Understanding Natasha’s Law: The UK Food Information Amendment

Unlock compliance with Natasha's Law! Discover our guide to navigating the UK Food Information Amendment for safe food labeling.

Last Updated on March 3, 2024 by Ossian Muscad

Natasha’s Law represents a significant update to the existing food legislation in the United Kingdom, aiming to bolster the safety and well-being of customers with food allergies. This amendment was initiated to mitigate the risks associated with undisclosed allergens in pre-packaged foods, a concern that has grown increasingly pressing amidst rising allergy rates.

Additionally, Natasha’s Law seeks to enhance transparency within the food industry, empowering businesses with the knowledge and tools necessary to safely cater to customers with allergies. This article will explore the critical facets of Natasha’s Law, discuss its implications for both consumers and businesses and offer guidance on how businesses can effectively adhere to these new regulatory requirements.

 

What is Natasha’s Law?

Natasha’s Law, formally known as the UK Food Information Amendment, came into effect on October 1, 2021. It mandates that all pre-packaged for direct sale (PPDS) food items must display a full list of ingredients with allergenic ingredients emphasized on the label. This legislation was inspired by the tragic death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction after consuming a pre-packaged sandwich that did not clearly indicate the presence of sesame seeds, an allergen for Natasha. The Law aims to prevent such incidents by ensuring consumers have access to comprehensive ingredient information directly on the packaging.

The implementation of Natasha’s Law signifies a major shift in how food businesses operate, particularly affecting bakeries, cafes, and restaurants that prepare and package food on their premises for immediate sale. Businesses are now required to review their labeling processes and ensure that all PPDS items are correctly labeled with the ingredient and allergen information. It represents a significant step forward in allergen management, aiming to enhance consumer safety by providing individuals with food allergies the information they need to make safe food choices.

 

Changes that Natasha’s Law Introduced

The legislation introduced by Natasha’s Law mandates new allergen labeling requirements specifically tailored for PPDS (Prepacked for Direct Sale) food items. This category includes food that is packaged at the same place it is sold, and the packaging takes place before a customer has chosen to purchase it. Common examples of PPDS foods encompass sandwiches prepacked on-site, items from hot foods sections, offerings from a butcher’s aisle, and bakery products. These items are now legally required to feature full ingredient labeling on their packaging to ensure transparency and safety for consumers.

Allergen Identification

A critical component of this new regulation is the emphasis on allergen identification. If the food contains any of the 14 major allergens identified by food safety authorities, these must be clearly highlighted to the consumer. The 14 allergens include the following:

  • Gluten
  • Peanuts
  • Tree Nuts
  • Mollusks
  • Eggs
  • Milk
  • Fish
  • Lupin
  • Soy
  • Celery
  • Crustaceans
  • Mustard
  • Sesame
  • Sulphite

 

This goal can be achieved through various methods, such as using bold text, block capitals, or a contrasting color of text. This change is aimed at significantly improving safety for individuals with food allergies by making it easier for them to identify potentially harmful ingredients before making a purchase.

Distinctions for Non-prepacked Foods

Beyond PPDS foods, it’s crucial to understand the distinctions between non-prepacked foods, which broadly fall into two categories. The first category, loose foods, encompasses items such as fruits that have not been packaged or foods that are packed only after being ordered by a customer. For these loose foods, allergen information must be readily accessible to consumers. This can be accomplished through various means, such as clearly stated allergens on a menu located near the foods sold or an information pack that customers can review.

The second category includes food items that are pre-packaged by one business before being supplied to another. Notably, these items are not classified as PPDS food, which means they are subject to different legislations concerning allergen labeling. Despite not falling under the scope of Natasha’s Law, there exists a legal obligation for these products to include detailed allergen information, ensuring consumer protection across all forms of food purchase and consumption. This delineation emphasizes the extensive efforts to safeguard individuals with food allergies, providing them with the crucial information needed to make informed and safe dietary choices regardless of how the food is packaged or sold.

Distance Selling

PPDS foods sold over the phone or internet (such as through takeaway services) also face specific requirements under what’s known as Distance Selling. For these items, it is mandatory to communicate allergen information both prior to the completion of the purchase and at the moment the food is delivered. This could be done orally or in writing. For instance, staff can relay allergen details over the phone, or the information can be prominently displayed on a website or menu. Upon delivery, the driver may verbally repeat allergen information, or the packaging might include a sticker listing the potential allergens. The methods for providing this crucial information can greatly vary from business to business.

Clear and Consistent Information

Additionally, as part of these new PPDS regulations, the name of the food item must also be clearly stated. While this might seem straightforward, the Law now requires that the legal name of the product, if available, is used. The legal name can either be a prescribed name established under UK law, or it may be a ‘Reserved Description,’ which applies to food meeting specific compositional criteria. For example, a ‘beef burger’ must contain no less than 62% beef. In the absence of a legal name, a customary name that is widely recognized by the general public, such as ‘Yorkshire pudding,’ is acceptable. If neither a legal nor a customary name can be provided, then a descriptive name, generally outlining the most noticeable ingredients in the food, will be necessary.

