Natasha’s Law Explained: PPDS Food Labelling
Natasha’s Law will come into effect on 1st October this year. This new law obliges all food businesses to label a full list of ingredients and highlighted allergens, on any food product that has been ‘pre-packed for direct sale’ - or PPDS.
The new law seeks to protect the two million allergen sufferers in the UK, providing them with the confidence that they will be safe from the food that they purchase. We ask, what implications this new law will have on the healthcare sector and how staff make sure they are complying with the it…
Food businesses are defined in Article 3(2) of Regulation 178/2002 (General Food Law) as “…any undertaking, whether for profit or not and whether public or private, carrying out any of the activities related to any stage of production, processing and distribution of food.” As such, Care Homes, nursing homes, hospitals and general healthcare catering which sell or supply PPDS food will need to comply with the new regulations, including where such food is supplied as part of the provision of another service.
What is Natasha’s Law?
Natasha’s Law is named after Natasha Ednan-Laperouse who at the age of 15 passed away due to a severe allergic reaction. Natasha had a serious sesame allergy and was not aware that sesame seeds had been baked into the bread of a sandwich she had bought. The fact that the packaging did not display any allergen information reassured Natasha that the food was safe for her to eat.
Following this tragic accident Natasha’s family campaigned for increased transparency of UK food labelling, as a result, Natasha’s Law comes into force later this year.
What is Pre-packed for Direct Sale food?
PPDS food is any food which is packaged at the same place it is sold to customers and is already packaged before it is selected by the customer. Any places that produces PPDS food will be required to label it with the name of the food and a full ingredients list, with any allergens emphasised within the list. It can include food that customers pick out themselves as well as products kept behind a counter and some food sold at mobile or temporary outlets.
What does not qualify as a PPDS Food Product?
Basically, any food that is packaged after being ordered by the customer does not need PPDS labelling. There is no requirement to have a label with name, ingredients and allergens emphasised. Allergen information must still be supplied but this can be done through other means, for example on the menu, on a notice stating customers can ask staff for allergy information or through a member of staff telling the customer.
This means that foods made to order, takeaways, or deliveries must continue to provide allergen information to customers for dishes, at the point of order and at the point of delivery, as they have done for the last seven years. However, where food has been prepared and packaged ready for a customer to order, e.g. a burgers made and packaged before a busy time in the day, this becomes pre-packed for direct sale and will require a label.
Any food packed by one business and supplied to another business is classed as prepacked food and already must have full labelling. These food products will already include the name of the food and a full ingredients list, with allergenic ingredients emphasised within it, along with other mandatory labelling such as nutritional information.
What needs to be listed on PPDS labelling?
Firstly, the labelling that is required from October 2021 consists of the name of the food item and a full ingredients list that must be supplied in descending weight order of ingredients (largest contained ingredient first).
PPDS items are further required to be labelled with the name of the item, a declaration of the ingredients and whether items have been irradiated or contain genetically modified materials. Where the item is a meat product e.g., a sausage roll, it must also have a meat content declaration.
The label must also make clear any allergens contained within the item, this may be using bold text for allergens,
e.g. for a Bakewell tart:
Wheat Flour (Wheat Flour, Calcium Carbonate, Iron, Niacin, Thiamin), Sugar, Palm Oil, Plum And Raspberry Jam (8%), Water, Glucose Syrup, Rapeseed Oil, Glacé Cherry Half (4%), Invert Sugar Syrup, Humectant (Glycerol), Pasteurised Egg, Pasteurised Egg White, Emulsifiers (Mono- and Di-Glycerides of Fatty Acids, Sucrose Esters of Fatty Acids), Flavouring (Almonds), Raising Agents (Disodium Diphosphate, Sodium Bicarbonate), Rice Starch, Cornflour, Acidity Regulator (Citric Acid).
Plum And Raspberry Jam contains: Glucose Syrup, Plum Concentrate, Sugar, Water, Raspberry Concentrate, Colour (Anthocyanins), Gelling Agent (Pectin), Acidity Regulators (Citric Acid, Sodium Citrate), Flavouring.
Glacé Cherry Half contains: Cherry, Glucose-Fructose Syrup, Fruit And Vegetable Concentrates (Apple, Blackcurrant, Radish), Acidity Regulator (Citric Acid), Preservative (Sulphur Dioxide).
What are the allergens?
It is essential that the presence of the following allergens is specifically highlighted on any PPDS labelling:
- Cereals containing gluten (oats and barley)
- Crustaceans (crabs, lobster, prawns)
- Molluscs (oysters and mussels)
- Sulphur dioxide and sulphites (for concentrations above ten parts per million)
- Tree nuts (almonds, walnuts, brazil nuts, hazelnuts, pecans, cashews, macadamias, and pistachios)
Preparing for Natasha’s Law
- Identify your PPDS products.
- Engage with suppliers and build good relationships. Your supplier has a legal obligation to provide you with the exact ingredient composition of any foods you buy.
- Appoint an Allergy Champion within your business
- Keep recipes simple to minimise allergenic ingredients wherever possible.
- Source a labelling system.
- Train your staff. Training should be completed and tested regularly to ensure team competency and confidence in dealing with allergens and customer requests.
Natasha’s Law will save countless lives and, by preparing now for its implementation, you can stay ahead of the curve and best protect your people.