Natasha’s Law: how to comply with the new rules

Food companies will have to follow stricter food labelling rules when Natasha’s Law will come into effect in October in England, Wales and Northern Ireland. The law states that all food that is pre-packed for direct sale (PPDS) must display a label with a full ingredient list including the 14 allergens. Allergens include milk, fish, tree nuts, crustaceans, cereals containing gluten, eggs, peanuts, celery, soybean, lupin, molluscs, mustard, sesame, sulphur dioxide and sulphites.

The new legislation aims at protecting those suffering with food allergies, by preventing food-related illnesses and even death.
The law is named after 15-year-old Natasha Ednan-Laperouse who, in July 2016, suffered a fatal allergic reaction after eating a Pret A Manger baguette. The teenager was unaware the sandwich she bought at Heathrow Airport contained sesame seeds, to which she was allergic to, because the ingredient wasn’t listed on the baguette label. Natasha later went into anaphylactic shock and died.

Nutrition and food information management software company Nutritics, who with Manchester Metropolitan University, EuroFir and Quadram Institute, are the founders of the UK Food Labelling Resource, have put together a month-by-month checklist to help food companies adhere to the new rules.

“Between now and October, we’d suggest food operators break down what they need to look at and take a different focus each month.” says Stephen Nolan, Nutritics ManagingDirector. “By starting now, there is enough time to identify any changes that need to be made without danger of missing the 1st October 2021 deadline.”

April: Focus on Suppliers and Stock
The first indication of how long it will take you to get ready for Natasha’s Law is to look at how many different suppliers you may have. Make a list of all the suppliers you use and audit all of your ingredients and products being delivered to you.

● What information do you receive from your suppliers and what format is it currently in?

● Can you ensure this information is accurately retained and transferred to labels?

● How are changes to ingredients being managed? Make sure any global suppliers are fully aware of the 14 allergens and the need to have each ingredient clearly labelled. As part of this process, consider seasonal recipes such as Christmas sandwiches or seasonal baked goods and any additional suppliers that might be involved in providing seasonal ingredients.

May: Focus on Software & Hardware
 Software and hardware developed specifically for the field of food labelling to improve, automate and make time-consuming analysis more efficient and less susceptible to accidental human error, is invaluable.

● Is the system you have in place suitable for complying with Natasha’s Law and minimising the risks of inaccuracies or human error?

● Does it capture supplier information or do you have to input this manually?

● If there is a change to an ingredient, does it automatically update or do you have to go through each stage of the recipe management process and manually make a change?

● If you have a printer, is it suitable for the volume of labels you will now need for PPDS products and is it freezer and heatproof to account for how your products might be stored or cooked?

June: Focus on Staff Education & Training
Staff training and education should be ongoing but use this month to step back and take an overall look at integrating allergen awareness training across your food production process. Appoint an allergen champion that has a deeper understanding and can provide more detailed information to consumers and additional training to staff. Ensure all staff are fully aware of Natasha’s Law, whether they are involved in ordering ingredients, managing software, producing PPDS food or selling to consumers. For allergen management to be fully successful, it needs to be the responsibility of all members of your team.

July: Trial Run
Make sure to organise a trial run of your setup once you have trained your staff, added your supplier information recipes and created labels in your chosen software system. Decide on one location and stress test all essential aspects of your supply chain for compliance with Natasha’s Law.

August and September: Review, Refinement and Readiness
Use these two months prior to the regulations being enforced to make sure the process is as smooth and risk-free in your business as it can be. Review all suppliers and add on any new information. Check the deliveries you receive and identify how best to manage substitutions and changes and check the label generation process.

● Are the fonts correct, is the information clear and legible to consumers?

● Are your staff clear on why these changes are being introduced and what to do if consumers ask questions regarding Natasha’s Law and PPDS?
Stephen Nolan adds, “Over the last three months we have participated in education webinars with over 2,000 businesses planning for Natasha’s Law. Our advice to all food operators is to access the excellent resources and education supports available through the Food Standards Agency and sites like the one we support as part of the UK Food Labelling Resource Initiative at Natasha’s Law. Then look at the solutions available in the market that will reduce the risks of inaccurate ingredient and allergen information appearing on labels. Automating as much of this process will lead to reduced risk of errors as well as saving time and money.”

Natasha’s Law comes into effect in England, Wales and Northern Ireland on 1 October 2021.