Allergen law and labelling

An allergic reaction can kill. As a supervisor, you are responsible for the systems that protect customers with food allergies, intolerances and coeliac disease.

UK law names 14 allergens: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya, and sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre.

These conditions are different. A food allergy involves the immune system and can cause anaphylaxis, which can be fatal. Coeliac disease is an autoimmune condition triggered by gluten. A food intolerance does not involve the immune system in the same way. All of these customers need accurate information.

What the law requires depends on how the food is sold. Prepacked food needs full labelling, with allergens emphasised in the ingredients list.

Prepacked for direct sale (PPDS) food is packed on the same premises where it is sold, before the customer orders it. Examples are sandwiches made and wrapped in the morning and placed in a display fridge, salad pots, and boxed cakes on a counter. The label must show the name of the food and a full ingredients list, with allergens emphasised, for example in bold. This has applied across the UK since 1 October 2021. It is known as Natasha's Law, after Natasha Ednan-Laperouse.

Be careful with PPDS and movement between sites. A sandwich made in a central kitchen and sent to another of your shops is not PPDS. It is prepacked food and needs full labelling. Food that is packed after the customer orders it is not PPDS. It is non-prepacked.

Non-prepacked or loose food includes meals in restaurants and food served from a deli counter. Allergen information must be available for this food. Distance selling covers orders by phone or online. Allergen information must be available before purchase and on delivery.

A 'may contain' statement is voluntary and must reflect a real risk. It is not a replacement for good control. 'Gluten free' has a legal meaning: 20 mg/kg of gluten or less. A 'free from' claim is a promise. If you cannot rule out cross-contact, do not make the claim, and tell the customer.

Every team needs to know what to do in an emergency. If a person shows signs of anaphylaxis, use the person's adrenaline auto-injector if they have one, and call 999 straight away. Say 'anaphylaxis'. If a colleague is with you, do both at once. Lay them flat with their legs raised, unless breathing is difficult. Give a second dose after 5 minutes if they are no better. Do not leave them alone.