What is Natasha’s Law?
Natasha’s Law came into effect on 1st October 2021, and requires food businesses to provide full ingredients lists, including allergen information, on foods pre-packaged for direct sale on the premises.
The Food Information Amendment was brought about following the death of teenager Natasha Ednan-Laparouse, who died after an allergic reaction to an undeclared ingredient in a pre-packed meal. It is estimated about 1 in 5 people in the UK suffer from some kind of allergy, and the legislation was introduced to protect allergy sufferers and give them confidence in the food they buy.
PPDS (Pre-packaged for Direct Sale)
Natasha’s Law applies to PPDS food. PPDS food is food that is packaged at the same place it is offered or sold to consumers. It is a single item, consisting of the food and its packaging, that is ready for presentation to the consumer before it is ordered or selected.
It applies to hot and cold food – anything which is pre-packed before being ordered, and to food which the customers pick themselves from a display counter, as well as food behind the counter, if it is already packaged.
Food is PPDS if it is a single item, packaged as follows:
- the food is fully or partly enclosed by the packaging
- the food cannot be altered without opening or changing the packaging
- the food is ready for sale to the final consumer.
The Food Standards Agency have developed a tool to help you identify if the food you serve is classed as PPDS. You can find this PPDS identification tool here.
How Will Natasha’s Law Affect Your Business?
For many catering organisations, there will be minimal impact on their catering offer. If food is served in a dining room from a hot or cold counter and is unpackaged, then no changes are needed – although full allergen information should be available for the food which you serve. Food which is put into packaging after it has been chosen/ordered is not affected either. If food is cooked to order from a menu then it does not need ingredients lists to be provided – but again, allergen information must be available.
If the food is bought in already packaged (e.g. confectionary, crisps, bought in sandwiches etc), then the manufacturer is already required to list the ingredients on the packaging.
However, if you make food and package it on site, or portion up and package bought-in food on site, the new regulation is likely to affect you. Examples of food which is packaged on site, before being ordered by the customers includes:
- site-made sandwiches
- individual wrapped cakes or biscuits
- pots of salad
- pots of jacket fillings such as coleslaw
- fruit pots
- breakfast pots
- boxes of hot food such as pizza or nuggets on a hot counter
- some food served at functions or events may also be affected, if it is packaged in advance.
These PPDS items must be labelled with a full ingredients list. That means it is essential you know what ingredients are in each item – so you should develop specific and consistent recipes for each of these items, and make sure staff do not deviate from the approved recipe.
What Information Must Be on Your Food Labels?
If you identify that you do serve PPDS food, then it must now be labelled with the name of the food and a FULL INGREDIENTS LIST. Any allergens in the ingredients must be emphasized – e.g. in bold type. Ingredients should be listed in decreasing order, and there are specific requirements for font size etc – more information can be found on the Food Standards Agency website.
This is a significant change for catering. Prior to this, there was only a requirement to provide allergen information, but now every ingredient must be listed. For example, in a cheese and pickle sandwich, there can be over 30 ingredients:
In addition, these may vary slightly depending on the brand of food provided. Different breads will have different ingredients, and different brands of mayonnaises, pickles and dressings may have subtly different ingredients too. This means the same brand should be used each time, and/or the ingredients lists need to be checked regularly. Given the current supply chain issues, it is likely you will get substitutions delivered in place of your usual brands, so this is something which needs to be looked at closely.
Only buy from your approved suppliers. Try to set up an agreed substitution list, so you know what you are going to get delivered.
Printing Food Labels for Natasha’s Law
Depending on how much PPDS food you provide, you may need to consider software and printing options for the kitchen. The software will ensure the labels are compliant with the font size etc, and should ultimately save time. You can use an existing printer, but label specific printers are efficient – consider whether to use thermal printers or ink printers – and consider the cost of ink cartridges etc.
If you are planning on using your existing printing capacity, bear in mind many kitchens have limited access to printers and computers due to lack of space.
Natasha’s Law Checklist
- Identify if you have any foods affected by Natasha’s Law.
- Develop set recipes for these items.
- Decide how you are going to label these foods – e.g. printer, labels, software. Make sure you have plenty of labels and printer ink in stock.
- Talk to your suppliers about stock and substitutions. Make sure there is a system to check the labels are correct in case any of your usual products or ingredients are substituted.
- Train staff in the new requirements of Natasha’s Law, and how to label. Also refresher training in allergy awareness.
- Arrange an independent audit to see how well your allergy management systems are working.
It will take time to set up an effective Allergen Management system – and extra time during each day to ensure it is working properly. An incorrect label is potentially more dangerous than no label, so it is essential that time is available to make this work. Environmental Health Officers will be adding this to their inspection lists when they next visit your kitchens.
How Can We Help?
How do you know if your new allergy management system is working and compliant with the new regulations?
At In House, we can help you with your allergy systems – both general allergy management, and the new Natasha’s Law systems. We can audit your policy and procedures, either as a stand-alone allergy audit, or as part of a food hygiene audit of your whole catering operation. The allergy aspect of our audits includes:
- Management procedures – a review of your policy and procedures, notices, staff training
- Practical inspection – storage of allergens, safe handling, labelling, staff knowledge
We can also provide food safety training for staff. There is a wide range of training available for allergy awareness, both formal and bespoke. This includes:
- Formal CIEH or HABC Allergy Awareness course – suitable for more senior catering staff and managers. This is a half day course and covers
- Food allergies, intolerances and Coeliac disease
- The 14 regulated allergens
- Food labelling requirements – including new Natasha’s Law requirements
- The importance of practical allergen management
- Providing complete and accurate allergen information to consumers
- Bespoke allergy awareness courses – aimed at general assistants etc. We can provide these at any length, although 1.5-2 hours is usual. We will provide a certificate of attendance for staff who attend this course.
- Get in touch to learn more about our allergy awareness courses and how we can help your business.