The UK Food Information Amendment, more widely known as Natasha’s Law, will be introduced on 1 October 2021. The change in allergen labelling follows the tragic death of teenager Natasha Ednan-Laperouse in 2016, after consuming a baguette containing sesame.
All pre-packed for direct sale (PPDS) foods will be required to conform to pre-packed labelling requirements, with a full ingredient declaration showing allergens highlighted.
What should be done to prepare over the summer? As food procurement experts specialising in independent education, allmanhall provide 10 essential considerations…
1. Do you have PPDS foods?
Is there even a need to adopt the new approach to labelling? If so, how much of your range will be impacted? PPDS foods are:
● Prepared on site
● Individually packaged
● Fully or partially packaged prior to selection
● Have packaging that would have to be disturbed to access the food
● Not pre-ordered.
Could the PPDS range be refined? What ingredients will be used and from which suppliers? Can they be streamlined? A procurement partner like allmanhall can help look at options for you.
2. Create PPDS recipes
To correctly label PPDS foods, the ingredients and allergens in each item need to be known along with the quantities, so that the ingredient declaration is in descending weight order. This will mean creating recipes for each PPDS item.
3. Obtaining ingredient and nutrition information
Will information be obtained via a catering platform, a labelling system or on-pack? Several sources are likely. Checking on-pack can ensure greater accuracy.
4. Labelling solution
Creating handwritten labels to the legislative standards may be operationally challenging. Consider how a labelling solution would fit into catering processes, what hardware is required (ie printers) and where these will be located.
5. Identify risks
Allergen management is about reducing risk to the end consumer. Map the journey from ordering products to a pupil selecting a PPDS item.
Identify each risk point and establish an operational practice to manage them. For example, has a substitute product been sent in by a supplier? Has the allergen information altered on a product? Has a recipe changed?
6. Consider cross-contamination risk – precautionary allergen labelling
Precautionary allergen labelling is where manufacturers cannot eliminate a risk of cross contamination and add a ‘may contain’ or ‘not suitable for’ statement to the label.
This should now be considered in a catering environment. Catering teams should undertake risk assessment to establish any chances of cross contamination.
7. Trial and train
As this is a change in operational practices, it may be wise for your team to trial the new process ahead of October. The summer is a good time to provide training to support delivery and compliance.
8. Environmental health
Consider engaging with your local EHO now, sharing how you will be approaching new legislation and obtaining their feedback in advance of October.
Through labelling of PPDS foods, consumers may presume they are selecting a bought-in product and valuable communication with the catering team regarding allergies will therefore not take place.
Posters or a sticker on your PPDS foods can highlight that they are made on site and encourage customers to still speak to the catering team.