Frequently Asked Questions

FAQs – all you need to prepare for the UK Food Information Amendment.

UK Food Labelling Resource FAQs

What is the UK Food Information Amendment about?

The changes will apply from 1 October 2021, to allow food businesses time to prepare for compliance with the new rules. The legislative changes have been introduced in England, Wales and Northern Ireland with similar arrangements expected to follow in Scotland to ensure a consistent UK-wide approach at a similar time.

When will the changes apply / become mandatory?

The changes will apply from 1 October 2021, to allow food businesses time to prepare for compliance with the new rules. The legislative changes have been introduced in England, Northern Ireland and Wales. Similar changes are expected to be introduced in Scotland by Food Standards Scotland to ensure consistency of provision of food information across the UK.

What foods are classified as ‘Prepacked foods for direct sale’ (PPDS)?

‘Prepacked Foods for Direct Sale’ are foods that have been packed on the same premises from which they are being sold. For example, a packaged sandwich or salad made by staff earlier in the day and placed on a shelf for purchase. The new labelling will be required on any food that is prepacked for direct sale. This is food which is packaged at the same place it is offered to customers and is in the packaging before it is ordered or selected.

This can include salads and sandwiches that customers select themselves and pre-wrapped foods kept behind a counter, as well as some products packaged and sold at mobile or temporary outlets.

What information is mandatory on a PPDS label?

According to the new rules, PPDS food will have to clearly display the following information on the packaging: 

  • The name of the food
  • Full ingredients list, with allergenic ingredients emphasised (for example in bold, italics or a different colour)
What are the 14 categories of food allergens that must be declared?

There are 14 allergens that must be declared by law

Cereals containing gluten – wheat (such as spelt and khorasan wheat), rye, barley, oats Note: The cereal name e.g ‘wheat’, must be declared and highlighted, not ‘gluten’

Crustaceans e.g. crabs, prawns, lobsters

Eggs

Fish

Peanuts

Soybeans

Milk

Nuts (almonds, hazelnuts, walnuts, cashews, pecan nuts, brazil nuts, pistachio nuts, macadamia/Queensland nut) Note: The name of the nut, e.g. ‘almond’, must be declared and highlighted, not ‘nuts’

Celery

Mustard

Sesame Seeds

Sulphur Dioxide and sulphites (at concentrations of more than 10mg/kg or 10mg/L in terms of total sulphur dioxide) – used as a preservative

Lupin 

Molluscs e.g. mussels, oysters, squid, snails

Note: there are some derivatives of these allergens which are so highly processed that they are not considered an allergenic risk and so do not need to be highlighted as allergens. View the full list of allergens and exemptions

How do I print PPDS labels?

Ingredient lists including the emphasis of any of the 14 categories of allergens must be printed on the package or on the label in such a way as to ensure clear legibility*. Nutritics is a cloud based platform – printing labels from Nutritics is simple, you can print directly from Nutritics to any printer you have available. If you need a printer, you can contact us for special rates on Brother printers. 

*In characters using a font size where the x-height is equal to or greater than 1,2 mm. In case of packaging or containers the largest surface of which has an area of less than 80 cm2 , the x-height of the font size referred to in paragraph 2 shall be equal to or greater than 0,9 mm

What does the UK Food Information Amendment mean for food businesses?

From 1 October 2021, the way food businesses provide labelling information on Prepacked for Direct Sale (PPDS) food will change. These changes will provide essential information to help people with a food allergy or intolerance to make safe choices when buying PPDS food.

How do I get this information from my supplier in an accurate and timely manner?

Your supplier has a legal obligation to provide you with the exact ingredient composition of any foods you buy from them, this is considered mandatory within the Regulation on provision of food information. This exact compositional information will be listed on the food’s  prepackaging or on a label attached to the packaging, or on the commercial documents referring to the foods where it can be guaranteed that such documents either accompany the food to which they refer or were sent before or at the same time as delivery.

How do I have to deal with substitutes on a daily basis (e.g. different bread supplied that morning has a different ingredient list, which then has to be input into the recipe and onto a label)?

