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Natasha’s Law: A Guide for Confectionery Retailers
When your business revolves around stock that customers are going to eat, it is important that you take steps to ensure that what you offer is not only delicious but safe, too. These steps protect consumers and retailers and ensures that everybody is well and happy. Natasha’s Law is a UK statute introduced to do exactly that and dictates the labelling of ingredients and allergens in pre-packaged consumable goods – to protect those with the most common food allergies.
What is Natasha’s Law?
In place since October 2021, Natasha’s Law followed the tragic and avoidable death of Natasha Ednan-Laperouse. Natasha bought and ate a sandwich that had no allergen warnings on its packaging – and therefore thought it was safe. The result of a campaign led by her parents; Natasha’s Law sets the standard for labelling allergens on PPDS (prepacked for direct sale) foods. Making it compulsory for businesses to label their prepacked foods with their name and full ingredients list – with any of the top 14 allergens clearly emphasised – the law aims to avoid the most common allergic reactions. For reference, these allergens are celery, gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts, peanuts, sesame seeds, sulphur dioxide (sulphites), and soya. If you are pre-packing and selling items that include any of these, they must be emphasised within your list of ingredients. In accordance with the law, any foodstuffs prepared, packed, and sold at the same site should be labelled with:
The name of the food
A full ingredients list
Any of the 14 allergens must be clearly emphasised
What is PPDS?
As previously stated PPDS stands for prepacked for direct sale – and understanding it is key to complying with Natasha’s Law and labelling stock correctly.
The prepacked aspect is self-explanatory – it refers to foods that are packaged and sold to consumers from the same location. Direct sale refers to stock that is in its final, packed form when shoppers see and interact with it. Commonly this includes stock that shoppers pick off the shelf themselves as well as items behind a counter. Obviously, this applies to various shops and cafes, but also to temporary and mobile stores, too. Full details on what products must be labelled and how can be found on the Food Standards Agency website.
In the world of confectionery, the impact of Natasha’s Law won’t really be felt unless you deal with repackaging stock before the point of sale. Offering lines such as bespoke pick n mix bags or boxes, chocolate mixes, or any loose confectionery in new packaging will mean that you require a full list of ingredients and highlight the allergens on each pack. Whether you are packing and selling sweets in your shop, on a stall at a fair or market, or even from a temporary premises like a van, this will apply to you.
Does Natasha’s Law Apply to Your Business?
Whilst the most common examples of foods targeted by Natasha’s Law are prepacked sandwiches and pre-prepared food-to-go, there are cases where confectionery businesses will need to comply.
In the world of confectionery, the impact of Natasha’s Law won’t really be felt unless you deal with repackaging stock before the point of sale. Offering lines such as bespoke pick n mix bags or boxes, chocolate mixes, or any loose confectionery in new packaging will mean that you require a full list of ingredients and highlight the allergens on each pack. Whether you are packing and selling sweets in your shop, on a stall at a fair or market, or even from a temporary premises like a van, this will apply to you.
Given that it is produced and packaged by one company and sold to consumers by another, the vast majority of wholesale confectionery will not be PPDS. In this instance the responsibility for labelling lies with the manufacturer. If such stock does not have appropriate labelling, however, it should not be sold.
However, appropriate labelling should be a primary concern for businesses that rely on re-packing products, as well as those that sell online or over the phone – also known as distance selling. Any stock that you re-package and then seal before the consumer buys it. Distance selling is a little different in the sense that not only must prepackaged stock have allergen stickers or information at the point of delivery, but the information must be made available to the consumer beforehand. This includes on your website or a menu as well as orally over the phone.
Any businesses creating their own pre-packed pick n mixes, chocolate platters, or even online bundle-builders, must ensure that shoppers have all of the relevant allergen information clearly displayed before the point of purchase.
Practical Considerations for Confectionery Businesses
Regardless of the type of business you run, if you sell stock that customers consume it is extremely important to be aware of Natasha’s Law. Even if the stock you sell is not PPDS, making sure that shoppers have access to a list of ingredients in products is essential.
First of all, it is important to make sure that you know what of your stock is PPDS. Unless you understand how your stock fits in with the regulations you cannot make sure that you are correctly labelling everything. If you do have stock that is prepackaged and needs to be labelled, make sure that you know what is in it.
You not only need the information to accurately label your stock, but you need the means to provide legible allergen labelling. It is allowed to hand-write labels, however, we would only recommend this for very small-scale batches or one-off occasions. If PPDS stock is a fixture of your regular arsenal, we recommend investing in a printer as it is better for efficiency and clarity. This would enable you to label en masse quicker and with guaranteed accuracy that you know shoppers will be able to understand.
Whether Natasha’s Law applies directly to your business or not, ensuring that ingredients and allergens are readily available is vital for the safety of consumers. Hence why it is a legal requirement. A core aspect of running a business responsibly, accurate ingredient information is a strong trust signal to shoppers and helps to build relationships.
Most importantly, whether sharing allergen information online or on packaging, the best advice for any business is not to take chances and ensure that all of the information any shopper needs is readily available. Whether your business deals with PPDS items or not, the principles of Natasha’s Law should always apply, and information regarding common allergies shared.