Corporate Group Instinctif Partners

September 29, 2021

Natasha’s Law comes into force; reputation factors to consider

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Natasha’s Law comes into force; reputation factors to consider

  • Staff training is key to ensuring compliance with the law
  • Businesses must assess their product offering to understand how food hypersensitive consumers might interpret application of the law
  • Risk communication with consumers on an industry and individual level is important

“Natasha’s Law”, which regulates labelling of foods pre-packed for direct sale (PPDS), comes into effect on 1st October. It will affect all food businesses, such as cafés, that package food products on the same premises where they are sold to consumers.

Officially called the UK Food Information Amendment, the regulation has become known as Natasha’s Law after teenager Natasha Ednan-Laperouse, who died from an anaphylactic reaction to an allergen in a sandwich. Her parents campaigned for a change in the law to require allergens to be labelled on such foods. From October, food businesses packaging products on the premises (e.g. by wrapping, bagging or otherwise enclosing a product) must label their products with the full list of ingredients, and highlight any allergens, in the same way that food manufacturers supplying retailers already do.

Food businesses have been working for months to ensure they are ready for the change of law, but the next weeks and months will prove the extent to which the law is being properly implemented by the industry – and, crucially, understood by people living with food hypersensitivity (allergy, intolerance and coeliac disease).

Although the new legislation has been created for all the right reasons – to prevent further serious illness or loss of life – inevitably allergic consumers will need to remain vigilant to ensure they understand which products are and are not covered, and how this might vary between establishments. For example, a business selling products which are packed to order at the point of sale, such as a fish and chip shop, is not required to label its products. However, if the fish and chip shop team prepares for the dinner-time rush by putting some fish and chips into boxes and leaving them under the heater, then these products become pre-packed and do need to carry labelling.

Training of staff – both initially and on an ongoing basis – will be key to ensuring compliance with the law. Food safety culture plays an important role too. And communication is key; there is a case for risk communications materials to be developed to inform consumers as to what labelling to look for, and where they will find it – and not find it.

For businesses with a mixture of pre-packed and loose products, over-compliance should be considered, to ensure that allergic consumers are kept fully informed of ingredients. However, consider also that a similar business next door might not be labelling loose products; in which case does the blend of approaches serve only to confuse consumers? And, of course, cost and competition will be additional factors working against the kind of consistent clarity that people with food hypersensitivity may have hoped would arise from the new law coming into force.

The whole weight of implementation doesn’t fall upon food businesses’ shoulders, of course. Industry associations, training bodies and the Food Standards Agency will all provide advice on the precise requirements of the law and its application, and will remain valuable sources of information and advice. In addition, global standards organisation GS1 UK is helping businesses guarantee increased visibility and accurate traceability of food product supply chains through implementation of its unique barcode identification keys. These barcodes ensure the safe tracking of individual items and ingredients, starting from their provenance and monitoring every stage of their development until they reach end consumers.

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