Getting your suppliers in order, organising stock and documenting the various brands used is the only way to deal with a flexible supply chain. As a customer, you have buying power so use it. Only buy products from your approved suppliers list. Take time to meet your sales rep, you probably do this regularly to agree food costs. Next time you meet – define your preferred brands and agree the brands that will be substituted in the event that your preferred brand is not available. A digital food information management platform like Nutritics is designed to help you easily manage the various brands used across your business. With real time right click and ‘replace all’  functionality, you can swap brands across recipes quickly and easily ensuring confidence that the correct information, including ingredient lists with full allergen profile is available for your customers.

How can I ensure accuracy of information?

Ensuring the accuracy of the allergen information in the foods served in your business requires ‘Allergen Management’ to become a function of your business in the same way Food Safety Management is. Implementing allergen management should be integrated with your existing HACCP plan. Everyone in your business has a responsibility to ensure the provision of correct allergen information so make sure adequate training is given to empower staff with the knowledge they need to keep the system operating as expected. Define exact roles and responsibilities and appoint a person who validates the ingredient formulas of every food used in your business on a regular basis. Ask your suppliers to let you know if there is going to be a change to a product and use an electronic food information management system to make managing the information quick and easy.

How do I maintain accurate information across all sites?

It is important that each site implements an allergen management system that is specific to their exact operation. This means each site should have allergen management as a function of their HACCP plan. The daily challenges of supply chain management will differ between sites, so each site must be trained in ensuring the provision of accurate allergen information. Nutritics provides professional training courses with certification to ensure all personnel are enabled to fulfil their responsibilities and provide safe food with accurate information to their customers.

How do I maintain accurate information on a daily basis as new products are listed?

Getting your stock in order for the first time is the biggest challenge. It will take time to document the exact ingredient formulas for all the ingredients used to create each menu item on offer. However, once this is done, with the aid of a digital food information management system like Nutritics, the process of labelling recipes becomes as simple as making the recipe itself! Nutritics is designed to help businesses deal with tricky situations like a last minute change of brand with a different allergen profile at the click of a button. Multiple recipes can be updated in batch or single recipes can be customised. Once the system is updated the information for the label is updated instantly.

How do food businesses account for old stock in their recipe management processes?

Having different versions of the same ingredient on site is one of the most challenging situations from an allergen management perspective and it takes considered planning and preparation to ensure information remains accurate. Nutritics offers tailored consultancy services to talk you through the best ways to deal with these complex challenges. You can contact Nutritics for bespoke advice regarding your situation here.

When and in what format should I receive product specifications?

Mandatory particulars must be presented at every point of the supply chain. These can be declared on the prepackaging or on a label attached to the packaging, or on the commercial documents referring to the foods where it can be guaranteed that such documents either accompany the food to which they refer or were sent before or at the same time as delivery

Do I need to be advised of product changes or substitutions on delivery?

You can request that your supplier advises you of any changes to your agreed fixed order. Once you are happy with the level of service provided from your supplier they should be listed on your HACCP plan as an ‘Approved Supplier’ – if you are not happy with the level of service from your supplier, which should include adequate communications regarding changes to your order and stock substitutions, you should consider changing to a supplier who provides a better service.

What are the requirements around reformulation? Does the supplier / manufacturer HAVE to tell their customer? And if so, how and when?

Exact product compositional information will be listed on the food’s prepackaging or on a label attached to the packaging, or on the commercial documents referring to the foods where it can be guaranteed that such documents either accompany the food to which they refer or were sent before or at the same time as delivery.

How do I push any recipes changes out to all my sites / menus? Will they automatically update?

Using a digital recipe management system like Nutritics makes communication about changes to recipes or menus across multiple sites as easy as clicking a button. Nutritics has a suite of integrated tools to support your business operations.

We don’t hold the information for that item but I have contacted my supplier – are they allowed to say this is our customer buys something directly from them?

Food information must be available at every point in the supply chain. In some complex circumstances food information may not be available from the company who delivers the product, however, this does not absolve that company of their legal obligation to ensure the continuity of the flow of food information. If you are unsure if your supplier is complying with their obligations, you can contact Nutritics for bespoke advice regarding your situation here.

