink ready to use?
  • Ensure contingency planning – does someone else know how to use the systems if the person responsible is not there?
  • Allergen data isn’t fixed and recipes for products can change. Do not forget the importance of a physical label check against the data shared with you.

How CMC supported schools  

CMC has supported the effective roll-out of the new food labelling legislation in schools since January 2021. We are a strong supporter of Natasha’s Law and firmly believe in the amendment’s potential to protect the lives of millions of allergen sufferers in the UK.

With help from FSA guidance, CMC consultants were able to support schools in identifying whether they sold PPDS foods and what they needed to do to comply with Natasha’s Law.

CMC also supported schools to ensure all their products were labelled correctly. CMC sourced a solution and recommended the use of LabelLogic Live. This was all done in the Summer term in 2021 to ensure schools were up and running with the tools they needed to comply with Natasha’s Law from the start of the 2021/2022 academic year. A template for labels was sourced and designed by the team to ensure that not only was the information correctly sized and legally compliant, but that it looked good too.

CMC published some FAQs for catering managers and schools so that they could make informed judgements about how they produced their foods.

The support CMC can provide to schools does not stop now Natasha’s Law has been implemented. Head over to the CMC website to see the various support they have on offer.