Natasha's Law

Food Labelling changes

The change to food labelling law known as Natasha’s Law, is effective from Friday 1 October 2021.

The legislation makes it mandatory for any business that produces Pre-Packed food for Direct Sale (PPDS) to label it with the name of the food and a full ingredients list, with allergenic ingredients emphasised within the list.

This is food which is packaged at the same place it is offered or sold to consumers and is in the packaging before it is ordered or selected.

The factsheet is available online in a number of languages from the Chartered Trading Standards Institute (CTSI) website.

We are distributing printed copies of factsheets to businesses in the borough.

Food allergy and intolerance

• Between 1-2% of adults and 5-8% of children in the UK have a food allergy.
• Tragically about 10 people a year die from food induced anaphylaxis.
• A food allergy is when your immune system mistakes the protein in food as a threat.
• A food allergen is any substance, consumed or inhaled, that causes a reaction of the immune system.
• There is no cure for food allergies. The only way to manage it is to strictly avoid food that triggers the body’s immune response. The smallest trace of an allergen could cause a fatal reaction.
• Symptoms of an allergic reaction can be mild, moderate or severe.
• Anaphylaxis is the most severe allergic reaction. It is potentially life-threatening and requires immediate medical treatment. If you think someone is experiencing anaphylaxis dial 999 and ask for an ambulance.
• Food intolerance is not the same as a food allergy. Most do not involve the immune system and are generally not life threatening. Intolerance is a difficulty digesting certain foods and having an unpleasant physical reaction to them.
• Coeliac Disease is an autoimmune condition caused by a reaction to gluten, a dietary protein found in cereals such as wheat, barley and rye. The body’s immune system attacks the small intestines and reduces its ability to absorb nutrients from food.
• Customers with food intolerance and Coeliac Disease should be treated with the same caution as someone who has a food allergy. Failure to do so could make someone very ill or affect their long term health.

Legal requirements

• Food businesses have a legal duty to provide information about the presence of 14 allergens required to be declared by law which are in the food or drink they sell. These 14 allergens are listed, with examples, below.
• Any food produced or prepared for consumers must be safe.
• If you tell a customer food is ‘free from’ a specified allergen and it is not, you have supplied unsafe food. This applies whether the allergen is one of the 14 allergens required to be declared by law or not.
• Food must be accurately described and food descriptions must not be false or misleading.
• Supplying unsafe food, or making false or misleading statements about food in the course of a food business is a criminal offence.
• Prepacked Food: which is fully or partially enclosed by packaging so that the food cannot be altered without opening or changing the packaging must have full labelling; including the name of the food and a full ingredients list with any allergens listed being emphasised each and every time that they are mentioned.
• From Friday 1 October 2021 food allergen labelling is required on food Prepacked for Direct Sale (PPDS). PPDS is food which is packaged at the same place where it is offered to consumers and in packaging before being ordered or selected, for example sandwiches or salads. Labels must declare the name of the food and a full list of ingredients. If any of the 14 allergens are present in the food they must be emphasised in the ingredients list, such as in bold font.
• Non Prepacked Food: allergen information can be provided in writing (best practice) or verbally.
• Where food allergen information is communicated verbally, a food business must display a written notice placed in a clearly visible position explaining how your customers can obtain this information.
• Food businesses selling food at a distance, such as internet and telephone sales, are legally required to ensure that food allergen information is available to consumers both before the order is placed and also at the point of delivery to the customer.

Allergen management

• Implement a documented food safety management system such as Safer Food Better Business.
• Have allergen management procedures in place from back to front of house including storage, preparation and service areas.
• Identify and record the presence of the 14 prescribed food allergens in all food and drink you supply. Include ‘May Contain’ ingredients. Where necessary obtain, written allergen information from your suppliers.
• Train all staff to be Allergy Aware and record their training. Update staff when allergen information changes.
• Have a dedicated member of staff on each shift who has overall responsibility for allergen management and who can talk to customers about food allergies.
• Manage cross contamination risks when preparing, cooking and serving food. Only use precautionary allergen statements if you have carried out a meaningful risk assessment and it is not possible to guarantee there will be no allergen cross contamination.
• Store ingredients securely. Allergen free ingredients should be stored separately and preferably at a higher level than those containing allergens. Be aware of air borne allergens such as flour. Clean up spillages immediately.
• Review and update food allergen information as ingredients may change if you receive a product substitute, change supplier, change a specification/recipe or change your menu.
• Always ask customers if they have an allergy or intolerance before taking an order for food. Accurately record allergen-free food orders and effectively communicate them to the chef.
• Have a ‘no guessing’ rule; staff should never guess the answer to a question about allergens.
• Have an Emergency Action Plan in place so staff know what to do in the event of an emergency.
• Do not cater for a customer with a food allergy or intolerance if you cannot do so safely.