What can I do when my supplier says they don’t have the time or resources to provide the data?

If you can’t get the information you need from the company you are working with, consider changing to a different supplier. If you aren’t sure about what you can and can’t expect, you can contact Nutritics for bespoke advice regarding your situation here.

What can I do when my supplier says they won’t take responsibility?

If you can’t get the information you need from the company you are working with, consider changing to a different supplier. If you aren’t sure about what you can and can’t expect, you can contact Nutritics for bespoke advice regarding your situation here.

We are not willing to share the ingredient list as this is sensitive data. What can I do?

If you can’t get the information you need from the company you are working with, consider changing to a different supplier. If you aren’t sure about what you can and can’t expect, you can contact Nutritics for bespoke advice regarding your situation here.

How does Natasha’s Law affect: Cafes, Restaurants, Caterers, Pubs, Delis, Small businesses, Medium to Large Businesses

From 1 October 2021, the way all food businesses provide allergen labelling information on Prepacked for Direct Sale (PPDS) food will change. The changes will affect any businesses that produces PPDS products. These changes will provide essential information to help people with a food allergy or intolerance to make safe choices when buying PPDS food.

Are fast food and takeaway businesses affected by Natasha’s Law?

Fast food and takeaway businesses could be affected by the changes in the legislation depending on their businesses models and how they operate (for instance, some businesses may produce some foods in advance and package them at busier times).

It effectively comes down to the moment when a customer orders and when food is packaged. Where the food is packaged before the customer has ordered it is considered ‘pre-packed food for direct sale’ (PPDS). If it is packaged after it is ordered, it is considered to be ‘non-prepacked food’, even if the food is then provided in packaging.

The reason for the distinction is that if the food is in packaging before it is ordered, then the customer can’t change it and it requires a label. If the food is packaged after it is ordered then, in theory, the consumer could request that items are removed which would change the contents. Therefore, this is considered to be ‘non-prepacked’ and a label is not required.

Some businesses will produce PPDS and non-prepacked food side by side and in exactly the same way. However, a burger that has been prepared and packaged ready for a customer to order is effectively the same as a sandwich that has been made earlier that day ready for a customer to select it. Both are prepacked foods that can’t be changed and will require a label.

How to deal with a situation when you have multiple locations in England and/or Wales and/or Scotland and/or NI?

The changes being implemented in England, Wales and Northern Ireland under Natasha’s Law will mean that foods that are packed for direct sale will have to carry a full list of ingredients clearly highlighting allergenic components.  This practice is expected to be adopted in Scotland to ensure consistency of provision of  food information across the UK.

I provide catering to primary schools across the UK – does Natasha’s Law apply to me?
To understand if any of the schools you service are implicated by Natasha’s Law, the definition of ‘prepacked for direct sale’ must be considered and any foods provided by your service that meet this definition will now require the mandatory labelling on pack of the name of the food and a full ingredient list highlighting any of the 14 categories of allergens.
‘Prepacked for direct sale’ is currently defined as those foods that have been packed on the same premises as they are being offered. Foods which could fall under this category are sandwiches / pies or cakes that are individually wrapped and sold prepacked from the premises in which they were made.
Before Natasha’s Law, the display of an allergen summary sheet and / or a notice to enquire about allergenic ingredients from a member of staff was sufficient for the provision of allergen information for these items. However, by October 2021, if any of the schools individually wrap any items that can essentially be taken away and consumed at a point in time where access to allergen information is not available, these items will then fall under the new rules.
How will I know what is considered as a PPDS food?

The FSA has developed a handy checker tool:
www.food.gov.uk/allergen-ingredients-food-labelling-decision-tool

What is the difference between prepacked and prepacked for direct sale (PPDS) foods?
Prepacked for direct sale (PPDS) food is packaged at the same place it is offered and before it is ordered or selected by consumers. This includes food that customers select themselves, as well as pre-wrapped items, kept behind a counter. Food sold at mobile or temporary outlets also falls under PPDS foods.
Prepacked food, however, is either offered or sold by a different business to one which packaged it or offered or sold at a different location to where it was packaged. Prepacked food already requires full ingredient and allergen labelling as well as a nutritional information declaration.
When writing “traces” on the packaging of some ingredients, do we have to mention that allergen on the final dish allergen information? Is “traces” considered as an allergen?

