Following recent and high-profile allergen related fatalities the government has published new legislation The Food Information (Amendment) (England) Regulations 2019 No 2018.
Prior to this amendment foods and drinks packed on the site from which they are sold – known as ‘pre-packed for direct sale’ (PPDS) – do not have to be labelled with allergen information. It is expected that the consumer can directly ask the staff who have made or packed the products about any allergens that may be present. This lack of allergen information on these types of products has occasionally resulted in allergenic consumers mistakenly believing there to be no allergens present.
The amendment to the Food Information Regulation 2014 (FIR) requires that food and drink ‘pre-packed for direct sale’ will have to be labelled with the product name and a full ingredient listing with allergens emphasised.
In practice this means that loose foods (e.g. unpackaged loaf of bread) and foods packed at the customer’s request (e.g. pot of coleslaw filled as the customer waits for it) are unaffected by these changes and do not require any additional allergen labelling. Foods ‘pre-packed for direct sale’ such as sandwiches and boxed salads pre-made and displayed packaged in a chiller, as well as foods packaged for selling from a market stall run by the same operator, as well as cheese pre-weighed and packed and displayed in a cheese counter will all require labelling with product name and a full ingredient list.
Generating an ingredients list may sound an easy thing to do but it can be complicated, and ensuring that it is always accurate when ingredients themselves can change on a regular basis is a technical challenge even for the big food manufacturers.
The new legislation comes into force in October 2021. This may sound a long way away but if these regs apply to your business you need to be starting to plan your process for this NOW and getting labelling hardware and software sourced and commissioned and your staff trained.
If you would like help with this then give me a call.