There is a lot of information and conversations taking place about Natasha’s Law but do you know what it is?
More importantly do you know what you need to do to follow the rules and stay legal?
This amendment to the Food Information Regulations will be enforced from 1st October 2021. It applies to any food business offering food to the public or mass caterers which includes mobiles, restaurants canteens, hospitals.
What is Pre-Packed for Direct Sale Food (PPDS)?
In my previous blog Allergen Labelling for Pre-Packed for Direct Sale Food I explain what PPDS food is. As a food business you must make a decision on whether it applies to the food you serve. Use the questions in the flow chart to see if it applies to you. If it does you must follow the rules to stay legal.
This update will explain what to put on the label or package for PPDS food. This is food you are making on your premises and pre-pack BEFORE you offer it for sale to the customer. Examples are boxed sandwiches, hot rotisserie chicken, pre-weighed and packaged deli cheeses/meats and boxed salads.
Where can I find the relevant guidance?
(1)The Food allergen labelling and information requirements technical guidance published in June 2020. Here you can find out how you can comply specifically with the allergen labelling requirements including PPDS food.
(2)The Food Information Regulations 2014 Summary Guidance published in July 2020. This document explains how you should provide food information to your customers including the required format of the ingredients list.
What must be on the label for PPDS food?
The Name of the Food
When naming the food you must think consider if it has a legal, customary or descriptive name? Also check out the guidance for any exemptions.
This will make sure that your customers know what the food in the packaging actually is.
An ingredients list (FIR guidance p21-23)
Start the ingredients list with the word ‘ingredients’ .
List the ingredients in descending order of weight. In the guidance it does not specify that each ingredient must be physically weighed therefore it is reasonable to make an estimate if you need to. Also check if any exemptions apply and what to do about compound ingredients.
If you are using bought in ingredients eg. bread for sandwiches, you can use the ingredients and allergen information on the pre-packed bread label. If you are making the bread yourself you will need to know the ingredients and allergens it contains from your recipe.
Top Tip: documented standard recipes can be useful to help with PPDS labelling
….including Allergenic ingredients (Allergen guidance p10-11)
Emphasize the 14 allergenic ingredients every time they appear in the ingredients list. This can be in bold, in capital letters or in contrasting colours.
How should mandatory information for PPDS food be presented on the label?
- be visible, clearly legible and not obscured.
- on a printed label wherever possible (to reduce human error of handwritten labels).
- the minimum font size is 1.2mm if the label is 80cm2 or bigger, or 0.9mm if it is less than this. See Allergen guidance p18-19 for more information.
- see an example on the Food Standards Agency allergens page for What needs to be on the label
If you need any more help with Natasha’s Law or PPDS labelling please Contact me