Confused about food labelling?
It seems that it has become a bit of a minefield for most food businesses. Particularly with the food labelling laws changing on 1st October 2021 when Natasha’s Law under the amended regulations
will come into force in the UK.
There has been lots of advice and information available on how businesses can get ready. However don’t worry if you are at the last minute and need some help. Use my beginner’s guide with 10 handy tips which hopefully will make things ‘as easy as pie’
Why are there different rules for labelling different types of food?
As a consumer you need to know what is in the food you are are eating. This is because you may have a food allergy or require nutritional information etc. It all depends on how the customer can obtain this information to what the label needs to say. Essentially if there is someone in the business a customer can ask about the food they are eating or purchasing then less information is required to be on the label.
Loose or non pre-packed food
This is food that is served in a restaurant/cafe or food that is not in packaging when the customer orders it or is packaged at the customers request after they order
- restaurant meals
- a deli sandwich ordered and put in a bag at the customer’s request,
- a pizza slice displayed on a tray or
- battered fish in a glass display
There is no requirement to label or have an ingredients list or nutritional information for loose food. However you must provide clear and accurate information about allergenic ingredients in the food you produce or serve.
You must either clearly signpost customers to this information in a written statement such as in this allergen signage example.
Alternatively write it on a chalk board, on the menu etc.; or upfront on the menu.
Helpful tip 1: labelling food on buffets
If you do buffets label individual food with the allergens they contain to help customers with allergies to decide what is safe for them to eat. Also keep food separate to reduce cross contamination.
Helpful tip 2: Use the allergen matrix
Although legally you can give allergen information orally writing it down in a allergen matrix
will help make sure it is accurate and mistakes are not made.
Helpful tip 3: Labelling non-prepacked food distance selling
Non pre-packed or loose food sold online or over the phone such as a food delivery or takeaway, is known as distance selling. You must provide allergen information before the sale either orally or on your website, social media site etc. Also label the food with the allergens it contains or on a written menu on delivery.
Pre-packed Food for Direct Sale [PPDS]
The new rules for pre-packed for direct sale food are detailed in the amended regulations called Natasha’s Law. This is food that is made onsite and packaged before being offered for sale on the same premises. Label the food with the name of the food, and a full ingredients list with allergens emphasized on it.
Helpful tip 4: Decide if the food PPDS
- a pre-packed sandwich or salad made on site and displayed in a chiller,
- a pizza made in a supermarket and packaged and displayed.
- a burger in a fast food restaurant that is packed before it is ordered often at busy times
- food sold in a mobile but made and packaged by the same business
Use the decision making tool to decide if your food is PPDS
Also read my blog for my Ten top tips to help you get ready for Natasha’s Law.
Helpful tip 5: the new rules do not apply to food sold by distance selling
Distance selling is when the customer is not physically present when the food is ordered. If the food is picked up as a takeaway or delivered to a customer’s house you must follow the rules for non-prepacked or pre-packed food.
Food that is packaged before it goes on sale is called pre-packed food.
The label must include mandatory information detailed in Article 9 of the FIC regulations
including the name of the food, list of ingredients with allergens emphasized, net quantity, minimum durability or shelf life etc.
Helpful tip 6: Get expert advice
You might need extra help to get your labels right, including microbiological testing for minimum durability or ‘use-by’ date and nutritional analysis .
Helpful tip 7: Labelling pre-packed food sold by distance selling
If you sell pre-packed food over the phone or online, known as distance selling, you must make the same information available as if you were buying it in a shop except the durability date. You should not charge premium rates if providing this information by phone.
Helpful tip 8: Business to business selling
If you sell food to a wholesaler or caterer, such as individually packed brownies, label them as pre-packed food. However you can put the following information on the label and provide the other mandatory information in commercial documents.
• Name of the food,
• Date of minimum durability,
• Special storage conditions / conditions of use,
• Name and address of food business operator.
For pre-packed and PPDS food there are rules in about how the mandatory information including allergens must be provided on the label. See p18 of the technical guidance
for a detailed explanation including the size of the font and the size of the label.
Helpful tip 9: handwritten v printed labels
Handwritten labels difficult to read or rub off, so it is better to print them if you can.
Helpful tip 10: be careful that you follow the labelling rules,
If you start putting additional information on labels like a ‘durability date’ this triggers the need to follow the pre-packed rules above.
Where to find more information
Introduction to allergen labelling changes
Food allergen labelling and information technical guidance
The Food Information Regulations 2014
The Food information [Amendment][England]Regulations 2019
The Food Information to Consumers Regulation 2011
Labelling guidance for food sold online
Speak to your local Trading Standards Department for further help on labelling and read my guest blog getting your food labelling right.
if you would like help with your food labelling to make sure you are ready for Natasha’s Law or any other food safety issue