What Does Natasha’s Law Mean for My Business?
From October 2021, you must label all foods produced and packed for sale at the same premises with a full list of ingredients. This is coming into force under Natasha’s Law, a new food labelling legislation created after Natasha Ednan-Laperouse had a fatal allergic reaction. Natasha’s family have since campaigned for greater transparency around the labelling requirements, the outcome of which is the upcoming law.
What is Natasha’s Law?
In July 2016, 15-year-old Natasha ate a Pret a Manager artichoke, olive and tapenade baguette bought at Heathrow Airport. Unknown to her, sesame seeds had been baked into the bread. Due to her sesame allergy, Natasha sadly died of anaphylaxis after collapsing onboard a flight shortly afterwards.
This tragedy may have been avoided if clear legislation was already in place, ensuring all food sold to the public is labelled with every ingredient. Instead, Natasha was ‘reassured’ by the lack of any allergen information on the product when she chose it.
Under the UK’s current Food Regulations 2014, you don’t have to individually label freshly made, non pre-packaged food. This meant Pret a Manger didn’t have to list all ingredients on food product labels. Instead, they had signs near displays prompting consumers to raise any allergen queries with staff. However, this will change with the introduction of Natasha’s Law. From October 2021, food pre-packed for direct sale (PPDS) must list all ingredients on food labels of individual products.
Environment Secretary Michael Gove announced the law in a move to protect England’s 2 million food allergy sufferers. When it comes into force, Natasha’s Law will give consumers greater transparency about what they are eating. This is something that will benefit everyone, and, most importantly, help to prevent potentially life-threatening allergic reactions.
How Will Natasha’s Law Affect My Business?
Natasha’s Law will only apply in England – it will not be a legal requirement in the rest of the UK. However, it’s likely that Scotland, Wales and Northern Ireland will follow suit once the impact of the legislation is clear. This does not mean that you can disregard allergens if you run a food business in one of these countries. It is always strongly recommended that you are transparent about allergens and what you are putting into your products. If you rely solely on verbal information, there is always the possibility of this being incorrect or of customers not asking and assuming the food is safe. Having all ingredients clearly listed is just one way that we can provide more reassurance to those with allergies.
Cafés & Delis
Until October 2021, you are not legally required to label ingredients on pre-packed food made on-site. Typically, this applies to cafés and delis, where food is produced at the same premises and usually on the same day. Example products include ready-made salads or sandwiches. Currently, cafés and delis tend to display signs prompting customers to ask a member of staff about allergens. However, if you give wrong information, this could cause a customer to experience a potentially life-threatening allergic reaction.
Under Natasha’s Law, you must list all ingredients on individual packaging of products that are considered pre-packed for direct sale (PPDS). If you sell PPDS food, then you must ensure you have implemented the new regulations by the deadline. You should have plenty of time with the two-year transition period intended for businesses to make the necessary changes.
Restaurants will not be affected by Natasha’s Law and the changes it will bring to the listing of ingredients. However, you must make allergen information available, whether that be via the menu or verbally if the customer asks. This is not without risks, as the recent tragedy of Owen Carey demonstrates.
Before ordering, Owen informed staff at the burger chain Byron about his dairy allergy. Despite this, he was reassured that the grilled chicken he consumed was free from the allergen. However, it emerged that the chicken had in fact been marinated in buttermilk. There had been no mention of any marinade or allergenic ingredient on the menu or by staff. As a result, Owen unfortunately died following a severe anaphylactic reaction. Since the avoidable incident, his family have been campaigning for ‘Owen’s Law’. Similar to Natasha’s Law, they want legislation to be put in place that ensures restaurants label allergens better.
While Natasha’s Law may not specifically affect your business, it’s in your best interests to take allergens into consideration. With a clear industry wide crack down on allergens, being ahead of your competitors will put you at an advantage. Consumers are more likely to trust businesses that pay attention to allergens. By providing clear allergen information for every dish, this prevents the customer having to ask a server about each one.
The pizza chain Franco Manca are a leading example of how to make allergens clear and readily available for customers. Their allergen menu clearly indicates what allergens are in each dish with a picture icon. This feature is available on their online menu too, helping consumers to feel reassured in advance. By providing this, Franco Manca help customers to make an informed choice, and removes the need for them to enquire.
Takeaways come under the same category as restaurants, as they sell ‘non-prepacked (loose) foods’. This means you can give allergen information either in writing or verbally. Likewise, takeaways will not be affected by Natasha’s Law. However, unlike restaurants, takeaway meals are considered to be ‘distance selling’. This means that allergen information must be available to the customer both at the point of purchase and point of delivery. This information must be in a written document that is kept at the takeaway premises, as well as available in written form for the consumer if they request it. To make your takeaway business stand out from your competitors, you could clearly list the allergens in each dish on your menu or have a separate menu doing so.
How Should I Prepare for Natasha’s Law?
You have until Natasha’s Law comes into force in October 2021 to implement all the required changes. This two-year transition period should give you plenty of time to arrange how you are going to label all products with a full ingredients list. It is recommended that you try and do so as soon as possible. If you run a small deli or café you may feel you lack the staff, time or technology to make the changes. To make things simpler, we recommend the following ways of preparing:
Ensure your staff have up to date allergen awareness training and understand the importance of taking allergens seriously.
The consequences of mislabelling food can be as severe as death by anaphylaxis, as was the case for Natasha. Staff must understand why having an awareness of allergens is necessary and what they must do to keep consumers safe. This includes knowing where to find the correct, up-to-date ingredients list of products and to share this information with customers when requested.
Have a system in place for quickly responding to ingredient changes.
As soon as a recipe changes, you need to alter the labelling process to match this. For example, if a soup recipe changes to contain celery, you need to update the ingredients label as soon as the product goes on sale. You should also make it clear that the recipe has changed, such as in writing on the product label. Some customers may have previously checked that celery wasn’t an ingredient and bought the soup, so may not check the ingredients again.
Keep your staff informed.
If you change the ingredients in a product, you must inform staff of this as soon as it happens. This updated information should be stored somewhere that all colleagues have easy access to. If a customer then has a query, they can easily refer to the product information.
Investigate what technology would be suitable for your business.
This is dependent on the size of your business and whether you can access certain technology. One way to prevent mistakes is to link your label printer to an online database of what ingredients every product contains. Then, if an allergen is introduced to a product, you can easily input this data and be reassured that your labels are correct.
Clearly signpost allergen information.
Although you will have to include a list of all ingredients on products, this shouldn’t mean you take down allergen signs. Customers are likely to still have allergen or ingredient queries, and showing you are clued up and willing to discuss them can be incredibly reassuring.
Although Natasha’s Law isn’t enforced until October 2021, it’s recommended that you start making the required changes now. Providing clear ingredient and allergen information shows you are committed to making the experience of eating out as reassuring as possible. By establishing your business as one that understands the risks allergens pose, consumers will trust you and, as a result, your company is bound to flourish.