Consequences for Non-compliance

Non-compliance with these updated requirements could result in severe consequences, including unlimited fines, up to six months in prison, and considerable damage to a company’s reputation. Additionally, businesses may face recall costs, legal expenses, risks, and insurance implications. Therefore, adhering to these regulations is crucial for keeping customers safe and avoiding legal issues. For businesses uncertain whether these labeling requirements apply to them, the Food Standards Agency offers an online tool to determine if your business supplies PPDS food and suggests methods to effectively communicate potential allergens to customers.

 

Allergen Labeling for Different Types of Food

Communicating allergen information to customers for different types of food can be done in various ways. However, we’ll look at two of the most common types: prepacked foods and Prepacked for Direct Sales.

Prepacked Foods

Prepacked foods involve foods that have been canned, bottled, or wrapped securely before being served to the customer. Under Natasha’s Law, an accurate list of ingredients must be present on the packaging of these foods. 

This list must be indented in a clear font and placed near the name or brand of the product. In addition, any allergens in the product ingredients list must be highlighted in some way that will make them easily visible to the consumer.

Prepacked for Direct Sales (PPDS)

PPDS refers to foods packaged in the same location as they’re provided or sold to consumers. It is commonly packaged before being ordered by the customer.

It can also include ingredients people choose for themselves, other items stored behind a counter, and some meals sold at temporary locations or via mobile vendors.

As with prepacked foods, allergen information must be present on the packaging of these foods. This list must be indented in a clear font and placed near the name or brand of the product. In addition, any allergens in the product ingredients list must be highlighted in some way that will make them easily visible to the consumer.

In addition, businesses are also required to verbally provide allergen information to customers upon request. This ensures that customers with food allergies can make informed decisions about the food they buy.

Examples of PPDF Foods

Below are some examples of PPDF foods according to the Food Standards Agency:

  • Fast food prepared before ordering, such as burgers
  • Sandwiches and baked goods are packed on the premises before customers order them.
  • Burgers and sausages are packed on the premises by a butcher for retail sale.
  • Pre-packaged products like salads, pasta, rotisserie chicken, and pizzas.
  • Foods packaged by the same business will be sold at a different location, such as a market stall or food fair.
  • Food is served in schools, hospitals, nursing homes, and other institutions.
  • Foods packaged at a market stall or food fair
  • Personalized orders from customers, such as sandwiches made to order.
  • Bakeries and delis are packaging food for display.

 

Responsibilities of Food Businesses Under Natasha’s Law

Food businesses are responsible for taking all reasonable steps to ensure that the food they serve or sell is safe for human consumption. Not only is it a legal requirement, but it is also a moral responsibility to protect the health and well-being of customers. Some key responsibilities for businesses under Natasha’s Law include:

  1. Providing accurate information: food sellers are required to provide accurate food labeling and allergen information upon request. This information needs to be updated, especially when new recipes or ingredients change or when there’s a change in the manufacturing process.
  2. Ensuring food safety: Food businesses must take rigorous steps to prevent cross-contamination by implementing separate cutting boards for different food groups, ensuring proper storage of raw and cooked foods, and maintaining a stringent cleaning schedule to uphold a safe and hygienic environment for food preparation.
  3. Training employees: All food handlers should undergo comprehensive training programs that cover not only basic food safety practices but also specialized allergen awareness training. This ensures that employees are equipped with the knowledge and skills to handle food safely, prevent cross-contamination, and respond effectively to allergen-related queries or incidents.
  4. Communication with Suppliers: Establishing clear and consistent communication channels with suppliers is crucial for food businesses to obtain accurate and up-to-date information on ingredients, sourcing practices, and potential allergens. Suppliers should be legally obligated to provide detailed ingredient lists, including any allergens present, to enable food sellers to make informed decisions and accurately label their products.
  5. Providing emergency contacts: Food businesses must prominently display emergency contact information for consumers to reach out to in case of allergen concerns or queries. This contact information should be easily accessible on packaging, menus, or websites to ensure quick assistance and guidance regarding allergen information or potential reactions.
  6. Keeping records: Maintaining detailed records of ingredient sourcing, usage, and allergen information is essential for traceability and quality control. Accurate record-keeping enables businesses to quickly identify and address any issues related to allergens, track product batches in case of recalls, and demonstrate compliance with food safety regulations during inspections or audits.

