On June 18th 2020, the Food Standards Agency published its latest technical guidance on allergen labelling for prepacked for direct sale products (PPDS) - It updated the Food Information Regulations 2014 to implement Natasha's Law in England.
What is prepacked for direct sale (PPDS) food?
Food that is packed before being offered for sale by the same food business to the final consumer:
i) on the same premises; or
ii) on the same site
iii) on other premises, if the food is offered for sale from a moveable and/or temporary premises (such as marquees, market stalls, mobile sales vehicles) if the food is offered for sale by the same food business who packed it.
Prepacked for direct sale (PPDS) food does not include food packed at a consumer’s request, food not in packaging, or food in packaging that can be altered without opening or changing the packaging.
What is the plan?
PPDS products will need to have labels with ingredient lists and with the allergens emphasised, to try and reduce consumer confusion at the point of purchase.
The new legislation states Natasha's Law will come into effect on the 1st of October 2021 and will only apply for prepacked for direct sale products.
The time frame allows businesses to implement this and prepare for the standard that needs to be achieved.
Natasha’s Law ensures that food businesses of all sizes will have to make changes to their products and practices if they sell PPDS products.
What types of food are covered?
Prepacked for direct sale (PPDS) food includes:
• Sandwiches placed into packaging by the food business and sold from the same premises.
• A café giving away packaged samples of a new range of cakes they have made on the same premises.
• Foods packaged and then taken by the same operator to their market stall to sell.
• A butcher who makes burgers or sausages which are prepacked to be sold on the same premises.
• Foods packed by a food business to be sold in its retail units located within the same building complex as the premises where the food was packed such as a train station, hospital, university, or holiday park.
In a retail environment such as a supermarket, the following examples would also be considered to be prepacked for direct sale food, provided they are packed on the premises from which they are being sold before they are offered for sale:
•Fresh pizzas from the deli counter e.g. on a cardboard tray and wrapped in plastic;
•Hot foods such as rotisserie chicken; and
•Foods that are pre-weighed and packed such as cheese or meats from a delicatessen counter or baked goods from an in-store bakery
What will be the challenges?
· Getting ingredients information from suppliers
· Combining that information to produce an accurate ingredients list
· Presenting information clearly to consumers
Consequences of the new regulations
· Many in the industry are concerned about the ability of SMEs to invest in systems to manage their ingredient information and label appropriately, particularly after the challenges of the lockdown, which has stripped them of money to invest, resources and time.
· Small businesses will have the challenge to manage and present a lot of information about their food ingredients whereas before they could focus entirely on allergens.
Types of labels
Handwritten labels are likely to encounter a high amount of human error & potential big mistakes. Are you willing to take that risk?
Pre-printed labels are not scalable, they are not practical. What if the product your order from your supplier is different one day? The ingredients will be different, and this could harm consumers if your company did not list food information correctly.
Therefore, printing food labels in real-time is more practical. Having an electronic solution will enable you to print straight away and easily make any changes. The labels will look more professional and also future proof. So, who can help with this? NT can.
What are the label requirements?
· Is sufficiently visible
· Readable for those with visual impairments
· A minimum font sizes (please see link to FSA for further information)
It is likely that branding, barcodes, and expiry dates will need to be included on the label.
Any business that fails to comply with these rules will be hit with a maximum fine of £5000 per offence.
NT Assure can help you get your business’s allergen labelling solution in place NOW. We work alongside our partner Brother to offer an in-house printing solution.
NT Assure has a team of technical and regulatory technologists on hand to provide professional food specification writing, pack copy, and label compliance services. Call us on 01933 272089.
Now, more than ever, communicating accurate information about food is an essential pre-requisite for food businesses, ensuring food safety, provenance and legal compliance is achieved.
Our out of the box solution will allow you to manage your food information on a tablet or another device, and when you’ve entered your product information, you can print – all ready for the product to go on sale. This solution works for firms that have a singular product or several hundred.
This is a cost-effective labelling solution for businesses who want to protect their customers and brand, with Natasha's Law coming into effect October 2021, get ahead & get started now.