Natasha’s Law FAQs
Your allergen legislation questions answered
15.09.21
With Natasha’s Law fast approaching from 1st October 2021, many food businesses and catering companies of all sizes still have lots of questions about what the changes mean. How can you ensure compliance?
So to help, working with the Food Standards Agency (FSA), we tackled some of the most commonly asked Natasha’s Law queries.
Our Experts:
- Arvind Thandi Team Leader - Food Hypersensitivity Food Standards Agency
- Rachael Sawtell Marketing Director Planglow
Want to find out more? Click here to book a 1:1 appointment
What's included:
- 1:1 appointment with a Planglow expert (approx. 30 minutes)
- What is Natasha's Law and does it apply to me?
- LabelLogic Live demo including how to get compliant and new software features
- Natasha’s Law compliant label options
Shop Label Designs Suitable for Natasha's Law
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Your Food Labelling Questions answered by our Experts (PART ONE)
What is Natasha’s Law & how does it affect me?
Is there a grace period for labels to be updated after 1st October?
Does Natasha’s Law affect the whole of the UK?
How does Natasha’s Law apply to distance selling?
What do I need to include on a PPDS label?
How does the ingredient list need to be presented?
What about micro-businesses, do they need to comply with these regulations?
What about plated meals & made to order?
What about packaged food provided by another business?
What would happen to labelling if the person managing it was off work?
Will EHO be checking Natasha’s Law during visits?
Am I required to include QUID information?
Can you add best before on labels?
Are there guidelines on the format and font of the labelling?
In layperson’s terms, should the font be 8pt in size to meet Natasha’s Law?
What about food in vending machines?
How do you label your food? How would you label a BLT?
What about advice for catering in schools?
What about advice for hospitals and the care setting?
What about advice for bakeries?
How do you go about labelling a cheeseburger and chips in a box meal?
Do the same rules apply if food is being given away rather than sold?
What about frozen meals made in our kitchen?
Is there training available about allergens and Natasha’s Law?
What is Natasha’s Law & how does it affect me?
On 1st October 2021, Natasha’s Law will become a legal requirement. Any business that produces Prepacked for Direct Sale (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.
Is there a grace period for labels to be updated after 1st October?
No, it is a hard date - 1st October 2021 - if you sell PPDS food, you need to follow the law from that date onwards - or before.
What is PPDS?
“Prepacked for direct sale or PPDS is food which is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected. It can include food that consumers sele>t themselves (e.g. from a display unit), as well as products kept behind a counter and some food sold at mobile or temporary outlets.”
(FSA)
It could include: A cake packaged in cling film. Bread placed in a paper bag with the bag folded over or twisted to encase the bread. Rolls contained in a plastic bag that is tied with a knot or sealed. Read more here.
What is the definition of packaging for Natasha’s Law?
“The legislation only applies if food is packaged as follows: the food is fully or partly enclosed by the packaging the food cannot be altered without opening or changing the packaging. " (FSA)
So, packaging for PPDS food does not need to be sealed to meet this definition, It can include for example:
- Bags that are folded over or twisted.
- Boxes that have tabs to shut them.
What about partial packaging or non-sealed bags and the law? Can we confirm, if hash browns for example are in an open end bag, would need labelling? Or would a sponge cake in an open 16oz pot need labelling?
"If the food can be altered without opening or changing the packaging then it is not ‘prepacked’ and thus is not PPDS - ‘prepacked for direct sale’."
So if a food item is in a bag which is left open and you can slide the food product out of the bag without doing anything to change the packaging, then it would be defined as non-prepacked food.
Is there an easy way to test whether it is PPDS? Could you advise where we could find a flowchart to decide if an item is PPDS?
Yes, the FSA has created a decision tree to help you.
Does the consumer choose or order the food in person at the premises?
- Is the food presented to the consumer in packaging?
- The packaging should fully or partially* enclose the food when presented to the consumer as the final product? (*If fully or partly enclosed by packaging, the food cannot be altered without opening or changing the packaging in some way.)
- Is the food packaged before the consumer selects or orders it?
- Is the food packaged at the same place* it is sold? (*This includes food packaged by the same food business and sold at a temporary or mobile site, such as a food truck or market stall and food packaged and offered at different units in one building complex, such as an airport or shopping centre.)
