UKHospitality: Labelling law

Kate Nicholls, chief executive of UKHospitality, says it’s vital that the sector implements Natasha’s Law correctly and acts in a responsible manner...

The introduction of Natasha’s Law on 1st October saw an extremely complex piece of legislation come into force that will have significant ramifications on the hospitality, contract catering and wider out of home sectors. After the issues faced across the course of the pandemic, not to mention the ongoing labour shortages and supply chain issues, this legislation possibly couldn’t have come at a more challenging time.

UKHospitality has been working closely with government and the Food Standards Agency (FSA) to ensure we have a full understanding and grasp of what is required of operators and then communicating these requirements to the wider sector. The changes brought about by Natasha’s Law have come with significant media attention, so it’s vital that we as a sector get this right and act in a responsible manner.

The new law requires all food that is pre-packaged for direct sale (PPDS) to have allergen information on the label, including items such as sandwiches, salads, soups and many more. Importantly, this will include all settings for those in contract catering, whether that be a care home, school or event venue.

For contract caterers, it’s also vital to note important distinctions when it comes to non and PPDS foods. For instance, when serving food at a buffet, a platter of sandwiches that is covered in clingfilm would not be considered PPDS as it depends on when it is packed for sale. If the food provided at the buffet was packed before it was ordered by the consumer then it will require full allergen information. For example, individually packaged sandwiches would be regarded as PPDS but not one large platter of sandwiches intended for different consumers choosing from a buffet.  

It’s also important that operators and contract caterers continue to communicate with customers regarding allergens. Throughout the consultation process and ahead of the introduction of this legislation, we have consistently raised concerns that labelling shouldn’t now be seen as being the only method of communicating vital allergen information. We feel strongly that businesses must continue to have clear and open lines of communication, to help educate consumers and raise awareness, as even with clear labelling confusion will likely arise. Therefore, we strongly advise that staff remain on hand to clearly communicate this information verbally to help ensure customers can make an informed choice.

Delving into the detail of any legislation such as this can be tricky, so please do make sure you check the FSA website and access all the information available. We are encouraged that the FSA has indicated that enforcement will be proportionate and not heavy handed, in particular over the first few months of implementation, as it’s crucial through the course of any change in regulation that businesses and authorities continue to maintain positive partnership working. At UKHospitality, we will continue to liaise with the FSA and government on the broader food safety agenda and to ensure that business’ voice continues to be heard.

The vast majority of operators remain in survival mode and will be for the foreseeable future. With new rules on calorie labelling rules due to come into force in April 2022, there is a real risk that this puts the brakes on our recovery. We are therefore urging the government to consider delaying the implementation of the calorie labelling legislation for a further six months, rather than layering on new costs for businesses.

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