If you work in the food industry you’ll definitely have heard about Natasha’s Law, and you’ve probably heard discussions about PPDS too.
It’s a hot topic – and one that’s not going away any time soon – so we’ve put together a handy starter guide to understanding PPDS and its importance, for anyone needing a refresher…
What is PPDS?
PPDS stands for “Pre-Packed for Direct Sale”. It refers to foods that have been packed on the same premises from which they are being sold, before they are offered for sale.
An example of this could be a salad or a baguette that was prepared by shop staff earlier in the day, and placed on a shelf for customers to select themselves and purchase.
Do PPDS foods need allergen labelling?
Up until recently, no. Not legally.
Under FIC (Food Information to Consumers) legislation, all pre-packed food should have allergen information on the labelling. However pre-packed foods and PPDS foods are not the same thing – pre-packed foods are not packed on the same premises from which they are sold. Examples are things like tins of soup bought from the supermarket, or a packet of sweets purchased from a newsagents.
PPDS foods do fall under FIR (Food Information Regulations) legislation, which sets out that food businesses are required to relay allergy information to their customers, but in any way they like – such as via a menu, or orally via a server.
So up until now, it has been required that staff at a business selling PPDS food are able to inform customers about a product’s allergy information, but not that the product itself has allergy labelling.
Why is legislation around PPDS changing?
1-2% of adults in the UK now suffer from an allergy, and and in children that rises to 5-8%.
Not only is the appetite from consumers for allergen information greater than ever, but it’s often difficult for them to distinguish between pre-packed food and PPDS food.
An allergy sufferer might pick up a PPDS food item thinking that it is a pre-packed food item, which is required to have any allergen ingredients noted on the packaging. They might then assume an absence of such information means that the item does not contain any allergen ingredients. But since PPDS food items are currently not required to display allergen information on their packaging, the product could in fact contain an allergen ingredient, putting the consumer at risk.
Public concern over this risk has increased since the high-profile case of Natasha Ednan-Laperouse, who in 2016 died from an allergic reaction having purchased and eaten a baguette from Pret-a-Manger. Although she knew about her severe sesame allergy, Ednan-Laperouse was not aware that the sandwich contained sesame seeds, as it was not labelled on the packaging. Her parents have campaigned tirelessly for a change in legislation on PPDS labelling.
This increased awareness around the issue, and the increasing need for accurate and easily accessible information on food labelling has prompted the British government to reassess legislation around PPDS packaging.
How is legislation around PPDS changing?
In January 2019, the FSA, FSS and Defra launched a consultation on proposed amendmendments relating to the mandatory information and presentation of allergen labelling for PPDS foods.
4 policy options were proposed, one non-legislative – promoting best practice, and 3 legislative – mandating “ask the staff” labels, mandating allergen labelling, and mandating full ingredient labelling.
After responses from business consultations, and advice from the FSA, the Government intends to take forward the policy of mandatory full ingredients labelling on all PPDS food items, believing this is the most effective way to mitigate the public health risk associated with allergens.
The changes will be made through an amendment to The Food Information Regulation 2014, and will come into action from October 2021 in England and Northern Ireland (with Scotland and Wales expected to follow).
We are now in a transition period until the end of 2020, while the EU and UK negotiate additional arrangements. With the consultation officially ending this week an FSA board meeting will take place next week, and though it’s thought that they will only publicly touch upon the outcome at that stage, at a later date we can expect to see FSA guidance published alongside legislation to support businesses and local authorities.
You can find out more about Updates to the Food Standard Agency’s Technical Guidance on food allergen labelling and information requirements here.