Are you label ready for Natasha's Law? Snacks-to-go providers reminded of allergen labelling deadline
While the Testing, Inspection and Certification (TIC) specialist welcomes the amendment to the Food Information Regulations (FIR), it is cautioning producers to set out a clear plan to transition towards more transparent labelling to avoid hefty penalties.
From 1 October 2021, all Prepacked for Direct Sale (PPDS) foods and snacks will need to sport a label showing the name of the item and a full ingredients list, with the allergenic ingredients emphasised in bold, italics or a different colour.
The 14 allergens are celery; cereals that contain gluten (such as barley and oats); crustaceans (such as prawns, crabs and lobsters); eggs; fish; lupin; milk; molluscs (such as mussels and oysters); mustard; peanuts; sesame; soybeans; sulphur dioxide and sulphites (if they are at a concentration of more than ten parts per million) and tree nuts (such as almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts).
Currently, it is not mandatory for these to appear on a product’s label and allergen information can be provided by any means (including verbally by staff).
However, following the public lobbying of Natasha’s Law – set up after Natasha Ednan-Laperouse suffered a fatal allergic reaction to undeclared ingredients in a baguette – there has been pressure on producers to become more transparent to help people with a food allergy or intolerance to make safe choices when buying PPDS food.
The new regulation will affect a number of businesses, including bakeries and market stalls, that provide PPDS foods (packaged on the premises where it is being sold, pre-packed before the consumer purchases it and either fully or partially enclosed in packaging).
Free webinar to understand the new allergen labelling law
Bureau Veritas’ expert food technical team – in partnership with international food law group Osborne Clarke – will be hosting a free webinar for food manufacturing, catering, hospitality and retail businesses to understand the new allergen requirements.
‘Understanding Allergen Requirements: Preparing for Food Labelling Changes’ will be held on Thursday 28 January at 10am GMT, and will cover topics such as preparing for changes to Food Information Regulations, the new legal requirements around managing allergens, and practical tips on how to effectively tackle it.
“Bureau Veritas has always been a business that leads the way in helping its clients and the wider industries keep on top of regulatory changes,” said Katie Vickery, partner and head of International Food Law Group at Osborne Clark.
“Allergen labelling has been incredibly topical in recent years due to the sad death of Natasha Ednan-Laperouse, and the new clarity on labelling required for food pre-packed for direct sale is helpful for business and the industry as a whole.
“It will affect the ways in which a number of food manufacturers and retailers work, and it will require businesses to learn, absorb information and adapt to a new system of working.”
Much needed change
“At Bureau Veritas, we welcome the much-needed changes to allergen labelling on pre-packed for direct sale food,” said George Macfie, food safety technical lead at Bureau Veritas.
“The amendment to FIR will offer consumers transparent information on which they can make informed and confident choices about their purchase, and literally could help to save lives.
“The regulatory changes, however, now put even more onus on the business to get it right, taking the responsibility away from the customer (who at present may have to ask for allergen information).”
He added businesses need to implement a robust plan and communicate this effectively throughout the business, from the development team to the production workforce and even those managing point of sale.
“A chink along this chain could cause information to be misconstrued or misinterpreted, potentially leading to incorrect labelling and allergen information being displayed.
“New infrastructure will also need to be put in place and additional expenditure such as purchasing labels and also investing in quality printing to ensure the information included on the label is legible. It may also be that internal training is required – especially for businesses that operate in multiple branches or locations where there will be a large number of staff to get up to speed on the changes for business and their individual responsibilities.
“Central to all of this will be documented management oversight at every stage in the process, ensuring effective transition to the new labelling format of communicating allergens,” he added.