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Allergen labelling change throws spotlight on supply chain

Natalie McEvoy

As Natasha’s Law comes into force on 1st October 2021, businesses will see stakeholders’ expectations rise and reputation risk rise

On 17 July 2016, 15-year-old Natasha Ednan-Laperouse died of anaphylaxis after eating an innocuous looking artichoke, olive and tapenade baguette from Pret a Manger at London’s Heathrow Airport. The baguette contained sesame not listed on the packaging, and to which she was allergic.

Food prepared on the premises in which it is sold is not legally required to display allergen information on the label, meaning allergy sufferers are denied the full picture when buying food to eat whilst they are out. Having a nephew with a severe peanut allergy, I know how deeply Natasha’s death impacted the allergy community; severe allergies are a millstone carried daily by a family out-and-about and sufferers should not have to play roulette.

From 1st October 2021, Natasha’s Law changes labelling requirements and brings some measure of comfort and solidarity to those navigating food-buying with allergies. The UK Food Information Amendment 2019 (“Natasha’s Law”) will require all businesses selling Prepacked for Direct Sale Foods in England, Scotland, Wales and Northern Ireland to carry a full list of ingredients.

Many businesses will have implemented the labelling changes as soon as the law was read in Parliament in September 2019; law is a reactive force and often lags behind public opinion and consumer expectation. PR and reputation protection, on the other hand, are proactive endeavours taken to ensure that a brand is known for staying ahead of the game.

Where a business is small and contained, preparing for the introduction of Natasha’s Law may be straightforward. Menus must be checked across the whole year, with every ingredient captured and listed; nothing may be added during the preparation process unless it goes on a list. Clear process and training will be the key here; routine and predictability will enable a smooth transition. If an added ingredient you have not made yourself contains a potential allergen - for example if you use a pre-purchased spread, marinade or sauce - you will adopt that responsibility in turn for checking and listing its ingredients. Constituent elements are imperative and must not be overlooked; after all, it was the small sesame seeds sprinkled on the bun which killed Natasha, so detail matters.

A larger business will rely on its supply chain for some of its constituent ingredients. Now more than ever, you will need to be able to have full confidence in the ethics of your business partners.

They will need to provide you with the ingredient list and allergen information for all of their products; if you are selling the finished product, the buck will stop with you, so you must be content that you are in receipt of sufficiently detailed information to confidently meet the labelling requirements.

Likewise consider and plan for any disruption that your labelling may face if there is a stock substitution or product change; end-user labels need to have the ability to be dynamic.

Make sure you avail yourself of the technology that will make the labelling task easier and safer. Automating fully compliant labels with labelling software that integrates your supplier data into one dashboard will embed this legal update into normality seamlessly. Money spent here will be a return on investment in terms of mitigating regulatory breach or litigation risk, not to mention in effectively supporting your employees. The human element is both your downfall and your saviour; automation reduces the chance of human error - perhaps in overlooking a constituent ingredient - but allows for a real-time reaction if amended labelling is required on a batch of food.

Every worker – not just those involved in food preparation - must be allergen aware, and up to speed with labelling requirements. Those managing the outlet and stacking the shelves are your first line of defence at close of business on 30th September 2021, ensuring that the shelves are cleared of any inadequately labelled produce, and likewise your second pair of eyes on 1st October as compliant labelling hits the shelves.

Review your franchise network, accounting for all of your food outlets across England, Scotland, Wales and Northern Ireland. This is impactful legislation and you can be sure that if a journalist calls, it will be from the most isolated, far away sandwich shop in your network. Plan and prepare for your vulnerabilities; often this comes down to clear and repeated communication to employees, simple and well-trained embedded processes and effective control of your supply chain.

What was lawful in September will be unlawful in October; such is the reality of business. Labelling requirements will – if not already - become another factor on the risk register, but as the legislation is motivated by the drive to prevent another allergy death, this advance supports businesses in avoiding the ultimate crisis.