It's easy to see why Natasha's Law is a great idea - and how important it is that the customer has full visibility of what is in their food.
Too many hotels think that it is something for the food retail industry - but all aspects of Hospitality need to play their part.
Melissa Thompson is our F&B Safety Expert. In this article, she answers a few key questions about the law and what it could mean for you!
Melissa is currently Managing Director of Safer Food Scores - one of the most respected food safety agencies in the country. Their Hotel credentials speak for themselves, having worked with Holiday Inns, Penta Hotels and London locations such as the Langham and Rosewood Hotels amongst others.
What is Natasha's Law?
Natasha's Law is the name given to a change in the UK’s Food Information Regulations. Its main effect is that food pre-packaged on the same site that it is supplied is no longer exempt from the need for a food label. The change in the law resulted from a UK-wide consultation which followed the tragic death of teenager Natasha Ednan-Laperouse. Natasha died as a result of an allergic reaction to a baguette she had eaten, which did not display allergen information on the packaging.
When does Natasha's Law come into effect?
Natasha's Law came into effect on 1st October 2021. There has been a two-year lead in period to help businesses prepare for the new requirements.
What can happen if Natasha's Law is not complied with?
If you have not labelled PPDS (pre-packaged for direct sale) foods on site, Trading Standards or Environmental Health Officers may provide advice, serve an improvement notice or prosecute a business. They should follow a risk based and proportionate approach to gain compliance.
A more serious offence is to label a food incorrectly, especially if allergens are missing from the ingredients list and an allergic incident occurs. Enforcement officers are likely to take formal action in these cases which could result in seizure, prosecution, unlimited fines, and imprisonment.
Who can check Natasha's Law food labels are compliant?
It's important to get expert advice in this area. I am part of the team at Safer Food Scores who include food labelling experts who can examine your Natasha’s Law food labels, explain if any changes are required, and provide a report for your due diligence. If you have not yet devised your labels, our food labelling experts can instead examine your recipes or product specifications and advise what you need to include on the label.
Does Natasha's Law apply to restaurants?
Natasha's Law applies to any food business that pre-packs food on the same site that it is offered or sold e.g., restaurants, cafes, takeaways, street vendors, butchers, bakers, grocers, schools, colleges, nurseries, staff canteens, care homes.
Which foods does Natasha's Law apply to?
Natasha's Law applies to foods which are pre-packed for direct sale (often referred to as PPDS foods). To meet this definition, food must be packaged at the same place it is offered or sold to consumers and must be in this packaging before it is ordered or selected. It can include food that consumers select themselves (e.g. from a display unit), as well as products kept behind a counter.
What is the definition of pre-packed food?
For Natasha's Law to apply, the packaging must enclose the food completely or only partially, but in any event in such a way that the contents cannot be altered without opening or changing the packaging.
Which foods are exempt from Natasha's Law?
Foods exempt from Natasha's Law include:
Any food packed after being ordered by the consumer
Food packed by one business and supplied to another business (full labelling required)
Foods that are distance sold e.g. ordered by phone or on a website
This is a useful decision tree from the Food Standards Agency to help determine whether your food products will require labelling.
How to comply with Natasha's Law?
To ensure that you comply with Natasha's Law, any foods pre-packed for direct sale must be labelled with:
Food name (may be descriptive, protected, or customary but must not mislead)
Full ingredients in descending order of weight (at time of production)
Allergens highlighted within the ingredient list (usually in bold)
Additives (technological function plus name or E-number)
Percentage meat content if a meat product (unless exempt)
Irradiated or genetically modified ingredients declared
What is the minimum font size for Natashas Law labels?
The font size of mandatory information must be at least 1.2 mm x-height if the surface area of the pack is equal or greater than 80cm², otherwise it can be 0.9 mm x-height
Packaging with a surface area of less than 10cm² does not require a full ingredient list but does require allergen labelling.
Expert advice on Natasha's Law
This Natasha's law food labelling guidance, should help you to understand what is required. Melissa has a HotelCostClinic treatment available that focusses on Natasha's Law and will help you through the legislation.
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