The presence of allergens when they are intentionally incorporated in a food is not subject to any threshold (except for the sulphur dioxide and sulphites).

Even traces of allergens must be labelled.

The statement “may contain…X” requires risk assessment. If our supplier states that the product “may contain” an ingredient, do we presume they have therefore done their own RA and, as such, we should simply pass that warning on?

Food businesses may voluntarily use labelling such as ‘produced in a kitchen which uses…’ or ‘may contain…’ or ‘not suitable for…’. These statements are used to communicate the risk of the unintentional presence of an allergen (e.g. milk, egg, peanuts, almonds) in a food product. This is typically due to the allergen entering the product accidentally, or through cross contamination. These statements should only be used after a meaningful risk assessment has been performed and there is considered to be a significant risk to the food allergic, or food intolerant, consumer. These statements should not be used as a substitute for good hygiene and safety practices.

Food Drink Europe (FDE) has produced best practice guidance on voluntary application of precautionary allergen labelling. See link below.

www.fooddrinkeurope.eu/uploads/publications_documents/Guidance_on_Food_Allergen_Management.pdf

Must you always use “may contain”, or can you use a statement like “prepared in an environment where nuts are handled”?

Food businesses may voluntarily use labelling such as ‘produced in a kitchen which uses…’ or ‘may contain…’ or ‘not suitable for…’. These statements are used to communicate the risk of the unintentional presence of an allergen (e.g. milk, egg, peanuts, almonds) in a food product. This is typically due to the allergen entering the product accidentally, or through cross contamination. These statements should only be used after a meaningful risk assessment has been performed and there is considered to be a significant risk to the food allergic, or food intolerant, consumer. These statements should not be used as a substitute for good hygiene and safety practices.

Food Drink Europe (FDE) has produced best practice guidance on voluntary application of precautionary allergen labelling. See link below.

www.fooddrinkeurope.eu/uploads/publications_documents/Guidance_on_Food_Allergen_Management.pdf

How should the risk of cross contamination be communicated/flagged on labelling when it comes to PPDS items? For example – although the product doesn’t contain nuts we use them on our premises – is this a “may contain” approach?

Food businesses may voluntarily use labelling such as ‘produced in a kitchen which uses…’ or ‘may contain…’ or ‘not suitable for…’. These statements are used to communicate the risk of the unintentional presence of an allergen (e.g. milk, egg, peanuts, almonds) in a food product. This is typically due to the allergen entering the product accidentally, or through cross contamination. These statements should only be used after a meaningful risk assessment has been performed and there is considered to be a significant risk to the food allergic, or food intolerant, consumer. These statements should not be used as a substitute for good hygiene and safety practices.

Food Drink Europe (FDE) has produced best practice guidance on voluntary application of precautionary allergen labelling. See link below.

www.fooddrinkeurope.eu/uploads/publications_documents/Guidance_on_Food_Allergen_Management.pdf

What about people having allergic reactions to allergens that are not part of the 14 legally declarable food allergies? e.g. allergy to legumes or alliums. Do these need to be declared?

Food businesses may voluntarily use labelling such as ‘produced in a kitchen which uses…’ or ‘may contain…’ or ‘not suitable for…’. These statements are used to communicate the risk of the unintentional presence of an allergen (e.g. milk, egg, peanuts, almonds) in a food product. This is typically due to the allergen entering the product accidentally, or through cross contamination. These statements should only be used after a meaningful risk assessment has been performed and there is considered to be a significant risk to the food allergic, or food intolerant, consumer. These statements should not be used as a substitute for good hygiene and safety practices.

Food Drink Europe (FDE) has produced best practice guidance on voluntary application of precautionary allergen labelling. See link below.

www.fooddrinkeurope.eu/uploads/publications_documents/Guidance_on_Food_Allergen_Management.pdf

Do you have to list all the ingredients, or can you list just the allergens present? Some labels could be rather bulky if all ingredients must be listed.

