If you prepare food like sandwiches or pies on site and then package them for sale then you need to be aware of how you will need to label these type of foods in the future.
Mandatory allergen information must be provided in terms of the use of allergenic ingredients in food and food is divided into two categories pre-packed and non pre-packed which includes loose food, food packaged at the request of a customer and pre packed for direct sale.
What is food that is Pre Packed for Direct Sale (PDPS)?
Following the tragic death of Natasha Ednan-Laperouse in 2016 who ate a sandwich made and packed at a Pret a Manger store that contained sesame seeds which she was allergic to; ‘Natasha’s Law’ will be introduced and enforced from 1st October 2021 and will require food Pre-Packed for Direct Sale to be labelled with a full ingredients list with the 14 allergens identified and emphasised to ensure customers are fully aware of what they are actually eating and keep allergy sufferers safe.
Unfortunately at the moment there is no legal definition for Pre Packed food for Direct Sale (PDPS) but the Food Standards Agency describes it as:
‘Foods that have been packed on the same premises from which they are being sold’ (FSA 2019)
This will most probably include sandwiches/meat pies made on site then packaged and sold on the premises where they are made, but this new law could also apply to other foods such as pizza’s and hot bakery items, but at the moment this is unclear and is causing a lot of confusion within catering businesses.
What is loose or non-pre packed food?
Currently any food which is classed as loose or non pre-packed including food packaged at the request of the customer, for example a deli sandwich made in front of the customer, does not require the allergen information to be put on a label on the food, but the allergen information must be provided up front, on a shelf sticker or similar, or if not customers should be signposted to this information.
How can I comply?
The technical guidance for ‘Natasha’s Law’ should be available in December 2019 how businesses can comply; look out for a further update via my Blog or sign up to my newsletters to ensure you don’t miss out on food safety updates and information. https://www.foodsafetylogic.co.uk/contact-us/