- If the answer is yes to all these questions, then it is PPDS. If the answer is no to any of these, then it is not PPDS.
Does Natasha’s Law affect the whole of the UK?
Yes, it will affect England, Wales and Northern Ireland and Scotland.
FSA: https://www.food.gov.uk/allergen-labelling-changes-for-prepacked-for-direct-sale-ppds-food
FSA Scotland: https://www.foodstandards.gov.scot/business-and-industry/safety-and-regulation/food-allergies-2/prepacked-for-direct-sale
Who does it apply to?
Food businesses packing their food products on-site to sell to consumers.
Prepacked for direct sale (PPDS) food can include the following:
- Sandwiches and bakery products, which are packed on-site before a consumer selects or orders them.
- Fast food packed before it is ordered, such as a burger under a hot lamp where the food cannot be altered without opening the packaging.
- Products, which are prepackaged on-site ready for sale, such as pizzas, rotisserie chicken, salads and pasta pots.
- Samples of cookies given to consumers for free which were packed on-site.
- PPDS food provided in schools, care homes or hospitals and other similar settings will also require labelling.
What is not PPDS?
“Any food that is not in packaging or is packaged after being ordered by the consumer. These are types of non-prepacked food and do not require a label with name, ingredients and allergens emphasised. Allergen information must still be provided but this can be done through other means, including orally.
“Food packed by one business and supplied to another business. This is prepacked food and already must have full labelling, including the name of the food and a full ingredients list, with allergenic ingredients emphasised within it.” (FSA)
How does Natasha’s Law apply to distance selling?
The requirements of Natasha's Law do not apply to PPDS food sold by distance selling. For example, food that can be purchased over the phone or on the internet.
The FSA states that:
"Businesses selling PPDS food this way will need to ensure that mandatory allergen information is available to the consumer before they purchase the product and also at the moment of delivery.
"You must provide allergen information: before the purchase of the food is completed - this can be in writing (on a website, catalogue or menu) or orally (by phone) when the food is delivered - this can be in writing (allergen stickers on food or an enclosed copy of a menu) or orally (by phone).
"Allergen information should be available to a customer in written form at a point between a customer placing the order and taking delivery of it. "Takeaway meals should be labelled clearly so customers know which dishes are suitable for those with an allergy.”
(FSA)
What do I need to include on a PPDS label?
“The label for PPDS food will need to show:
- the name of the food
- an ingredients list
- any of the 14 allergens emphasised in the ingredients list, if these are present in the food.”
(FSA)
How does the ingredient list need to be presented?
“The list of ingredients must be headed or preceded by a suitable heading which consists of, or includes, the word ‘ingredients’.
The ingredients used must be listed in descending order of weight at the time the product was made.”
(FSA)
You can list compound ingredients (e.g. ‘bread’ in a sandwich) if you immediately follow the compound ingredient with its own ingredients.
If the product contains any of the 14 allergens they must be clearly highlighted on the listed ingredients.
They can be in bold type, CAPITAL letters, contrasting colours or underlined. Alternative allergen statements, such as ‘Contains: wheat, egg and milk’ are not permitted.
A useful feature of LabelLogic Live, Planglow’s labelling software is that it automatically adds allergens in bold.
Can you put on the PPDS labelling at the time of sale? Can you use shelf edge labelling but nothing on the packaging until it is handed to the customer?
Refer to the definition of PPDS above. If you are selling a prepacked product for direct sale, which is in packaging before it is presented or sold to the consumer, and is packaged at the same site it is offered or sold, then it is PPDS. The shelf edge labelling would not be sufficient.
Check out the FSA’s decision tree.
What about micro-businesses, do they need to comply with these regulations?
Yes, each food business or public organisation, no matter the size, will need to find a way to meet the requirements. If you offer PPDS food, you will need to be compliant.
What about plated meals & made to order?
PPDS doesn't include food that is not in packaging. Food placed into packaging or plated at the consumer's request is not PPDS.
Examples of this include: unpackaged cakes, unpackaged food behind a glass display counter or in a hot hold cupboard, meals made or plated to order. "Non-prepacked (loose) food does not require a label and must meet current allergen information requirements for non-prepacked food.” (FSA)
What about packaged food provided by another business?
