Focus: It’s time to prepare for Natasha’s Law
October 2021 will see new legislation, Natasha’s Law, coming into effect, requiring all caterers to provide full ingredient lists and allergen labelling on foods pre-packed for direct sale (PPDS) on the premises. Tess Warnes BSc RD, from allmanhall, the independently-owned food procurement expert, explains how the new legislation will affect the labelling of foods, and gives advice to caterers on how to prepare for these changes…
Until now, only foods that are packaged and are sold off-site (such as in a supermarket) have to label the ingredients. Natasha’s Law is the first new legislation around allergen management passed in the House of Commons since the introduction of the European Union Food Information for Consumers Regulation in 2014.
Natasha’s Law follows the tragic death of the teenager Natasha Ednan-Laperou, who suffered a fatal anaphylaxis reaction as a result of eating a sandwich containing sesame seeds bought from Pret a Manger. Her parents subsequently fought for a change in the law to tighten up allergen management.
With as many as 20% of the population experiencing an adverse reaction to one of the 14 allergens, the new law will require foodservice providers and catering teams to provide full ingredient labelling on foods that are prepared and packed on the same premises from which they are sold or offered. The aim is to protect those with food allergies and giving consumers greater confidence in the food they eat.
According to Warnes: “With the law coming into force from October 2021, now is the time for caterers to plan and get ready to ensure they have the necessary training, processes, technology and support in place. Firstly, it is important to understand which businesses and types of food will be affected, and whether – or how – the new legislation will affect you.”
What food will be regarded as PPDS:
Food is considered prepacked when it is put into packaging before being offered for sale and cannot be altered without opening or changing the packaging. Examples of PPDS would be:
· Sandwiches placed into packaging by the food business and sold from the same premises
· Sandwiches placed into packaging for a school trip or sport event
· Foods packaged and then taken by the same operator to their market stall to sell
· Foods packed by a food business to be sold in its retail units located within the same building complex as the premises where the food was packed, such as a train station, hospital, university or holiday park
· Burgers or sausages made at a butcher’s, which are then pre-packed to be sold
Food that would not be PPDS:
· Open hotdog in a cardboard tray (as can be altered before serving)
· Sandwiches placed on wooden board for customers to help themselves
· Prepared sandwich or burger that is made and wrapped after taking an order
· Meals served individually in schools from a hot counter
· Cakes/cookies loose in cakes stands that would be put into bags or onto plates to serve
What does full labelling involve:
According to the new rules, PPDS food will have to have the following information clearly displayed on the packaging or a label attached:
· The name of the food
· An ingredients list including allergenic ingredients. The allergenic ingredients within the food must be emphasised every time they appear in the ingredients list (in the same way as labels on pre-packed foods). For example, the allergens in the food can be listed in bold, in capital letters, in contrasting colours or underlined
How can caterers prepare for Natasha’s Law:
The new law will mean that all caterers need to consider how to label any foods packaged on-site to ensure the information is accurate. Now would be a good time to start thinking about what products would fall into the PPDS category and start to consider if any changes to process or any training or tech support will be required, so that you can be ready in advance of 1st October 2021.
Foodservice and catering operations will need to consider how labelling would be done in the most accurate but time-effective way, and the implications of labelling specific allergens in situations where there is any risk of cross-contamination, such as in the ‘May contain’ statements on labels.
Current law requires businesses to manage cross-contamination risks effectively but recognises that where risk cannot be removed it is acceptable to communicate this to consumers. A compliance and allergen audit may also be a consideration, once catering operations reopen.
“As a leading independent food procurement provider, allmanhall offers foodservice consultancy to all our clients,” explains Warnes. “We are able to provide advice and resources to support a range of operational and regulatory compliance issues, including Natasha’s Law.
“As part of our fully managed procurement solution, we give access to platforms and tech integrations that will facilitate labelling requirements. As one of allmanhall’s registered dietitians, I provide clients with expert advice on allergen considerations, with any necessary training and the provision of guides and materials.”