If the food is prepacked before it has been ordered by the customer, a full ingredient list is required with allergens emphasised in the text.

It will indeed require the surface area of some labels to be changed or text size might need to be reduced. Please remember that there is a minimum font size requirement so you need to ensure that text isn’t too small.

How complete does the ingredients list need to be?

It needs to list the ingredient sub components in full, including branded items and sub recipes.

PPDS: Must ingredient declaration follow the same rules in reg 1169/2011 as for prepacked labelling? For example, with a sandwich made in store can declaration just state “Ingredients: Bread (Wheat), Turkey, Lettuce, Butter (Milk)” or must a statement like the following be used: “For allergens, including allergens containing gluten, see highlighted ingredients”?

According to the new rules, PPDS food will have to clearly display the following information on the packaging: 

  • Name of the food 
  • Full ingredients list, with allergenic ingredients emphasised (for example in bold, italics or a different colour)

It is not required that a statement be used.

Can the ingredients be listed by means of a QR code?

No. A QR code will not suffice.

As per the new allergen requirements, PPDS foods will need to have a label with a full ingredients list with allergenic ingredients emphasised within it. 

According to the new rules, PPDS food will have to clearly display the following information on the packaging: 

  • name of the food 
  • full ingredients list, with allergenic ingredients emphasised (for example in bold, italics or a different colour)
Do we need to put E numbers and preservatives on labels?

The new allergen rules for PPDS foods do not require that nutrient information is shared on the label.

Do we need to include calcium, iron, thiamine etc? Or, for example, can we just say “FLOUR”?

The new allergen rules for PPDS foods do not require that nutrient information is shared on the label.

Deli Counter: If a sandwich was on display (not packaged) and the customer asked for it toasted and then packaged for takeaway, does this sandwich then have to be labelled?

If the food is pre packed before it has been ordered by the customer, a full ingredient list is required with allergens emphasised in the text.

In the scenario mentioned in the question, the food is not prepacked before the order. It therefore does not need to be labelled.

On hot counters and buffets, do we need to state full ingredients and allergens?

If the food is pre packed before it has been ordered by the customer, a full ingredient list is required with allergens emphasised in the text.

Deli Counter: What if you have an unpacked sandwich on sale but then, once it’s sold, you package the item for the customer. Does this then require a label?

Allergen information for non-prepacked food can be communicated through a variety of means to suit the format of the food business. You are required to provide information about the use of the 14 allergens if they are present in a food. You are not required to provide a full ingredients list.

If the food is pre packed before it has been ordered by the customer, a full ingredient list is required with allergens emphasised in the text.

For cakes ordered online (for post) do we have to declare the ingredients or can we just list the allergens?

All food products sold through distance selling (such as over the internet or by telephone) already require allergen information to be provided before food is ordered and when it is delivered. This will not be affected by the new regulations.

Can you clarify the requirements for a pizza delivery chain? Do we have to provide allergen information at Point of Sale and Point of Delivery? Do we also have to provide the ingredient dec at the same time?

All food products sold through distance selling (such as over the internet or by telephone) already require allergen information to be provided before food is ordered and when it is delivered. This will not be affected by the new regulations.

For home bakers, who have the cake collected by the purchaser and may not be packaged by the baker, but by the purchaser, (if at all). Is the ingredient declaration and associated allergen labelling required?

All food products sold through distance selling (such as over the internet or by telephone) already require allergen information to be provided before food is ordered and when it is delivered. This will not be affected by the new regulations.

We are a school, the food is plated at the demand, so do we have to list all ingredients (as we already do for the 14 allergens) ?

If you are plating freshly cooked food (not prepacked before the point that it is ordered), there is no need to list the ingredient list in full. A reference to the presence of the 14 EU allergens is all that is needed.

Can you clarify if labelling is needed for primary school packed lunches that are produced on the premises and taken away on field trips/excursions?

