14th May 2019


 Issue No.  2019/08




Everyone knows, or should know by now, that allergies or food intolerances can be life changing, and in some cases, tragically, fatal. Over the last few years, there has been publicity surrounding people who have sadly lost their lives as a consequence of suffering an allergic reaction following consumption of food they have purchased from a variety of outlets.  These range from small, independently owned takeaways to nationally recognised chains.

According to the Food Standards Agency (FSA), there are 4,500 UK hospital admissions a year from food allergy; 10 food allergy deaths per year; 1 in 4 people surveyed said they or a relative had a reaction eating out; 8% of children affected by food allergies or intolerances; 2% of adults.

Last week the FSA proposing a further amendment to the existing requirements on suppliers to publish allergen information and therefore it is appropriate to provide an allergen update.

So what are Allergens?
Allergens are:

  • Cereals containing gluten – wheat, barley, rye, spelt, oats & kamut
  • Crustaceans – crab, lobster, prawns, langoustine & shrimps
  • Egg
  • Fish
  • Lupin (Lupin seeds and flour in some types of bread & pastries)
  • Milk
  • Molluscs – squid, octopus, mussels, cockles, periwinkles & snails
  • Nuts – almond, hazelnut, walnut, cashew, pecan, macadamia & Queensland
  • Peanuts – including groundnuts or monkey nuts
  • Soya
  • Sesame
  • Celery & celeriac
  • Mustard
  • Sulphur dioxide & sulphites (preservatives in dried foods, drinks)

What are the current requirements?
It is well established that allergen information must be provided for foods for direct sale whehter they are non-packed or pre-packed.

Food manufacturers are already required to include allergen details on labels on all pre-packed foods. 

Food businesses (e.g. restaurants, hotels, pubs, sandwich shops) selling wrapped or un-wrapped that is prepared or wrapped on site are required to provide information on allergens.  The information can be supplied on the menu, on chalkboards, tickets or provided verbally by an appropriate member of staff as well as in other formats made available to the consumer.  It must be clear and inconspicuous, easily visible and legible.

Where the information is to be provided verbally by a member of staff, then it will be necessary to make it clear that the information can be obtained by asking a member of staff.  It is insufficient for a food business operator to say that they do not know whether or not a food contains an allergen, nor is it enough to say that all their foods may contain allergens. In other-words, food businesses must provide the specific allergens contained in each and every food item that they serve.  It is also unacceptable to say their food contains all 14 allergens if they know it doesn’t.

FSA Proposed Changes
The FSA have last week advocated that allergen information should be provided on pre-packed direct sale food to give consumers greater confidence in the food they eat.  This means that foods that have been packed on the same premises from which they are being sold, (e.g. a pre-packaged sandwich or salad made by personnel earlier in the day and placed on a shelf for purchase) should, the FSA believe, have a label containing all the applicable allergen information. Currently this is not a requirement.

The FSA are to advise Government Ministers that full ingredient labelling should be mandatory for all pre-packed food for direct sale.  The FSA believe that full ingredient labelling would deliver a significant improvement, and greater consistency by following the same labelling system that consumers are familiar with, as found on other pre-packaged food that are bought in.

The proposal would not affect sandwiches that are made to order or have been pre-prepared but are not pre-packed (e.g. those unwrapped in a display cabinet, for example).  The situation would remain unchanged in that the Food Business would be able to provide the allergen information upon request, either in written form, or verbally, as it is expected that the customer can speak with the person who made or packed the product. Signage to that effect is required.

In Summary
Therefore, in summary, the FSA proposal will only extend the requirement to provide printed allergen information on those pre-packed sandwiches/salads etc. that are made and sold on the premises if the Government agree to the FSA proposal and make it a mandatory requirement. New legislation may be required to implement this.

We will need to wait and see how the Government respond.  As soon as we hear, we will update you accordingly.

If you have any concerns about how you manage food safety within your business, please do contact us on 03456 446 006. 





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