New allergen labelling rules are now enshrined in legislation in England, Wales and Northern Ireland, and will come into effect from 1 October 2021. These requirements will apply to a category of food called ‘Pre-packed for Direct Sale’ (PPDS).
This refers to food which is packaged at the same place that it is offered for sale to consumers, i.e. it is packaged prior to being ordered or selected. This can include salads, sandwiches, pre-wrapped hot foods, and more.
The key points are as follows:
- New allergen labelling rules will come into effect from 1 October 2021
- PPDS food must clearly display certain information on the packaging
- Allergy tracking and traceability information must be readily available
- There are 14 allergens that must be declared by law
- Schools will be required to list all ingredients and allergens on food labels
- Schools are being urged by the Food Standards Agency to make these changes as soon as possible
- Schools will need to review and make some changes to their allergen processes
Read on to learn more information about each key point.
New allergen labelling rules will come into effect from 1 October 2021
This new legislation was developed in 2019, thanks to the actions of a lobbying group led by the parents of Natasha Ednan-Laperouse: the teenager who died after suffering an allergic reaction to sesame seeds, which was an undeclared ingredient in a pre-packed baguette. This occurred as there was no specific allergen information on the sandwich packaging; therefore, Natasha assumed it was safe for her to eat.
The lobbying group challenged the lack of legislation regarding this issue and, due to their efforts, the government has confirmed that Natasha’s Law will be implemented from the 1 October 2021 to protect those with food allergies, providing them with greater confidence in the food they buy.
PPDS food must clearly display certain information on the packaging
The Food Standards Agency has stated that the new labelling requirements will help protect consumers by providing potentially life-saving allergen information on the packaging of the food.
According to the new rules, PPDS food will have to clearly display the following information on the packaging:
- The name of the food
- The full ingredients list, with ingredients that are allergens emphasised, e.g. in bold, italics or a different colour
Allergy tracking and traceability information must be readily available
Allergen information must be accurate and readily available. Schools should ensure there is one chosen method that is implemented consistently to avoid instances of providing inaccurate allergen information that may cause someone with allergies to consume food produce to which they may have a severe reaction that could cause them to become seriously ill, or even lose their life.
Allergy controls are required through the catering ‘process flow’ – from receipt from the supplier, to storage, preparation, handling and cooking, and ultimately to the staff taking food orders and serving food. If checks are not made, or controls are not in place, an allergy incident could occur. Allergens are a food safety hazard and should be covered in schools’ Hazard Analysis and Critical Control Point (HACCP) and Food Safety Management System. Schools may also wish to ensure they have a strong Allergen and Anaphylaxis Policy.
There are 14 allergens that must be declared by law
This includes the following:
- Cereals containing gluten and wheat, e.g. spelt, rye and barley
- Crustaceans, e.g. crabs, prawns, lobsters
- Nuts, including almonds, hazelnuts, walnuts, cashews, pecan nuts, brazil nuts and pistachio nuts.
- Sesame Seeds
- Sulphur Dioxide and sulphites at concentrations of more than 10mg/kg or 10mg/L in terms of total sulphur dioxide
- Molluscs e.g. mussels, oysters, squid, snails
Schools will be required to list all ingredients and allergens on food labels
Schools will be required to list all ingredients and allergens on the labels of any food made on site, e.g. snacks, sandwiches, salad pots or cakes, that are pre-packaged prior to them being offered for consumption.
Ingredient lists, with the presence of any of the 14 categories of allergen emphasised to the extent that they are clearly legible, must be printed on the package or label of any PPDS.
Your supplier has a legal obligation to provide the school with the specific ingredient composition of any foods you buy from them. This information should be listed on the food’s packaging, on a label attached, or on any accompanying commercial documents where it can be guaranteed that such documents either accompany the food to which they refer, or were sent before, or at the same time as, delivery.
It is vital that all staff are aware of their responsibility to ensure the provision of correct allergen information through training. It is also paramount to define roles and responsibilities and appoint a person who monitors the ingredient formulas of every food used on a regular basis.
Schools are being urged by the Food Standards Agency to make these changes as soon as possible
Schools are being encouraged by the Food Standards Agency to make these changes as soon as they can, ahead of the implementation date. It is recommended therefore that schools place full ingredient listing on any pre-packaged foods as soon as possible to protect pupils and the school.
Schools will need to review and make some changes to their allergen processes
In order to prepare for the implementation of the law, schools can:
- Engage with suppliers and build good relationships to ensure they keep updated on any product or ingredient changes quickly.
- Act on any updates or ingredient changes immediately, ensuring all associated documentation is revised and communicated.
- Keep menus small and simple, reviewing the extent of ingredients used and minimising allergenic ingredients wherever possible. Schools can make ‘quick fix’ changes that will ensure your menu is suitable for as many allergy sufferers as possible, e.g. using cornflour as a substitute to thicken dishes.
- Take a look at their cooking processes, e.g. avoid adding vinegar to water when poaching eggs or the shared use of fryers.
- Only keep one copy of their current allergen matrix – this makes it easier to manage and will avoid any issues with version control where staff could potentially be referring to an old document.
- Ensure staff are suitably trained in allergy awareness and the consequences of those with allergies consuming allergens. Staff should also know how to respond to an allergy sufferer’s questions. Training should be completed and assessed regularly to ensure the team are competent and confident in dealing with allergens. Regular spot checks and ‘quick fire’ questions will keep staff alert and ready to act on any requests.
- Ensure good communication between those at different stages of the ‘process flow’. Systems should be simple so they are easy to implement and maintain. Designating a staff member as an ‘allergy champion’ is an effective means of co-ordinating allergy management.
- For more information on the new legislation, you can visit the Food Standards Agency website here.
- Add this article to your ‘Watch list’ to be notified of the latest developments.
Allergen Labelling (2021) How To Comply With Natasha’s Law <https://www.navitas.eu.com/natasha-law-how-to-comply/> [ Accessed: 12 May 2021]
CMC (2021) Natasha’s Law <https://cmcschoolfood.co.uk/natashas-law-2/> [Accessed: 12 May 2021]
Cypad (2021) ‘Natasha’s Law – how will it impact schools?’ <https://www.cypad.com/2021/02/24/schools-natashas-law/>
Gov UK (2021) ‘Introduction to allergen labelling changes (PPDS)’ <https://www.food.gov.uk/business-guidance/introduction-to-allergen-labelling-changes-ppds> [Accessed: 12 May 2021]
UK Food Labelling Resource (2021) ‘Frequently Asked Questions’ <https://natashas-law.com/frequently-asked-questions/> [Accessed: 12 May 2021]