‘Prepacked for direct sale’ is currently defined as those foods that have been packed on the same premises as they are being sold. Foods which could fall under this category are sandwiches/pies or cakes that are individually wrapped and sold prepackaged from the premises in which they were made.

Before Natasha’s law the display of an allergen summary sheet and/or a notice to enquire about allergenic ingredients from a member of staff was sufficient for the provision of allergen information for these items. However, by October 2021, if any of the schools individually wrap any items that can essentially be taken away and consumed at a point in time, where access to allergen information is not available, these items will then fall under the new rules.

In a school setting, can you please clarify if labelling needs to be included on salad bars and site serving meals or on packaging?

If you are plating freshly cooked food (not prepacked before the point that it is ordered) there is no need to list the ingredient list in full.

A reference to the presence of the 14 EU allergens is all that is needed.

At our school, we have a deli bar where students can purchase a freshly filled baguette. But we then put the baguette into a package. Do we need to add a label to this?

If you are plating freshly cooked food (not prepacked before the point that it is ordered) there is no need to list the ingredient list in full. 

A reference to the presence of the 14 EU allergens is all that is needed.

If a parent orders a child’s lunch (sandwich) online using an online payment portal, would the distance selling rules apply?

All food products sold through distance selling (such as over the internet or by telephone) already require allergen information to be provided before food is ordered and when it is delivered.

This will not be affected by the new regulations.

Is there any guidance on implementing Natasha’s Law in a large, acute hospital?

It’s the same requirement, usually handled by the catering team or food safety officer. 

We will be publishing specific guidance for each industry on the Natasha’s Law website. Nutritics also have a food labelling and hospital meal ordering system which would be worth checking out. 

Visit Nutritics website by clicking on this link.

Can you recommend any label printing systems/software?

Nutritics offers a complete labelling solution including recipe development, label creation, printing solutions, and supplier management in one integrated system. 

Learn more about Nutritics for Natasha’s Law here.

How do allergens get listed in the supply chain for ingredients from overseas. Such as those not listed or declared in the US, but the ingredient is then used in a finished product in the UK?

Mandatory particulars must be presented at every point of the supply chain. These can be declared on the packaging or on a label attached to the packaging.

They can also be added to the commercial documents referring to the foods in question. This is only applicable when it is guaranteed that such documents will either accompany the food they refer to or were sent before/at the same time as delivery.

What is the minimum font size required on a label?

Ingredient lists including the emphasis of any of the 14 categories of allergens must be printed on the package or on the label in such a way as to ensure clear legibility.

  • In characters using a font size where the x-height is equal to or greater than 1.2 mm. 
  • In case of packaging or containers, the largest surface of which has an area of less than 80 cm2 , the x-height of the font size referred to in paragraph 2 shall be equal to or greater than 0.9 mm.
Which body will monitor and enforce this law?

EHOs will be adding to their inspection list and issue enforcement/change orders, and escalate as required.

If your question was not covered in the FAQ’s please email us and we will find an answer as soon as possible.

Please enter your email, so we can follow up with you.

Useful Links

FSA Business Guidance Packaging and Labelling

FSA Marks a Year Until Allergen Changes are Introduced – Wales and Northern Ireland Join

Legislative Amendment

Natasha’s Legacy Becomes Law

Allergen Guidance for Food Business

FSA Allergen Packaged for Direct Sale

Organisation

UK Food Labelling Resource
United Kingdom  

Connect

ABOUT

UK Food Labelling Resource is a non-profit initiative aimed at increasing the level of awareness about food labelling in the UK in advance of legislative changes.

Affiliation

This initiative is not affiliated or associated with NARF, the Natasha Allergy Research Foundation.

Contact

T: 0203 769 2226

Privacy Policy
Privacy Settings
We use cookies to enhance your experience while using our website. If you are using our Services via a browser you can restrict, block or remove cookies through your web browser settings. We also use content and scripts from third parties that may use tracking technologies. You can selectively provide your consent below to allow such third party embeds. For complete information about the cookies we use, data we collect and how we process them, please check our Privacy Policy
Youtube
Consent to display content from Youtube
Vimeo
Consent to display content from Vimeo
Google Maps
Consent to display content from Google