Food labelling guidance: Bringing F&B businesses back up to speed

Restaurants, bars, cafés and catering providers cannot afford to take chances with their food-labelling processes as it only takes a single slip-up to potentially put customers in danger and threaten the reputation of every business involved in the supply chain. In recent years, a brighter-than-usual spotlight has been shone upon food safety as the industry has been forced to face up to high-profile cases involving allergy-related fatalities. These have prompted significant regulatory responses, such as the recent update to The Food Information Regulations 2014, to implement Natasha’s Law, which will come into force in England on the 1st October 2021. The onus is firmly on the business to ensure that their customers are protected from harmful foods. Throughout the past few months, many food outlets and providers have had no choice but to adapt their business models; for example, sit-in restaurants are now offering takeaway food or pre-packaged meals where they hadn’t in the past to try to stay afloat during these challenging times and in the future. With these adaptations comes concerns from food business owners and managers, who now need to consider what food labelling requirements their businesses must meet. The issue we’ve seen arise with feedback and enquiries from our customers is that the current food labelling regulations aren’t clear enough on what is considered best practice and what is required by law. So, what is best practice labelling, and what is required by law? For restaurants now offering made to order food for customers to take away and consume immediately, or for delivery, their obligations haven’t changed from a point of purchase perspective. If a customer discloses that they have an allergy or intolerance at the point of ordering or asks which allergens may or may not be within a dish when making their choice, businesses are responsible for providing clear and correct allergen information, whether it’s through a written or verbal form. While it’s not a legal requirement, one of the best and easiest ways for restaurants and other food outlets to inform the customer is to include allergen information on their menu or website. This way, customers can see any allergens when making their food decisions up front and businesses can be assured that the information provided is correct by taking away the risk of members of staff unintentionally relaying it incorrectly. Another best-practice procedure that businesses can implement, although it’s not a legal requirement, is to provide allergen information or dietary requirements at the point of delivery, as well as the point of purchase. This process does not need to be complicated. One of the most reliable ways to provide this information is to label the takeaway box to make it clear which one has been specifically made for the customer with the allergy. It is recommended that this is done via a labelling solution which can create durable labels not only for allergen content, but for ingredients, barcodes, branding and expiry dates too, however, these are not mandatory. Businesses that still use handwriting as a method of labelling run the risk of the information being misspelled, rubbing off or being illegible, meaning the customer could accidentally eat the wrong meal, especially if several meals were placed on the same order. Alternatively, some restaurants might have changed their business models to now offer consumers prepacked for direct sale food (PPDS). This refers to all food that is made on site and packaged by the business, whether that’s grab and go options, such as sandwiches or salads, or meals that customers can heat and eat at home at a later time. Currently, the law does not require all PPDS food to carry an ingredients list on its packaging. However, from 1 October 2021 with the implementation of Natasha’s Law, PPDS food products will need to clearly display the name of the food and a full list of all ingredients and any allergens must be highlighted, for example by printing them in bold or another colour. Under current EU legislation, there are 14 allergens that must be emphasised or highlighted in the ingredients list if they have been used, or if an ingredient derived from or containing an ingredient derived from one of the named allergens is used in the food product. Any business failing to follow these rules could be hit with substantial fines, potentially up to £5,000 per offence, or even criminal charges. To label these allergens easily, businesses could look at implementing a solution which provides accurate labelling information from a cloud-based database of thousands of ingredients which are either sourced directly from the manufacturer or researched by qualified nutritionists. With many businesses changing their services over the past few months to offer takeaways or PPDS, now is a good time to refresh on both government regulation and best-practice food labelling procedures to ensure they’re meeting all the requirements. Saying that, it is evident that food businesses are becoming increasingly aware of their responsibility for providing clear and correct food labelling information, which in turn will pay dividends when it comes to consumer safety, helping build trust and loyalty longer-term. Submitted on behalf of Brother UK by Citypress