Natasha’s Law, which came into effect on 1 October 2021, was the result of a campaign to ensure all pre-packed for direct sale goods had labels on them to help customers understand what allergens were in the product.
The full extent of the law – ‘The Food Information (Amendment) (England) Regulations 2019 (SI 2019 No. 1218)’ was much more intense following the open consultation and around March 2019 the Food Standards Agency published a consultation guide for caterers, the public and any other interested bodies to state their position on the four choices being offered.
The four choices had been tabled previously following input from many people and organisations and the fourth choice was selected which not only desired allergens being labelled but a full ingredients list was to be mandated for sandwiches and any food and drink fully or partially packaged before being sold. And interestingly there were 1620 contributors of which only 126 food related organisations (Allergen Accreditation included) took part.
What was of greatest significance was the vast number of contributors who expressed a need for other ingredient information to be made available as there are many people intolerant and allergic to more than just the top 14 allergens.
Prior to Natasha’s Law the industry best practice standard was to label all PPDS with an allergen label, but that was not widely adhered to.
In August 2023, the Food Standards Agency released its updated technical guidance on allergens in food service. This reflects the more recent consultation on PAL (Precautionary Allergen Labelling). And also deals with the use of the term NGCI (No Gluten Containing Ingredients) a term which has never been popular with best practice practitioners who profess the best terminology is always Gluten Free when referencing a product that is less than 20 parts per million of gluten. Remembering that a gluten free product that does contain barley and oats must be noted as containing these allergens (Gluten free or not!).
The Owen’s Law campaign started in 2021 and in May of 2023 was debated in parliament and there are several key developments the campaign wishes to see in food service but the main thrust of Owen’s Law, however, is to mandate that all menus have allergens noted on them for easy access to customers when they are selecting their foods.
But, like Natasha’s Law, these do take time to develop and implement, although part of the accreditation process in Ireland is that ALL allergens are noted on the menu, and this has been the case since 2014.
Overall consumer confidence is much better off with allergen regulations and eating out for food hypersensitive customers has improved. Up until February 2020 the UK and Irish food service industry was at its absolute best in every respect.
Since March 2020, however, training and maintaining qualified personnel and consistent produce from suppliers has been seriously impacted and this has resulted a decline in some operating standards when it comes to allergen management. Less so in the public sector and professional food service organisations as caterers there tend to have more resources for quality assurance. These however have been stretched to the limit.
The next stage for allergen management is to refresh, train and develop as the market for hypersensitive customers is still growing. Cautiously, Trading Standards and local Environmental Health Officers will have far less tolerance for rules being broken that have been in place for almost 10 years!
Julian Edwards FIH, FCSI, CFSP. CEO: Allergen Accreditation