The UK Food Information Amendment 2019 came into place in October 2021 in England, Scotland, Wales and Northern Ireland to all businesses selling Prepacked for Direct Sale Foods (PPDS Foods). After determining whether or not your business fits this criteria, (need help deciding? This article about food allergen labelling outlines the PPDS classification) you’ll need to look closely at four key areas — Suppliers, Stock, Training and Implementation — to comply with the regulations. Allergen management should be treated just like any other risk management process in your business. That means a full review of all processes, risk assessment and mitigation and training for all employees to ensure they understand the risks posed by allergens.
To make your job a little easier, we’ve outlined below the six main risks encountered by food businesses in complying with Natasha’s Law, and their associated solutions.
1. Risk: Ingredients and allergens are not included or not broken down correctly by a supplier, e.g. you see that a prepared sauce doesn’t have a full breakdown.
- Solution: Work with your suppliers to make sure they understand the full ingredient and allergen information they are required to provide you with under law. Ensure any suppliers located outside the UK & EU are aware of the 14 UK & EU allergens as those listed in their country may be different.
- How Nutritics can help: Nutritics works with you to add your suppliers to the database. Nutritics already has over 10,000 UK suppliers in their database, meaning information is available to your recipe management and label generation process at a touch of a button.
2. Risk: Ingredients are not correctly entered into your recipe management system by an employee.
- Solution: Ensure staff are fully trained on their responsibilities and why ingredient accuracy is so important. Allow appropriate time for ingredients to be updated on your recipe management system. Integrate allergen management with your existing HACCP plan. All staff should be fully aware of Natasha’s Law, whether they are involved in ordering ingredients, managing software, producing PPDS food or selling to consumers. Define exact roles and responsibilities; appoint an allergen champion who can provide more detailed information to consumers and train staff for allergen management. Continually review and adjust your processes to prevent avoidable incidents.
- How Nutritics can help: Use a software solution like Nutritics to remove the risk of human error by automating the ingredient inputting process. Nutritics software means suppliers input the ingredients and further, any changes to ingredients are automatically captured in your software and flagged to you. In addition, Nutritics provides professional training courses with certification to ensure all personnel are enabled to fulfil their responsibilities and provide safe food with accurate information to their customers.
3. Risk: Labels have the incorrect size and layout to meet the Natasha’s Law regulation.
- Solution: Follow the FSA guidelines to ensure your product contains the right size label, the product name, correct font, lists ingredients in order of weight and allergens are clearly indicated in bold, underlined or in a different colour.
- How Nutritics can help: Nutritics software includes a setting to automatically print labels to the standards required by Natasha’s Law. If there is any missing information, such as the product name, our software will alert you to this. The Nutritics LabelMagic system enables you to share verified food label information from production sites to different locations in real time and a read only format. Printing on site is facilitated by a separate tablet and bluetooth connected printer, minimising the risk of incorrect label information being displayed with a completely automated process, controlled at the point of production.
4. Risk: Ingredients or formulations that you use in a standard recipe are changed.
- Solution: If there is a change in a formulation or an ingredient, e.g. in a pre-made sauce, then that change should be captured by your supplier in the information they provide to you. Every delivery should be checked by your employees to ensure that you are receiving exactly what was ordered. Any change in this should be noted and either updated in your recipe management system or if it is in error, queried with the supplier. Only once you have confirmed the full ingredient makeup should it be added to your recipe management process.
- How Nutritics can help: The Nutritics Supplier Portal automatically captures any supplier changes and flags those to you. Maintenance of a live product feed means you can rest assured that reformulation resultant changes to allergenic profile of products are communicated to the customer. Once a change is made to a product, you will be required to click scan for allergens again to verify the presence of any new allergens.If there’s been a change in a component ingredient, you’ll be alerted to this and to the specific changes, allowing you firstly to be aware of the change. This will automatically note any allergens and feed these changes all the way through your recipe management process to label generation and printing.
5. Risk: Recipe changes for seasonal variations of products.
- Solution: If your recipe changes, this should be immediately captured in your recipe management system. Allergens and nutrition information have to be recalculated and updated on the label.
- How Nutritics can help: Nutritics software captures any supplier changes and flags them to you automatically. If there has been a change in a component ingredient, you will be alerted immediately. The system will automatically note any allergens and feed the changes all the way through your recipes management process to the label generation and printing element of the software.
6. Risk: Failing mandatory Health & Safety Audits.
- Solution: Have a system in place that ensures allergen information is easily accessible and facilitates the printing of compliant food labels.
- How Nutritics can help: Nutritics software is cloud based. All information is accessible anywhere at any time. Web based software is automatically backed up and updated as required and modern encryption technology makes most online software even more secure than local software. The added benefit for a busy professional is unrestricted access to the software from any device in any location.