The law regarding labelling on foods that are pre-packed for direct sale (PPDS) will be changed on October 1st 2021. Soon businesses will have to display a full ingredients list and highlight allergens on all pre-packaged food, following the tragic death of a teenager due to an undeclared allergen in a pre-packed meal.
What is Natasha’s Law?
The UK Food Information Amendment, which is commonly referred to as Natasha’s Law, requires food businesses to provide a full ingredient list and allergen labelling on foods that are pre-packaged for direct sale on the premises.
The new law came into place following the actions of a lobbying group led by the parents of Natasha Ednan-Laperouse, a teenager who died suffering an allergic reaction to an undeclared ingredient in a pre-packed meal.
It is believed that 1 in 5 people in the UK live with allergies and these new rules are designed to provide protection to allergies sufferers and give an extra level of confidence in the food they purchase.
The law changes will apply in Wales, England, Scotland and Northern Ireland from October 1st 2021.
What does it mean for your business?
As a food business, you will be required to label any pre-packaged for direct sale foods with a name and full ingredients list, with allergens then emphasised within this list. This can include food that consumers select themselves, for example from a display unit, as well as products kept behind a counter, or some food sold at mobile or temporary outlets.
To remain compliant, changes to any PPDS food labels must be made by October 1st. The Food Standards Agency has created a tool to help you check products and their compliance (link: ).
What is PPDS?
Prepacked for direct sale is food that is packaged in the same place at which it is placed for sale if it is packaged before it is ordered or selected. It can be food that consumers select themselves from the likes of a display unit or products kept behind a counter. Food sold at mobile or temporary units is also included.
Some examples include:
- Sandwiches that are packed on site prior to a consumer selecting them.
- Fast food that is packaged before it is ordered and cannot be altered without opening the packaging, such as burgers under hot lamps.
- Burgers and sausages that are pre-packaged on premises by a butcher and ready for sale.
- Food samples are packed on-site and given to customers.
- Foods that are packaged on-site and ready for sales, such as salads, rotisserie chicken, pizza and pasta pots.
- Foods that are packaged and then sold by the same operator at mobile venues or market stalls.
PPDS foods that are provided in schools, hospitals, care homes and other similar settings will also require the correct labelling.
What is not PPDS?
Food that is not in packaging, or has been packaged after being ordered by the customer are not considered to be PPDS and will not require the full labelling. Allergen information must still be provided but it is believed that this can be done orally, with the customer, or staff member asking questions as the order is placed.
Food that is packaged by one business and then sent to another should already have full ingredient labelling, that includes full allergen labelling and the name of the food.
What needs to be on the label?
The label must show the name of the food and a list of all ingredients, with a list of the 14 allergens emphasised within it. They need to remain inline with the legal requirements that apply to naming food and listing ingredients.
The 14 allergens that must be highlighted are:
- Cereals containing Gluten
- Sulphur Dioxide and Sulphites
- Tree nuts
What about mobile ordering?
The new rules regarding PPDS food do not apply to any food sold over the phone or internet, however, businesses selling PPDS by these means do need to ensure that mandatory allergen information is easily available to consumers prior to purchasing the food item, and also at the point of delivery. This information can be given in writing, in a catalogue or menu or orally. At the point of delivery, allergen information can also be displayed in the form of a sticker or label on the food items.
Allergen information should always be readily available to customers in written form at points between the customer placing an order and accepting delivery of food items.
You can find guidance on Natasha’s law in the PPDS hub on the FSA website.