UK Food Information Amendment – what do organisations need to check?

The UK Food Information Amendment, also known as Natasha’s Law, came into effect on 1 October 2021. The new allergen legislation requires food businesses to provide a full ingredient list for pre-packed for direct sale (PPDS) foods. The new labelling will help protect consumers by providing potentially life-saving allergen information on the packaging.

Any business that produces PPDS food will be required to label it with the name of the food and a full ingredients list, with allergenic ingredients emphasised within the list. The legislation applies to a wide range of organisations which have catering facilities that sell PPDS foods including universities, colleges, schools, factories, offices, care homes and NHS bodies. PPDS is food which is prepared and packaged at the same place it is offered for sale to consumers.

Businesses need to check if their products require PPDS labelling and what they need to do to comply with the new rules. Lack of compliance will result in fines of up to £5,000 per offence and potential reputational damage.

The changes to food labelling are applicable to England, Wales and Northern Ireland. Similar changes are expected to be introduced in Scotland by Food Standards Scotland to ensure consistency of provision of food information across the UK.

The Food Standards Agency’s (FSA) food labelling tool assists businesses to identify the ‘type of food’ that is being provided and the ‘allergen labelling requirements.’

Food will require the new labelling if it meets all three criteria:

1. Is the food presented to the consumer in packaging?
2. Is it packaged before the consumer selects or orders it?
3. Is it packaged at the same place it is sold?

If all three answers are ‘Yes’, food will require PPDS labelling.

Labelling guidance

The FSA states that a food label ‘must be visible and clearly legible. The consumer should not need to open the packaging to access this information.’ There is a legal requirement for food labelling and businesses should ensure that they use the information provided from suppliers to produce accurate labels. Processes should be in place to update this information should there be a change in suppliers, or if ingredients change. The FSA has also published labelling guidance for PPDS food products to help food businesses meet labelling requirements.

What can food operators do to prepare?

The UK Food Labelling Resource has published a step-by-step guide to help businesses prepare for the legislation.

Allergen management should be addressed in the same manner as any other risk management procedure, including a ‘full review of all processes, risk assessment and mitigation and training for all employees to ensure they understand the risks posed by allergens.’

Guidance and resources

Specific guidance for each industry will be published on the Natasha’s Law website.

The UK Food Labelling Resource has also published a series of guides and checklists which covers the following areas:

• PPDS food labelling guide - what businesses need to know about Natasha’s Law;
• software solutions for Natasha's Law - risk framework;
• business roadmap for food operators; and
• how to prepare for inspections/audits.

How can RSM help?

We can help in a number of ways, including:

• by undertaking an audit of your existing policies and procedures;
• review of food safety (including allergen awareness) training; or
• where food provision is outsourced, review the arrangements you have in place to ensure those providing the service have the appropriate policies and procedures in place and, can provide the assurances you require.