Dr David Jukes, The University of Reading, UK

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Food Law News - UK - 2019

DEFRA/FSA Consultation, 25 January 2019

LABELLING - Consultation on amending allergen information provisions contained within domestic food information legislation for food prepacked for direct sale

Consultation on amending allergen information provisions contained within domestic food information legislation for food prepacked for direct sale

A copy of the consultation document is available on this site (click on image). A summary document is also available: Summary Overview. An Impact Assessment is also available (external link). Consultation closes: 29 March 2019.

Provided uder the Open Government Licence. The original consultation document was accessed from: . The original consultation page was accessed from:

The following is the text of the Summary Overview:

1. Introduction

We are launching this consultation on proposed changes to allergen labelling requirements for foods which are prepacked for direct sale (PPDS).

General background on food hypersensitivity

In the UK, it is estimated that 1-2% of adults and 5-8% of children have a food allergy. This equates to around 2 million people living in the UK with a food allergy, but this figure does not include those with food intolerances. 

There is no cure for food allergies and intolerances. The only way to manage the condition is to avoid food that makes the person ill. Therefore, it is very important that consumers are provided with accurate information about allergenic ingredients in products to allow them to make safe food choices.

2. What is PPDS?

Put simply, prepacked for direct sale (PPDS) foods are foods that are packed on the same premises from which they are being sold, before they are offered for sale.

These might include for example, a packaged baguette from a sandwich shop made by staff earlier in the day, or a salad made and packaged in the kitchen of a café and then placed on a shelf for customers to purchase.

Important distinctions: what is not PPDS?

Foods that aren’t prepacked, such as loose items sold without packaging (e.g. fruit) and meals served in a restaurant or café are not PPDS. Neither are foods that are: 

These foods are not PPDS and therefore fall outside of the scope of this consultation.

3. Why focus on PPDS?

Currently, PPDS foods are not required to carry labels on the packaging. The allergen information must be readily available, including through indications to ask a member of staff, and information on allergens can be given in person by the food business operator when asked.  

We want to make the rules clearer so consumers are more aware of any allergenic ingredients in the PPDS food they purchase.

4. Policy options

Through this consultation we are seeking views on different options to improve the provision of allergen information to consumers for PPDS foods. 

Options do not need to be considered as exclusive and may be combined or applied to different sizes of businesses in a two tier approach. 

Non-regulatory option

Policy option 1 – Promote best practice: This option would not require a legislative change. Instead, it would require additional activity to promote best practice around communicating allergen information. This would involve encouraging businesses and consumers to review their knowledge, skills and actions to ensure a safer environment for consumers. 

Regulatory options

Policy option 2 - Mandate “ask the staff” labels on packaging of PPDS foods, with supporting information for consumers in writing  This option would require “ask the staff” about allergens labels on all PPDS products. When asked about allergenic ingredients, staff would have to provide supporting information in writing upon request, before the food was purchased. 

Policy option 3 - Mandate name of the food and allergen labelling on packaging of PPDS foods This option would require PPDS foods to have a label on the packaging to tell the consumer the name of the food and which of the 14 allergenic ingredients specified in law the product intentionally contains.

Policy option 4 - Mandate name of the food and full ingredient list labelling, with allergens emphasised, on packaging of PPDS foods This option mandates PPDS foods to have a label naming the food and listing the full ingredients with allergens emphasised on the packaging. Labelling will include:

a. the name of the food.
b. the list of ingredients
c. any of the 14 allergenic ingredients specified in law or processing aids derived from them used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form, would be emphasised to stand out from the other ingredients in the list, for example in a bold typeface
See also: 25 January 2019 LABELLING - Environment Secretary proposes tougher labelling laws for allergy sufferers
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