Food Safety
Written by Joanne Hughes, Policy & Compliance SpecialistLast reviewed Published

UK legislation is changing when it comes to selling pre-packaged foods which are prepared and sold within a single establishment or premises.

In 2019 the Government revealed plans which will protect consumers with allergies by tightly regulating the labelling of allergens.The new laws and the specifics are yet to be launched, however what we do know is that each item that is packaged and placed out for sale to consumers must be labelled with a full list of ingredients.

Furthermore, each allergen must be clearly indicated in bold.

Why is this important for businesses? Protecting the health of consumers and practicing within the Law will protect your business from litigious actions and protect your business integrity.

The process of labelling however need not be a daunting task! At Policy Pro’s we have registered clinical and nutritional staff who will provide you with policies, procedures and training manuals to guide you through every step.

In addition, we can offer comprehensive training and reference guides on allergies and intolerance’s and what to do in the event of a medical emergency if someone suffers a serious reaction to an allergen.

For more information, please either email, call or complete an enquiry form for a quote.

Why Allergen Policy Matters

Food allergen labelling has been one of the fastest-evolving areas of UK food law since 2014.

The Food Information for Consumers Regulation (EU FIC, retained in UK law) requires the 14 named allergens to be emphasised in the ingredients list and provided for non-prepacked food on request.

Natasha's Law, in force since 1 October 2021, extended full ingredient and allergen labelling to food prepacked for direct sale (PPDS).

The Food Standards Agency continues to consult on further reforms, particularly on non-prepacked food in restaurants, takeaways and delivery, and on the standardisation of "may contain" precautionary statements.

The 14 Named Allergens

  • Cereals containing gluten (wheat, rye, barley, oats and their hybridised strains).
  • Crustaceans, molluscs and fish.
  • Eggs and milk (including lactose).
  • Peanuts, soybeans, lupin and other tree nuts (almond, hazelnut, walnut, cashew, pecan, brazil, pistachio, macadamia).
  • Celery, mustard, sesame seeds, sulphur dioxide and sulphites (above 10 mg/kg or 10 mg/litre).

What an Allergen Policy Should Cover

  • Identification of the 14 allergens across raw materials, recipes, and finished products.
  • Cross-contamination controls in storage, preparation and service.
  • PPDS labelling procedure (full ingredient declaration with allergens emphasised).
  • Verbal information procedure for non-prepacked food.
  • Supplier specification and change-management process.
  • Staff training records aligned to FSA guidance.
  • Incident response for suspected allergic reactions, including 999 protocol.

Frequently Asked Questions

Does Natasha's Law apply to my business?

Yes if you make food on the same site you sell it from and the customer can buy it directly without further processing. This includes sandwich bars, bakeries, cafes packing food in advance, and many event caterers.

It does not apply to food made to order or to food sold loose without packaging.

Are "may contain" statements legally required?

No. They are voluntary precautionary statements. The FSA expects them to be used only where a real cross-contamination risk has been identified through risk assessment, not as a blanket disclaimer.

What are the consequences of getting it wrong?

Local-authority enforcement, product recall, civil liability for personal injury, and prosecution under the Food Safety Act 1990 (with unlimited fines) and the General Food Regulations 2004.

Coroner's reports following fatal allergic reactions have repeatedly cited inadequate labelling and training.

What Policy Pros Delivers

Our Allergen Management Policy package includes the main policy, a 14-allergen recipe matrix template, a PPDS labelling procedure, a non-prepacked verbal information script, a supplier specification template, a staff training pack, and a serious-incident response procedure.

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