This article was first published by ASCL in their autumn term ‘Leader’ publication.
On 1st October 2021, legislation commonly known as Natasha’s Law will come into force. Teenager Natasha Ednan-Laperouse died after suffering an allergic reaction to an undeclared ingredient (sesame seeds) in a pre-packed baguette. There was no specific allergen information on the sandwich packaging. Campaigning following her death has resulted in new legislation designed to protect consumers by providing potentially life-saving allergen information on the packaging of the food.
Any schools providing pre-packaged food made on site will need to ensure compliance with Natasha’s Law. The key term is “prepacked for direct sale’ (PPDS). Before Natasha’s Law, the display of an allergen summary sheet or a notice to enquire about allergenic ingredients from a member of staff was sufficient allergen information for these items. However, from October, any PPDS food will have to clearly display the name of the food and a full ingredients list, with allergenic ingredients emphasised, for example in bold, italics or a different colour.
- PPDS means food that has been packed on the same premises as it is being offered. For example, sandwiches, salad pots or cakes that are individually wrapped at the school and sold prepacked from the school premises. If it can be taken away and consumed at a point where access to allergen information is not available, the new rules will apply.
- The law applies to any foods that are in packaging before they are ordered or selected. That will include food that students select themselves, as well as pre-wrapped food items that are kept behind a counter.
- If you are plating freshly cooked food (not prepacked before the point that it is ordered), there is no need to list the ingredients in full. A reference to the presence of the 14 EU allergens is all that is needed.
- There is a difference between prepacked and PPDS food. PPDS food is packaged at the same place it is offered and before it is ordered or selected by consumers. In contrast, prepacked food is offered or sold by a different business to the one which packaged it or offered or sold at a different location to where it was packaged. Prepacked food already requires full ingredient and allergen labelling as well as a nutritional information declaration.
Schools are advised to implement full ingredient listing on any pre-packaged foods as soon as possible to protect students and the school.
If you or your catering team are still unsure about whether a food is PPDS, there is an online tool which may assist.