“You may also sell prepacked food that was packed by another food business at a different site to where it is offered to consumers, or food that has been packaged by another business.
“This is not ‘prepacked for direct sale’ food but is ‘prepacked’ food. Prepacked food requires a label with a name, ingredients list, allergens and other mandatory details.”
(FSA)
Do suppliers have a legal obligation to inform us if the ingredients in products have changed or will be changing? Or is it purely that caterers have to read the labels of packaging?
Food businesses and their suppliers already have an obligation to ensure that accurate ingredient and allergen information is passed to consumers. Food businesses should also ensure that they have processes in place to update this information should they change suppliers or when ingredients change. Suppliers are legally responsible for passing on accurate information on ingredients and allergens to other food businesses.
Here is information from FSA:
“Food businesses supplying food and ingredients, from operator to operator, have a duty to pass food information down the supply chain. “They should ensure that food businesses are provided with sufficient information to allow them, where appropriate, to meet their labelling obligations as set out in food law.
“You should ensure that you have processes in place to update this information should there be a change in suppliers, or if ingredients change.” (FSA)
Planglow’s LabelLogic Live labelling software is here to keep you compliant with updated ingredients and new products from your suppliers and wholesalers.
Read more about how our client, Petroc College, manages this process here.
We buy individual portions of some items (i.e. jelly, ice cream, cheesecake, trifle and other cold desserts). I assume that on the introduction of Natasha’s Law these items will come in labelled if not already doing so.
As part of our service standards we would present these on a plate to the customer with a spoon and remove the lid. If the manufacturer is putting the ingredient and allergen information on a label on the lid are we at liberty to remove this for service to the customer?
These items should already be labelled if prepacked.
According to the FSA:
“This is not ‘prepacked for direct sale’ food but is ‘prepacked’ food. Prepacked food requires a label with a name, ingredients list, allergens and other mandatory details.”
Or the supplier will need to provide a full ingredients declaration in order for you to package them.
What would happen to labelling if the person managing it was off work?
We would recommend involving two or three members of your team in the labelling process such as the catering manager and chef. This way, you are able to check the accuracy or labelling together as well as to create labelling when one is away.
Will EHO be checking Natasha’s Law during visits?
Local authorities will be taking a supportive, precautionary approach in the early months providing advice and guidance in the first instances. Escalating an issue would depend on the level of risk posed.
How does Natasha’s Law affect Advisory and Precautionary Labelling (PAL)? Can we continue to include ‘may contain statements?’
See FSA guidance below:
“Precautionary allergen information
“Food businesses have a responsibility to provide food which is safe for consumers. You must provide information to help your customers make safe and informed choices. “In addition to mandatory allergen information, voluntary information about the unintentional presence of allergens, usually from unavoidable cross-contamination, should also be provided. Precautionary allergen information from ingredient suppliers must be passed on to the consumer. This precautionary allergen labelling often appears as “may contain” or “not suitable for” information on packaging.
“Although it is not a legal requirement of food law, we recommend that information on the unintended presence of allergens for PPDS foods is communicated on the packaging or label. This is to ensure that consumers with a food allergy or intolerance are aware of the risk and that food is safe.
“This precautionary allergen information should only be provided if a real risk of allergen cross-contact has been identified following a thorough risk assessment. This should only be provided in scenarios where this risk cannot be removed through risk management actions, such as segregation and cleaning.
“The use of precautionary allergen labelling when there is not a real risk, could be considered to be misleading food information and unnecessarily limit consumer choice.
“Providing this voluntary information is not a substitute for good food hygiene and safety practices.
“Food Drink Europe has produced best practice guidance on voluntary application of precautionary allergen labelling."
Update 13/10/2021
Following concerns raised regarding the risks of allergen labelling being misleading in small kitchen environments where cross-contamination could occur, the Food Standards Agency has written giving the go-ahead for precautionary statements, saying:
“On the risk of cross-contamination in small kitchens, each business will also need to decide how to provide voluntary information on the unintentional presence of allergens in food (also known as ‘precautionary allergen labelling’).
If a real risk of cross-contamination has been identified through a risk assessment this can be conveyed to consumers through a phrase such as ‘may contain…’ or ‘made in a kitchen that handles…’. We recommend that this information is also presented on the PPDS label (but it can also be provided through other means in writing or verbally).