Be a responsible business 

• Create a positive food safety culture that strives to provide safe food.
• Take food allergy/intolerance seriously - it could save someone’s life.
• Ensure allergen management procedures are in place.
• Check for allergens in your food and drink.
• Consider cross contamination risks.
• Train all staff.
• Ensure back/front of house communication is clear.
• Always ask your customers if they have a food allergy/intolerance.
• Provide customers with clear and accurate information so they can decide if food is safe for them to eat.
• Double Check, Never Guess.
• Do not cater for allergy/intolerance customers if you are unable to do so safely.
• Be allergy aware.

The 14 allergens

• Celery - This includes celery stalks, leaves, seeds and the root called celeriac. You can find celery in celery salt, salads, some meat products, soups and stock cubes.
• Cereals containing gluten - Wheat (such as spelt and Khorasan wheat/Kamut), rye, barley and oats is often found in foods containing flour, such as some types of baking powder, batter, breadcrumbs, bread, cakes, couscous, meat products, pasta, pastry, sauces, soups and fried foods which are dusted with flour.
• Crustaceans - Crabs, lobster, prawns and scampi are crustaceans. Shrimp paste, often used in Thai and south-east Asian curries or salads, is an ingredient to look out for.
• Eggs - Eggs are often found in cakes, some meat products, mayonnaise, mousses, pasta, quiche, sauces and pastries or foods brushed or glazed with egg.
• Fish - You will find this in some fish sauces, pizzas, relishes, salad dressings, stock cubes and Worcestershire sauce.
• Lupin - Lupin is a flower, but it’s also found in flour. Lupin flour and seeds can be used in some types of bread, pastries and even in pasta.
• Milk - Milk is a common ingredient in butter, cheese, cream, milk powders and yoghurt. It can also be found in foods brushed or glazed with milk, and in powdered soups and sauces.
• Molluscs - These include mussels, land snails, squid and whelks, but can also be commonly found in oyster sauce or as an ingredient in fish stews.
• Mustard - Liquid mustard, mustard powder and mustard seeds fall into this category. This ingredient can also be found in breads, curries, marinades, meat products, salad dressings, sauces and soups.
• Nuts - Not to be mistaken with peanuts (which are actually a legume and grow underground), this ingredient refers to nuts which grow on trees, like cashew nuts, almonds and hazelnuts. You can find nuts in breads, biscuits, crackers, desserts, nut powders (often used in Asian curries), stir-fried dishes, ice cream, marzipan (almond paste), nut oils and sauces.
• Peanuts - Peanuts are actually a legume and grow underground, which is why it’s sometimes called a groundnut. Peanuts are often used as an ingredient in biscuits, cakes, curries, desserts, sauces (such as satay sauce), as well as in groundnut oil and peanut flour.
• Sesame seeds - These seeds can often be found in bread (sprinkled on hamburger buns for example), breadsticks, humus, sesame oil and tahini. They are sometimes toasted and used in salads.
• Soya - Often found in bean curd, edamame beans, miso paste, textured soya protein, soya flour or tofu, soya is a staple ingredient in oriental food. It can also be found in desserts, ice cream, meat products, sauces and vegetarian products.
• Sulphur dioxide (sometimes known as sulphites) - This is an ingredient often used in dried fruit such as raisins, dried apricots and prunes. You might also find it in meat products, soft drinks, vegetables as well as in wine and beer. If you have asthma, you have a higher risk of developing a reaction to sulphur dioxide.

Other resources available

Templates, checklists, and sector-specific guidance is also available for;

• bakers;
• butchers;
• mobile sellers and street vendors;
• event caterers;
• fast food and takeaway restaurants;
• schools, colleges and nurseries; and
• restaurants, cafes and pubs on the Food Standards Agency (FSA) website.

Please get in touch 

Our officers can answer any queries or concerns you may have.

Feel free to contact us by calling 01628 683800 or via email at trading.standards@rbwm.gov.uk or env.health@rbwm.gov.uk.