Natasha’s Law Guidance – Our Best Practice – Allergen Labelling
In October 2021, the law changed to extend the display and communication of allergen information in foods to include all foods that are pre-packed before the point of sale AND includes:
- Foods packaged before selecting and ordering:
- Foods sold online from a website or menu
- Foods sold from a mobile food outlet/van
- Foods sold from a market stall
- Foods sold from different units in the same building i.e. shopping centres, airports, hospitals etc.
This applies to foods that are either entirely or partially enclosed where the food product is ready for final sale to the consumer, and where the packaging cannot be altered without either opening or replacing it.
Loose items which are packaged after ordering are not included.
Although this legislation does not extend to drinks and does permit the communication to be verbal via telephone or delivery driver, NutriCalc does not recommend verbal communications as this does not cover either the seller or consumer in the event that anything should be later attributed to the consumption of the food product.
Our recommendation would always be to ensure that:
- All staff have training and awareness of, and easy access to allergen information for all food and drink products
- Allergen information is clearly displayed on packaging, menus, and shelving where appropriate
- Recipes are thoroughly checked to ensure that allergen information is entered for every ingredient
- Allergen information stands out in the ingredient declaration/list
- Where ingredients/products are bought in, a check is carried out to ensure that the ingredient list matches the allergen expectation and declaration. e. if flour is present, wheat and gluten are listed and highlighted
- Drink products could also have allergens labelled and/or clearly displayed/communicated to ensure that any potential reaction cannot be attributed to the food product purchased at the same time later
- Possible cross-contamination is also declared
The term ‘may contain’ should be used where there is the possibility of cross-contamination but we feel is not helpful when over utilised. To use this term for a vegan product stating ‘may contain milk’ is unacceptable and deliberately misleading to the consumer.
If a product states that it is suitable for vegans, vegetarians etc. it should not contain anything that defines it as otherwise.
Please also be aware that when labelling food and drink products for sale outside of the UK or EU, or being imported into the UK or EU, the allergen labelling requirements may be different from your home country.