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Allergen Series (2) Natasha's Law Two Years On

View profile for Rebecca Ironmonger
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The 1st of October 2023 marked two years since Natasha’s Law came into force. This legislation, officially known as the Food Information (Amendment) (England) Regulations 2019, made it mandatory for food which is pre-packed for direct sale to include a full list of ingredients on the label. In 2021, Rebecca Ironmonger of the Food Regulatory Team discussed the introduction of Natasha’s Law and the potential impact on the meat sector. Here, Rebecca takes a look at what the impact has been of the law, two years on from its implementation.

In brief, Natasha’s Law requires all food products which are defined as ‘pre-packed for direct sale’ (“PPDS”) to contain a full ingredient list on the packaging label. PPDS products are food items which have been processed and pre-packaged on the premises they are to be sold. For example, a sandwich shop which makes the sandwiches in the kitchen, wraps them in plastic and places the packaged sandwiches in a fridge or on the counter and where that sandwich will not be further processed before being sold to the customer. Another example would be a butcher making up and packaging a barbeque pack of meat before customers come into the butcher’s shop to purchase it.

In April 2023, the FSA produced a report with the results of a survey they had undertaken into the impact on businesses, local authorities and consumers of Natasha’s Law. The full report can be found here. Some interesting findings of the report are:

  • 42% of consumers surveyed said they saw an improvement in the availability of allergen information on PPDS products
  • 24% of food businesses surveyed reported that they were not fully compliant with all labelling requirements
  • 72% of food businesses surveyed have started to apply precautionary allergen labelling to their PPDS foods and 17% have started to sell their previously PPDS foods as non-prepacked
  • 75% of local authorities surveyed reported that they believed further action is needed to improve compliance including general training
  • 51% of food businesses surveyed reported that their costs had increased due to the PPDS labelling requirements.

We would question whether, in the light of the above, the law as drafted is fit for purpose.  With nearly a quarter of food businesses surveyed admitting that they are not compliant with the law and where the response of 72% of businesses was to apply precautionary allergen labels to prepacked food, it seems to us that there is much to be done by both food businesses and the regulator alike. Common reasons for non-compliance amongst food businesses is likely to be ignorance of the labelling requirements and/or a lack of understanding of the rules as well as the cost of implementing the law. None of these would be a defence in a prosecution by the local authority.

The greatly increased use of precautionary allergen labelling is likely to reduce the amount of choice for allergy sufferers and in turn mean a loss of customers for those businesses. We discussed precautionary allergen labelling and the new guidance in last weeks Allergen blog here.

We would be interested to hear about the impact of implementing Natasha’s Law on your food business. Is your business fully compliant with the PPDS labelling requirements? Is there anything else you think the local authority could be doing to assist you and other businesses with labelling?

Our specialist food regulatory team is able to advise on all aspects of food and allergen law. If you have any queries about your compliance or you have been served with enforcement action, warning letters or even a court summons for breaches of allergen law, please get in touch with our trusted advisors.