Get ready for Natasha’s Law: our four-step plan

Natasha’s Law came into force on 1 October 2021, which means that we are now already seeing important changes to the way certain foods are labelled and sold. To help ensure food businesses are up-to-speed and are implementing these changes, I’ve summarised the law and what it means, alongside a four-step plan for following it.

With ‘Natasha’s Law’ now in force, all food businesses are required to provide full ingredients labelling, with allergenic ingredients emphasised on food that has been pre-packed for direct sale (PPDS).

The law is being introduced following the death of teenager Natasha Ednan-Laperouse, who suffered a fatal anaphylactic reaction after eating a pre-packaged baguette which contained undeclared sesame as an ingredient.

It will provide potentially life-saving allergen information to customers, and businesses must already be taking action by checking if their products comply with the new PPDS labelling standards.

What is PPDS food and what should you do to prepare for the changes?

PPDS food is food that is presented to the consumer in packaging. The legislation applies to food packed at the same place it is sold and packaged before the consumer selects or orders it.

Examples include:

• Sandwiches and bakery items, such as filled croissants or cakes, packed on-site before a customer chooses or orders them
• Fast-food packed before it’s ordered, such as burgers stored under a hot lamp that can’t be altered without opening the packaging
• Dishes or individual products prepacked on site ready for sale, like pizzas, rotisserie chicken, salads and pasta pots
• Samples of cookies given to customers for free which were packed on site
• Foods packaged and then sold elsewhere by the same operator at a market stall or mobile site
• Prepacked food for sale in schools, care homes, hospitals and other similar settings will also need labelling
• Burgers and sausages prepacked by a butcher on the premises ready to sell to customers

The ingredient and allergen information provided on the label must be accurate and presented in a suitable format. Labels should include the name of the food and a full ingredients list. Allergenic ingredients must be emphasised within this list. The Food Standard’s Agency (FSA) provides more detailed guidance about labelling foods prepacked for direct sale.

It’s essential to be prepared and to have implemented these changes, whatever style of food operation and however big or small.

Here are some simple steps you can take now:

1. Follow the guidance

The FSA’s website provides a whole range of useful, up-to-date information on allergen labelling, including sector specific guidance. Food businesses should speak to their local authority for advice specific to their business.

2. Work with your suppliers

You will need to work with all your suppliers to understand how they capture ingredient and allergen information, and how this will be passed on to you. Ask your supplier what verification checks and processes they have in place.

3. Ensure you and your staff are trained

Everyone in your business must be fully informed and responsible for providing the correct allergen information. Training staff on the new allergen legislation should minimise the risk of errors and mistakes when it comes to labelling and doing so through a certified course, like CIEH’s Certificates in Food Safety and Allergen Awareness will ensure every aspect is covered. Appropriate labelling means listing ingredients with allergen information emphasised – there are 14 major allergens that you should be aware of.

4. Link up your food data with labelling

Labels placed on PPDS foods must be up-to-date with all ingredient and allergen information when put on display. While pre-printed labels can save time and are useful if your printer is prone to problems, they don’t allow for last-minute ingredient substitutions from a supplier.

Therefore, linking up a database of food products and ingredients to the way you print labels will help make sure that the correct information is transferred easily. The database could record your products, recipes and ingredients, making it easy to track what’s being used and where.

Think about:

• How ingredient and allergen information is captured?
• How you’ll get all the ingredient information on the labels?
• How you’ll manage label production?
• How you’ll ensure food labels are providing accurate and reliable information in the correct format?

Following these four steps and checking that everyone handling food across your business is up-to-date on the changes will mean you and your business are ready to implement the legislation and more importantly, keep your customers and your business safe.

Here at CIEH, we provide comprehensive training across various elements of environmental health, including food safety and allergen awareness. For support on how you and your team can ensure its compliance with Natasha’s Law, explore the following training opportunities that have been recently updated to provide education and insight on the latest legislation.

• Level 1 Food Safety (Online)
• Level 2 Food Safety for Caterers and Manufacturers (Online)
• Level 3 Food Safety for Caterers and Manufacturers (Online)
• Serving the Allergic and Food Intolerant Customer (Online)
• Food Allergen Awareness