Are You Ready for Natasha’s Law?

What Is Natasha’s Law?

The UK Food Information Amendment, also known as Natasha’s Law, comes into effect from 1st October 2021 and requires food businesses to provide full ingredient lists and allergen labelling on foods pre-packaged for direct sale (PPDS) on the premises.

Why is the law being introduced?

The legislation is being introduced to protect food allergy sufferers and give them greater confidence in the food they buy. It has been named after Natasha Ednan-Laperouse, a teenager who died after suffering an allergic reaction to an undeclared ingredient in a prepacked meal. It is estimated that almost 1 in 5 people in the UK suffer from an allergy.

What foods are classified as ‘Prepacked Foods for Direct Sale’ (PPDS)?

These are foods that have been packed on the same premises from which they are being sold. For example, a packaged sandwich or salad/coleslaw or tartare sauce made by staff earlier in the day and placed on a shelf for purchase. This is food which is packaged at the same place it is offered to

customers and is in the packaging before it is ordered or selected. This can include salads and sandwiches that customers select themselves and pre-wrapped foods kept behind a counter, as well as some products packaged and sold at mobile or temporary outlets.

Are fast food and takeaway businesses affected by Natasha’s Law?

Fast food and takeaway businesses could be affected by the changes in the legislation depending on their businesses models and how they operate (for instance, some businesses may produce some foods in advance and package them at busier times).

It effectively comes down to the moment when a customer orders and when the food is packaged. Where the food is packaged before the customer has ordered it is considered PPDS. If it is packaged after it is ordered, it is considered to be ‘non-prepacked food’, even if the food is then provided in packaging.

The reason for the distinction is that if the food is in packaging before it is ordered, then the customer can’t change it and it requires a label. If the food is packaged after it is ordered then, in theory, the Customer could request that items are removed which would change the contents. Therefore, this is considered to be ‘non-prepacked’ and a label is not required.

Some businesses will produce PPDS and non-prepacked food side by side and in exactly the same way. However, a burger that has been prepared and packaged ready for a customer to order is effectively the same as a sandwich that has been made earlier that day ready for a customer to select it. Both are prepacked foods that can’t be changed and will require a label.

What do food businesses need to do?

According to the new rules, PPDS foods must clearly display the following information on the packaging:

• The name of the food eg: Coleslaw, Tartare Sauce, pre prepped meals to take home and cook ie macaroni cheese / lasagne.
• A full ingredients list, with allergens emphasised (for example in bold, italics or a different colour) eg: eggs – crustaceans – mustard.
• These changes will apply to businesses in England, Scotland, Wales and Northern Ireland.

Here’s a handy checklist…

Nutrition and food information management software company Nutritics (with Manchester Metropolitan University, EuroFir and Quadram Institute) are the founders of the UK Food Labelling Resource and have put together a checklist to help Companies adhere to the new rules.

1. Suppliers and Stock:

• Make a list of all the suppliers you use and audit all of your ingredients and products.
• What information do you receive from your suppliers and what format is it currently in?
• Can you ensure this information is accurately retained and transferred to labels?

Whilst we hold a manufacturing specification for every food product, the law holds the Caterer fully responsible for displaying allergen information, so we urge you to check the actual packaging on the food products we deliver as the manufacturer must ensure that this is current/correct

2. Software & Hardware:

Software and hardware developed specifically for the field of food labelling to improve, automate, and make time-consuming analysis more efficient and less susceptible to accidental human error, is invaluable.

• Is the system you have in place suitable for complying with Natasha’s Law and minimising the risks of inaccuracies or human error?
• Does it capture supplier information, or do you have to input this manually?
• If there is a change to an ingredient, does it automatically update, or do you have to go through each stage of the recipe management process and manually make a change?
• If you have a printer, is it suitable for the volume of labels you will now need for PPDS products and is it freezer and heatproof to account for how your products might be stored or cooked?

3. Staff Education & Training:

Staff training and education should be ongoing. Step back and take an overall look at integrating allergen awareness training across your food production process. Appoint an allergen champion that has a deeper understanding and can provide more detailed information to Customers and additional training to staff.

Ensure all staff are fully aware of Natasha’s Law, whether they are involved in ordering ingredients, managing software, producing PPDS food or selling to Customers.

4. Trial Run:

Make sure to organise a trial run of your setup once you have trained your staff, added your supplier information recipes and created labels in your chosen software system. Stress test all essential aspects of your supply chain for compliance with Natasha’s Law.

5. Review, Refinement and Readiness:

Before October 1st make sure the process is as smooth and risk-free in your business as it can be. Review all suppliers and supplies and add on any new information. Check the deliveries you receive and identify how best to manage substitutions and changes and check the label generation process.

• Are the fonts correct, is the information clear and legible to Customers?
• Are your staff clear on why these changes are being introduced and what to do if Customers ask questions regarding Natasha’s Law and PPDS?

What are the 14 categories of food allergens that must be declared by law?

For more information about the new law

visit www.natashas-law.com