The New Food Information Regulations Is your business ready?
UNDERSTANDING THE NEW FOOD ALLERGEN RULES Stephen Pugh Head of Food Labelling Team DEFRA
Key facts ~1.92m people have food allergy in the UK (based on population of 63.1m). This figure excludes food intolerance. There is no cure, therefore need to observe avoidance Read ingredient labels Look out for hidden allergens
Food labelling is changing Moving from General Labelling Regulation (2000/13/EC) to Food Information for Consumers Regulation (1169/2011/EC) Three year transition period from the coming into force date from 13 December 2014 new rules on allergen labelling shall apply Existing requirements for pre-packed foods are retained but new requirement to emphasize allergenic foods in the ingredients list Introduction of new requirement to provide allergy information for unpackaged foods
Scope of the Regulation Covers business operators at all stages of food chain concerning provision of information to consumers: Food intended for the final consumer Foods delivered by mass caterers Foods intended for supply to mass caterers
Annex II The big 14 Peanuts Nuts Milk Soya Mustard Lupin Eggs Fish Crustaceans Molluscs Cereals containing gluten Sesame Celery Sulphur dioxide
Mandatory particulars Article 9(1)c - Any ingredient or processing aid listed in Annex II, or derived from a substance or product listed in Annex II causing allergies or intolerances, used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form Article 9(2) - The specified allergenic foods to be indicated with words and numbers - they may additionally be expressed by means of pictograms or symbols
Article 12 & 13 Clarity and Legibility For prepacked foods, mandatory information to appear directly on the package or on a label attached to it Mandatory food information to be available and easily accessible for all foods Mandatory information to be marked in a conspicuous place, be easily visible, clearly legible and, where appropriate, indelible. It should not be hidden, obscured, detracted from or interrupted by other written or pictorial matter
Article 14 Distance selling In the case of foods offered for sale by means of distance communication, mandatory food information to be available before purchase is concluded and to appear on the material supporting the distance selling or be provided through other appropriate means clearly identified by the food business operator All mandatory information to be available at the moment of delivery
Article 21 Labelling of allergens Allergens to be indicated with clear reference to name of the substance or product as listed in Annex II i.e. whey (milk) Allergenic ingredients to be emphasized through a typeset that clearly distinguishes it from the rest of the ingredients by means of the font, style or background colour In the absence of a list of ingredients, the indication of the allergenic ingredients to comprise the word contains followed by the name of the substance or product listed in Annex II Where several ingredients or processing aids in a food originate from a single allergenic ingredient, the labelling shall make it clear for each ingredient or processing aid concerned
EU FIC Labelling
Article 44 non-prepacked food A new requirement for allergen ingredients information to be provided for non-prepacked foods and food provided prepacked for direct sale Foods are offered to sale to the final consumer or to mass caterers without pre-packaging, or where foods are packed on the sales premises at the consumer s request or prepacked for direct sale, the provision of the information about allergenic ingredients is mandatory
Article 44 non-prepacked foods cont Oral provision also permitted, provided the business indicates clearly that such information can be obtained upon request. Oral information must be accurate, consistent and verifiable upon challenge What is consistent? Is there a process in place to enable consistent information to be provided? For example to refer queries to the nominated person(s) What is verifiable? Ingredients information on a chart, recipe book, ingredients information sheets, scrap books with labels etc
Article 44 non-prepacked foods Could declare allergen ingredients information through a contains statement, charts, tables etc. i.e. chicken tikka masala Contains: milk, almonds (nuts) Consider Article 12 and 13 on accessibility of mandatory information - Marked in a conspicuous place, easily visible, clearly legible Signposting is required when information is not provided written and upfront. It should be where consumer would expect to find allergen information e.g in a folder, on menu board, at till or on the menu card Food Allergies & Intolerances Before you order your food and drinks please speak to our staff if you have a food allergy or intolerance
Providing allergen information Mollsucs Lupin Sulphites Sesame Mustard Celery Nuts Milk Soyabeans Peanuts Fish Eggs Crustaceans Cereals containing gluten Dish Lasagne wheat Mushroom risotto Lemon cheesecake wheat almonds
Article 44 non-prepacked food How are dietary requests communicated from front to back of house? e.g. use of chef cards, order tickets, receipts Preparing foods for allergic consumers- what process is in place Is the business observing Safer Food, Better business (SFBB) Safe Method: Allergy Are they making specific claims i.e. gluten free Consider how this claim is verified or validated Would no gluten containing ingredients (NGCI) statement be better?
Regular reviews, keep it current Food businesses need to have processes in place to ensure the information they provide is accurate Regularly review the ingredients information Where ingredients change, review the accuracy of the recipe Do garnishes or dressings change the allergenic profile of the meal? Check! Accuracy is dependent on the information on labelling, updating allergen information for dishes, updating staff and consumers
Communication is key Think about the chain of communication The person buying the food The person handling the food The person taking the order The person ordering the food
Changes to enforcement Broadening responsibility FIR will introduce Improvement notices outlines necessary changes to reach compliance, timebound First tier tribunals businesses to challenge / appeal IN s Criminal sanctions for breaches in food allergen provisions food safety EHOs / TSO s to help educate the food businesses and to maximise the opportunities of LAs to talk to businesses
SFBB allergy safe method http://multimedia.food.gov.uk/multimedia/pdfs/public ation/foodallergies-sfbb-0513.pdf
Further information FSA allergy pages: http://food.gov.uk/policy-advice/allergyintol/ Allergy E-learning http://allergytraining.food.gov.uk/ released December 2013 suitable for businesses Allergy chef card: ttp://multimedia.food.gov.uk/multimedia/pdfs/chefcard.pdf Safer Food Better Business for Caterers Food allergies http://www.food.gov.uk/multimedia/pdfs/publication/foodallergies-sfbb- 0513.pdf General FIR information to be found on GOV.uk Consumer advice http://food.gov.uk/multimedia/pdfs/publication/allergyleaflet.pdf BRC-FDF guidance for prepacked foods http://www.brc.org.uk/downloads/guidance%20on%20allergen%20labelling.pdf
Thank you for listening Email: chun-han.chan@foodstandards.gsi.gov.uk
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