Food labelling and composition

New prepacked for direct sale labelling requirement

On 1 October 2021 the law on allergen labelling for prepacked for direct sale (PPDS) food changed. This means any business selling PPDS foods has to include a full list of ingredients on the product labelling with allergenic ingredients emphasised on that list.

Also known as "Natasha's Law", the change comes following the death of a teenager Natasha Ednan-Laperouse, from an allergic reaction caused by a prepacked baguette, which at the time did not require allergen labelling.

PPDS foods can include salads and sandwiches etc. that the customer selects themselves as well as pre-wrapped foods kept behind the counter, as well as some products packaged and sold at mobile or temporary outlets.

To help support businesses, the Food Standards Agency has launched a PPDS Hub featuring information including new labelling guidance for PPDS foods and sector guidance. The guides for bakeries, butchers, fast food and takeaways, mobile sellers, restaurants and cafes, pubs and schools each give practical information on PPDS and how these changes could impact businesses. You can also find further guidance and an allergens webinar to support businesses with compliance on the Business Growth Hub.

Allergens

EU Regulation 1169/2011 on the provision of information for consumers (FIC) and the UK Food Information Regulations 2014 (FIR) introduce mandatory allergen labelling on pre-packed food and requirement for the provision of allergen information at restaurants and takeaways. Food Standards Agency has produced guidance for small businesses, a range of resources to assist businesses to comply, and on line training.

We have also produced allergen charts and example recipe charts to further assist food businesses.   

The Chartered Institute of Trading Standards have also produced allergen resouces in many languages including Bengali, Bulgarian, Cantonese, Hungarian, Kurdish, Mandarin, Polish, Punjabi, Romanian, Turkish and Urdu.

Food Labelling and compositional requirement

There are many legal requirements which cover the composition and labelling of food which caterers, manufacturers, distributors and retailers of food need to follow. There are also a range of product specific regulations covering particular foods such as bottled water, bread and flour, cocoa and chocolate products, fats and oils, fruit juices, honey, jams and preserves, meat and meat products, milk and milk products etc. and organic food and specific regulations which govern the nutrition and health claims that can be made in relation to food (e.g., low fat, source of protein, lowers cholesterol etc.).

Furthermore there are specific rules and restrictions governing food imports into the UK from outside the European Union.

A full range of detailed guidance on food labelling can be found on the Gov.uk website and Business Companion website which includes in depth guides on allergens labelling, labelling of sweets, jam and similar products, GM foods, organic foods and many more.

We appreciate this leglislation is complex and small businesses may find it difficult to interpret. If you have specific labelling queries regarding the food you manufacture or sell please contact us and we will try to answer your questions.

If however you require a detailed definitive legal interpretation we recommend you employ the services of a public analyst or similar food safety consultant.