"This type of information should not be used as a blanket disclaimer as that reduces choice for consumers as well as their trust in the accuracy of the labelling”.
Does this mean that gluten has to be included on all labels as 'may contain' as it is airborne and likely gluten containing products will be handled in the same kitchen/prep areas? Is there advice on gluten free claims?
It is important to do a risk assessment before you use any form of precautionary allergen labelling such as “may contain”. Find out more about managing the risk of cross-contamination in the Safer Food, Better Business packs.
Below is the advice from the FSA: Free-from, gluten-free and vegan claims:
“Making free-from claims for foods requires strict controls of ingredients, how they are handled and how they are prepared. A free-from claim is a guarantee that the food is suitable for all with an allergy or intolerance.
“For example, if you are handling wheat flour in a kitchen and you cannot remove the risk of cross-contamination through segregation by time and space, you should let the customer know. You should not make any gluten-free or wheat-free claims.
“The Food and Drink Federation provides specific information and guidance on free-from and gluten-free claims.
“Customers sometimes assume that vegan meals are free-from animal-based allergens (egg, fish, crustaceans, molluscs, milk).
This is not always the case as low-level cross-contamination from these ingredients can occur during the production process. You need to be clear about this risk in the food you provide. “The Food and Drink Federation provides specific information and guidance on allergen-free and vegan claims.”
Am I required to include QUID information?
Quantitative Ingredient Declaration (QUID) FSA advice:
“Quantitative Ingredient Declaration (QUID), tells a customer the percentage of particular ingredients contained in a food product. For PPDS foods, QUID is only required for meat products.
“You must give this information either: as a percentage in brackets in the ingredients list after the name of the ingredient, for example ‘pork (80%)’ in or next to the name of the food, for example ‘containing 80% pork’.
“There are exemptions to providing QUID, as outlined in Regulation 7(3) of the Food Information Regulations 2014. This includes ready-to-eat food sold by mass caterers.
"More information on QUID is contained in wider government guidance on food labelling.”
Can you add best before on labels?
Planglow’s LabelLogic Live can add different types of shelf life to suit your needs. Storage conditions and date labelling “Food labels must be marked with either a ‘best before’ or ‘use by’ date so that it is clear how long foods can be kept and how to store them.
“Further information can be found in the guide on date marking on the Waste & Resources Action Plan (WRAP) website.” (FSA)
Are there guidelines on the format and font of the labelling?
Here is the information on labelling - format and font
The information must appear on the package or on a label attached to the package Must be easily visible and clearly legible On the outside of the product and not obscured in any way. Must not be difficult to read due to poor lettering or colour contrast The ingredient list has to be a minimum font size where x-height is 1.2mm or more. If products have a packaging surface less than 80cm2, in which case the x-height can be reduced to 0.9mm.
There's more detail in the technical guidance here:
https://www.food.gov.uk/sites/default/files/media/document/fsa-food-allergen-labelling-and-information-requirements-technical-guidance_0.pdf
In layperson’s terms, should the font be 8pt in size to meet Natasha’s Law?
It all depends on the printer and the font you’re using. In general size 7 should be fine but we recommend checking the measurements on a label print out for each item.
What about food in vending machines?
The same allergen information rules as now apply so you don’t have to make any changes specifically because of the new PPDS rules. Much of the food sold in vending machines will be prepacked food so that will be labelled already e.g packets of crisps or chocolate bars. For non-prepacked food, you will need to have the allergen available somewhere on or next to the machine, or on the item of food itself if possible.
How do you label your food? How would you label a BLT?
Food labelling must be descriptive and inform the customer of the true nature of the food Customary names which are commonly understood can be used, such as ‘BLT sandwich’.
Where names are prescribed in law they must be used. This mainly applies to food containing seafood, fish and meat ingredients.
Can you advise what is required if we have a kitchen and decant opened boxes of food e.g cereal into a lidded container for safe storage please.
Is this PPDS?
In this case, it is not, assuming that the cereal is not presented to the customer in packaging. See PPDS definition.
Ask yourself:
- Does the consumer choose or order the food in person at the premises?
