Posted: 03/06/2021

Time is running out to prepare for Natasha’s Law allergen labelling changes

Time is running out to prepare for Natasha's Law allergen labelling changes
All food that is pre-packaged on a business’s premises will be subject to new labelling requirements

Key bodies have urged independent food retailers to prepare now for sweeping changes to food labelling requirements, known as Natasha’s Law, that come into force later this year.

The Guild of Fine Food and global food safety consultancy Navitas stressed the importance of getting to grips with the Food Information Amendment ahead of it becoming enforceable from 1st October. 

Created after lobbying by the parents of teenager Natasha Ednan-Laperouse, who died after suffering an allergic reaction to an ingredient in a Pret a Manger baguette, the legislation will make it a legal duty for retailers to label all food pre-packaged for direct sale on their premises with full ingredients and correct emphasis on allergens (see box).

Kirstie Jones of Navitas told FFD: “Natasha’s Law will affect all businesses that work within the food and hospitality industry. With regulations continuing to be updated, ensuring that staff are suitably trained is key. 

“Although the law does not come into effect until October, we encourage businesses to get a head start on training staff and getting themselves prepared. Since the newest legislation has stemmed in part from tragic circumstances, businesses can’t afford to be behind when it comes to upholding food safety.”

Jones said digital management was a useful technique to help retailers keep their customers safe.

“Digital food safety and allergen management can aid businesses by storing all allergen and ingredient information for food items, as well as supplier information, all of which can be accessed anywhere and is an effective tool for tracking and traceability,” she said.

The Guild of Fine Food has prepared a document to help businesses in the sector get ready for the law change.

“It’s important you start preparing for compliance,” the document states. “Businesses must put in place procedures for labelling for those products pre-packed for direct sale (PPDS) and meet legal obligations to ensure customer safety.”

The Guild has urged retailers to follow a four-step process with the acronym DELI.

Its guidance states: “Decide what products you sell or intend to sell as PPDS and what labels you intend to use; Ensure you gather the correct information (recipes, ingredient specifications and allergen details); List the ingredients and allergens on labels with the relevant information; and Inform your staff of procedural changes and update or refresh any allergen training.”

The document adds that being able to show you fully undertook due diligence concerning labelling will be critical to defending any claims brought against you under this new legislation.

What exactly does Natasha’s Law cover and how do you comply?

Katie Chandler. Natasha's Law

Katie Chandler, pictured right, partner at law firm TaylorWessing, answers your questions.

When exactly is a purchase covered by the new law? 

The answer is in the definition of pre-packed foods. Food is pre-packed when it is either fully or partly enclosed by the packaging; cannot be altered without opening or changing the packaging, and is ready for sale. Pre-packed food for direct sale (PPDS) is food that is packaged at the same place it is sold to consumers and is in the packaging before it is ordered or selected. Made-to-order food is not included.

What exactly is required by the legislation for items that do come under it? 

For those food products which fall within the meaning of PPDS, a label is required with the name of the food and a full ingredients list, in quantity order, with any of the 14 allergens emphasised within the list in bold, capital letters, contrasting colours or underlined. 

What are the potential consequences of non-compliance? 

Failing to comply with allergen labelling laws is a serious issue. On top of the consumer safety risk, there are significant consequences for non-compliant businesses – Food Standards Agency enforcement action can include improvement notices, closure notices or even criminal prosecution. Reputational damage could destroy a food business and civil claims can be brought under the Consumer Protection Act 1984.

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