 

How to Ensure Compliance with Natasha’s Law

Ensuring compliance with Natasha’s Law is crucial for all food businesses to protect individuals with food allergies. This requires meticulous attention to detail in labeling, staff training, and customer communication. Here are five notable tips to assist food businesses in adhering to this essential legislation and safeguarding consumers.

Conduct Regular Allergen Audits

Carry out frequent allergen audits to ensure all ingredients are correctly identified, and potential cross-contamination risks are mitigated. This entails reviewing and documenting all the ingredients used in your food preparation processes, identifying allergens present, and assessing the risk of cross-contact with non-allergenic foods.

Update Labels with Clear Allergen Information

Update all product labels to clearly highlight allergens within the ingredient list. Use boldface, a different color, or an alternative font style to make allergen information stand out. This applies to both prepacked foods and Prepacked for Direct Sales (PPDS) items, ensuring that allergens are easily identifiable at a glance.

Implement Comprehensive Staff Training

Ensure all staff members are thoroughly trained in allergen management, including recognizing allergens, understanding cross-contamination risks, and communicating allergen information to customers. Regular training sessions should be conducted to keep all employees up-to-date on the latest allergen advice and legislation changes.

Offer Detailed Allergen Information On Demand

Prepare to provide detailed allergen information upon customer request. This could include creating comprehensive allergen menus, having allergen information readily available on your website, or training staff to provide accurate allergen information verbally. Ensuring customers can easily access detailed allergen information empowers them to make safe dining choices.

Maintain Transparency with Suppliers

Build a transparent relationship with all your suppliers to ensure you receive accurate and comprehensive information about the ingredients you purchase. This includes having detailed knowledge of any potential allergens in the ingredients supplied. Agree on a protocol for suppliers to notify you immediately of any changes in product formulation or potential cross-contamination risks.

 

Frequently Asked Questions (FAQs)

Q1: Who does Natasha’s Law apply to?

The Law applies to all food businesses in the UK that produce PPDS food. This includes restaurants, cafes, bakeries, sandwich shops, and supermarkets, among others, that prepare and pack their products on the same premises from which they are sold.

Q2: What constitutes a prepacked-for direct sale (PPDS) food item?

PPDS food items are those that are packaged before being offered for sale by the same business to the end consumer on the same premises or an associated premise. Essentially, if the food is packed before a customer selects or orders it, it is considered PPDS.

Q3: How can businesses identify allergens in their products?

Businesses should conduct comprehensive ingredient checks and supplier verifications to identify any allergens in their products. They can also carry out allergen audits to ensure the accuracy of the allergen information provided on their labels.

Q4: Are there specific penalties for non-compliance with Natasha’s Law?

Yes, food businesses that fail to comply with Natasha’s Law may face enforcement actions, including fines and legal action. Non-compliance not only risks public health but also damages a business’s reputation.

Q5: Can food businesses provide allergen information verbally instead of on the label?

While verbal communication of allergen information can be supportive, Natasha’s Law mandates that specific allergen information must be provided in writing on labels for PPDS food. This aims to minimize the risk of errors in verbal communication.

Q6: Does Natasha’s Law apply to food businesses in other countries?

Natasha’s Law was introduced in the UK, and currently, it only applies to food businesses within the country. However, similar legislation may exist in other countries to protect the safety of individuals with food allergies. Food businesses need to stay informed about any relevant legislation in their respective countries. Complying with Natasha’s Law requires a proactive and diligent approach from food businesses.

 

Use DATAMYTE to Streamline Compliance with Natasha’s Law

DATAMYTE is a quality management platform with low-code capabilities. Our Digital Clipboard, in particular, is a low-code workflow automation software that features a workflow, checklist, and smart form builder. This tool lets you design and deploy custom workflows for managing all aspects of Natasha’s Law compliance, including allergen audits and labeling checks.

DATAMYTE also lets you conduct layered process audits, a high-frequency evaluation of critical process steps, focusing on areas with the highest failure risk or non-compliance. Conducting LPA with DATAMYTE lets you effectively identify and correct potential defects before they become major quality issues.

With DATAMYTE, you have an all-in-one solution for streamlining compliance with Natasha’s Law and improving the overall safety and quality of your food products. It offers real-time data collection, analysis, and reporting capabilities to ensure that your business stays compliant with regulations at all times. Book a demo now to learn more.

 

Conclusion

Natasha’s Law is just the beginning of a more extensive and crucial movement towards enhancing food safety and transparency within the industry. By implementing these stringent regulations on allergen labeling for PPDS foods, both consumers and businesses stand to benefit from higher standards of health and safety. The Law not only highlights the significance of accurate allergen information but also prompts businesses to reassess and improve their overall food safety practices.

While compliance may initially pose challenges, the long-term benefits of fostering a safer dining environment for individuals with food allergies cannot be overstated. Moving forward, it is imperative for the food industry to continue adapting and innovating to protect the well-being of its consumers fully.

 

 

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