- Is the food presented to the consumer in packaging? The packaging should fully or partially* enclose the food when presented to the consumer as the final product? (*If fully or partly enclosed by packaging, the food cannot be altered without opening or changing the packaging in some way.)
- Is the food packaged before the consumer selects or orders it?
- Is the food packaged at the same place* it is sold? (*This includes food packaged by the same food business and sold at a temporary or mobile site, such as a food truck or market stall and food packaged and offered at different units in one building complex, such as an airport or shopping centre.)
If the answer is yes to all these questions, then it is PPDS.
If the answer is no to any of these, then it is not PPDS.
I work in a cafe where we put our salads in boxes but showcase them without the lids in a refrigerated deli counter. We put the lids on after the customer has ordered it. Is this subject to the labelling requirements?
No, if we refer to the definition of packaging in PPDS. Packaging needs to completely or partially encase the food so the food cannot be altered without doing something to the packaging. If it’s open with no lid, then the food can be accessed and changed in some way. If it’s in that form when a customer orders it, then it’s not PPDS or subject to the new legislation. You still need to provide allergen information in some form e.g. a sign on your cafe or verbally.
“Non-prepacked (loose) food does not require a label and must meet current requirements for providing allergen information. This means you must provide information on the 14 major allergens to consumers. You have some choice in how you provide this information to them.” (FSA)
There is more information for restaurants, cafes and pubs here: https://www.food.gov.uk/business-guidance/prepacked-for-direct-sale-ppds-allergen-labelling-changes-for-restaurants-cafes-and-pubs
What about advice for catering in schools?
My junior school does a packed lunch which is pre-ordered; sandwiches are put into a plastic pack or bag. Do we need to put a label on them?
No, this is pre-ordered and therefore does not fall into the PPDS category. If the packed lunch has not been ordered by an individual then it would have to follow PPDS labelling requirements. If there are multiple items in a packed lunch you will need to provide allergen information for each item. Each PPDS item would need to be labelled individually.
Here is the advice from the FSA:
“PPDS allergen labelling changes only affect food that is packed and sold or offered at your site.
“If packed lunches are made on school premises in anticipation of an event, such as a school trip, the allergen information requirements may vary. If the lunches are made and packed to order, these are not prepacked, and are therefore not PPDS. If, however, the school lunches are made and packed without specific orders from individual children, then these would need to comply with the new PPDS labelling requirements.
“If there are multiple items in a packed lunch you will need to provide allergen information for each item. You will need to label each PPDS item individually.
“Any prepacked items you have bought from elsewhere (that is food packed at a different location by another business) will already have full ingredients labelling.”
You can find more information about Schools, Colleges and Nurseries on the FSA website: https://www.food.gov.uk/business-guidance/prepacked-for-direct-sale-ppds-allergen-labelling-changes-for-schools-colleges-and-nurseries
I work in a school kitchen and make sandwiches daily. They are then placed in a paper bag and given to the child. Do I have to label every sandwich or would an allergen sheet from the council be sufficient?
This depends on when the order is made. So if a parent made a specific order for a student in advance, then the food has been made to order and it is not PPDS. But if there is an array of packaged sandwiches, and the student chooses one, then it would be PPDS and would need full ingredient labelling.
Where primary schools are serving jelly or fruit salad in a pot, would this need full ingredient labelling? The menu of the day is pre-chosen by the parent, which includes a choice of dessert, which is listed.
See answer above.
What about buffet food that is packed for customers for COVID secure reasons? Is this treated as PPDS? Where do buffets fall into the regulations when not individually served, please?
With buffets, it depends on the setup. PPDS applies to single items that are offered to customers. If there is a big plate with sandwiches on it, and consumers take one on to their plate, this is not PPDS.
If they are offered sandwiches as prepacked but they have been ordered in advance and made to order, these are not PPDS.
You would still need to provide allergen information as required by the current laws. But if an item is individually wrapped as part of a buffet - and not made to order - and a consumer chooses it, then this is PPDS and falls within Natasha’s Law. This could be a range of packaged items, but not specifically ordered, such as individual sandwiches, cakes etc, which would need the PPDS labelling.
What about advice for hospitals and the care setting? For food packaged in hospital canteens for patients, is it PPDS?
If you package the food for your patients before they order it, at the same location that it is offered, and the food is fully or partly enclosed by the packaging/ cannot be altered without opening or changing the packaging, it’s PPDS. But if it’s not prepacked and offered on a plate, then you would provide allergen information as you do now on a sheet, poster or verbally.
Check out the FSA’s decision tool: https://www.food.gov.uk/allergen-ingredients-food-labelling-decision-tool
We ask patients to request if they would like certain items made up in advance. Would these be classed as pre-packed for direct sale and would they need labelling?
If the item has been ordered in advance by the customer, then you would not need to provide the PPDS labelling. You would need to provide the customer with allergen information as per the current regulations.
We also prepare snack items (i.e. sandwiches) for supper and these would be plated and placed in the fridge covered for later use. These would generally be served out by the nursing team to patients from a bulk plate. Would these items be classed as prepacked for direct sale and would they need labelling?
In this case, they would not be presented to the customer in packaging, and would not be PPDS.
We are an acute teaching hospital who prepare patient meals on site. The food is served bulk style from a food trolley, would we need to label our meals?
If the food is pre-ordered or non prepacked, then it would not be PPDS and therefore not come under the new legislation. You would need to verbally or in writing inform patients about allergens as you do within the current law.
We wrap sandwiches in cling film, take them to the wards & then unwrap the sandwiches serving to the patient on a plate. Do these sandwiches need labels on for transportation?
The key point here is that food needs to be packaged and ready for presentation to the customer. The food is unpackaged before being presented to the customer so it is not prepacked food. You still need to provide the allergen information as you do now - in writing or verbally. But if you presented the food packaged on site to the end customer that they had not pre-ordered, you would need to label it.
We provide meals at home for the elderly. They are pre-ordered by the client. We put allergen information in a tick box format. Do we need to provide labels with a full ingredient list?
No, because the food is pre-ordered, you do not need to add the PPDS information. You need to add the allergen information as in the current guidance.
What about advice for bakeries? What about cakes that are made in cafes & then bagged up when the customers choose what they require - do these need labelling?
No, by the definition of PPDS, these are packaged when the customer chooses what they want rather than being prepacked. This could include: unpacked cakes or slices of cake, pastries, loaves, buns, sandwiches or rolls made to order at the consumer's request. FSA “Non-prepacked (loose) food does not require a label and must meet current requirements for providing allergen information. This means you must provide information on the 14 major allergens to consumers. You have some choice in how you provide this information to them.”
Is there specific guidance for home bakers?
Yes see FSA’s guidance for home bakers.
“Home bakers, who sell their food online or through other means of distance selling, will already be required to provide allergen information before food is ordered and when it is delivered.
“Food sold through distance selling, without the physical presence of the consumer during the ordering process, will not be impacted by the new regulations.
“However, this food will still be subject to requirements for distance selling. We have further information on food sold through distance selling and the allergen information that must be provided in our technical guidance.
“If you have recently started to sell food from home, use our guide to starting a food business from home for more information on registration, food hygiene, allergen management and selling food online.
” If a cafe has six cake stands with dome lids with scones, pastries, pre-cut cake. Is this classed as PPDS? This is not PPDS. In this instance, the customer is choosing the food item from cake stands and then the product is packaged. The food is not packaged before the customer orders it.
If you are a home baker and you sell your products to a bakery and the products are kept in a jar and placed in a paper bag for sale? Do you need to label? Does this law apply to home baked cake sales?
The important thing to note is the point at which it is packaged and sold. If the home baking is loose and only packaged when a customer orders it, it is non PPDS. We need to refer to the definition of PPDS. If the cakes are put into individual bags before the customer orders, then you need full ingredients PPDS labels.
In my bakery, some customers have a box of mixed cakes in a cardboard box, how would I label it?
Assuming that these are packed to order, they would not have to follow the PPDS guidance.
Read more about the FSA’s PPDS advice for bakeries here: https://www.food.gov.uk/business-guidance/prepacked-for-direct-sale-ppds-allergen-labelling-changes-for-bakers
How do you go about labelling a cheeseburger and chips in a box meal?
If it is made to order it does not require a label. The food item only requires a label if the product is prepacked before the customer selects or orders it. Then all of the ingredients need to be listed.
Does Natasha’s Law apply to an individual wrapped piece of fruit or prepacked fruit (e.g grapes and apples)?
You do not need to list ingredients, such as for fresh fruit and vegetables, including potatoes, which have not been peeled, cut or similarly treated. (FSA)
https://www.food.gov.uk/business-guidance/labelling-guidance-for-prepacked-for-direct-sale-ppds-food-products
If I make a mixed fruit salad with diced /sliced fruit then mix it up and put it into packaging. How do I list the fruit as the weights are likely to differ?
All the ingredients used in making the product must be listed in descending order of weight at the time the product was made. Based on the information that you have provided, we would suggest that the ingredients should be listed on the label based on the quantities of each ingredient used in the overall recipe before packaging into individual portions.
Do the same rules apply if food is being given away rather than sold?
The legislation applies to both sold, offered and free food that meets the definition of PPDS.
What does 'sold' mean in relation to Natasha's Law? Does it mean that payment is made for the prepackaged food at the time of collection? In a buffet, items are "free", but paid for with an invoice.
<b>If we put three items already individually labelled into a clear bag, does the outer bag require a label?</b>
These rules apply to things that are 'single items' ready for presentation to the customers. If your ‘single item’ is composed of three things in an outer pack which have been packed on-site, then you would need to label the outside.
What about frozen meals made in our kitchen?
See the definition of PPDS and decision tree:
https://www.food.gov.uk/allergen-ingredients-food-labelling-decision-tool
We sell pasties that are baked from frozen. If a customer orders 100 pasties for a wedding, we will put them in a bag. Would we be responsible for the guests getting the allergen information?
As these are pre-ordered they would not be PPDS. You would provide allergen information verbally or in writing as you do now.
Is there training available about allergens and Natasha’s Law?
Yes, the FSA has food allergy online training: https://www.food.gov.uk/business-guidance/allergy-training-for-food-businesses Planglow is here to help. Get in touch with our friendly and expert team to ask a question.
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The Menucal tool supplied by FSS does not have a category for greatest ingredient first, will this change? Are there any other free online tools?
We are currently updating MenuCal to include more supportive functions with regard to the changes for labelling of PPDS foods and hope to have them live in the tool shortly. However, the weights of foods can be recorded in the tool when using it for both Calories and Allergens which may be an interim solution for users.
The FSA online Allergen training was last updated on 7 Sept 20. Do you know when this will be updated to include Natasha's Law/PPDS?
The FSA online allergen training was updated to include PPDS content in June 2020. The content of this training will be reviewed on a regular basis.
I understand that in addition to the 14 allergens there is another B list. Can someone explain if this is the case in the UK and where the list is and do the regulations cover this list to the same extent in terms of what is required?
The current regulation that applies in the UK includes a list of 14 allergens, which are recognised as the most common ingredients or processing aids of public health concern across Europe that cause food hypersensitivity. Food businesses must provide clear information on the presence of these 14 allergens in foods – the way this information is presented varies depending on the category of food e.g. whether is it prepacked, PPDS or sold loose (as non-prepacked food). The UK Government has no plans at present to add to the 14 allergen list. Any additions to this list would only be made based on relevant scientific evidence and views gathered through public consultation. (There is no ‘B list’ of allergens outside of the 14 allergens list).
Given the new guidance is it the case that manufacturer are expected to include allergen and ingredient information on individual sachets that are sold as part of an outer box. (i.e. sauce sachet, milk portions, Nutella portions, marmite, jam)
Suppliers have a responsibility to provide food information down the supply chain, as laid out in Regulation (EU) 1169/2011, Article 8(8), which states “food business operators…shall ensure that those other food business operators are provided with sufficient information”. We would encourage all food businesses to ensure they are getting accurate information from their suppliers.
Multipacks are ‘prepacked food’ and individual packets from a multipack should not be sold or offered if they do not comply with labelling requirements. This is why packets inside a multipack that do not individually comply with the applicable labelling requirements will be labelled “not for individual sale” or “part of a multipack, not for resale.”
Any prepacked food you sell or offer must be labelled in accordance with the requirements for prepacked food even if you are not the operator responsible for the food information.
The original supplier should be labelling the individual items, and not just the multipack, if the intention is to separate these out and provide them to individuals separately. If you are not receiving appropriately labelled items from your supplier you should request that they do provide you with correctly labelled items.
