Food Allergen Labelling

Food allergen labelling is crucially important for food safety. An estimated 2 million people suffer from a food allergy in the UK alone and this is increased to 2.6 million when you consider the 600,000 who suffer from coeliac disease.

This means that all food outlets need to be mindful of food labelling. And whether you make sandwiches in a café or sell burgers from a van, it is important that your food has all the information regarding potential food allergies.

The chances are that you will have customers who could be put at risk if they mistakenly eat something which has been incorrectly described or labelled. So whether you work in a busy food outlet, occasionally make and sell sandwiches, have a food delivery business or anything else, your food allergy labelling needs to be accurate in order to avoid causing life-threatening reactions or even death.

This is both a legal and moral responsibility. Just imagine how you would feel if your sandwich or burger hospitalised or killed somebody? Without accurate food labelling available to your customers, this is a strong possibility.

The law and food allergen labelling

Pre-packed food

The law requires you to provide a full ingredients list including potential allergens on all pre-packaged food that you sell. This applies to food such as ready meals, sandwiches, pasties, pastries, cakes or anything that you receive ready made from a supplier.

You are required to highlight potential allergens so they are visible to the customer. You can do this by sticking on labels or using a marker pen on the packaging to make the allergens more noticeable.

The laws surrounding food manufacturing safety and allergens are comprehensive and will already have been covered by the food manufacturer.  So this is not something that you need to worry about, because in the case of pre-packed food bought in, your only responsibility is to make customers aware of any potential risks. You should be able to explain the products to any customer who asks by referring to the label.

If the bought-in food products are sold loose, such as cakes or pies, you should highlight any potential allergens so that customers know exactly what they are buying. You should provide accurate signage that makes this simple, such as saying contains eggs if your ingredients list from the manufacturer includes common derivatives such as albumen.

Signs containing allergen advice should be positioned at the point of sale and there should always be at least one staff member who understands the products and how they relate to allergens.

Foods that are packaged on the premises

Natasha’s law came into place in October 2021, meaning any cafes or delis selling pre-packaged for direct sale (PPDS) food must legally provide this information. All ingredients on individual product packaging must be labelled and allergenic ingredients must be emphasised in italics, bold, or a different colour.

Natasha’s Law

Natasha Ednan-Laperouse was a 15-year-old girl who died tragically after consuming a baguette from the Heathrow Airport branch of Prêt a Manger. The artichoke and olive baguette also contained undisclosed sesame seeds which caused Natasha to go into anaphylactic shock during the flight to Nice. Natasha died because of inadequate food labelling, and her parents have campaigned for tighter regulations. These will be implemented in England from October 2021.

Check out our knowledge base to find out more about Natasha’s Law and how it will impact food businesses.

What is a food allergy?

A food allergy is caused by the way that the body reacts to specific foods. It is caused by the body’s defence system that mistakenly treats certain types of protein as a threat. When this happens the body releases chemicals and it is these that cause the allergic reaction.

According to the NHS, any foods can trigger an allergic reaction but in general problem foods fall into specific categories.

These are:

• Milk
• Eggs
• Peanuts
• Tree nuts
• Fish
• Shellfish
• Some fruit and vegetables.

Symptoms of food allergies

Symptoms of food allergies can vary from person to person and may affect different parts of the body at the same time. They can be mild and soon pass off but in some cases they can be extremely dangerous.

Common symptoms of a food allergy include:

• A rash or hives
• Itchy sensation in parts of the face including throat, ears and inside the mouth
• Swelling of the face including the throat, eyelids, lips, tongue and roof of the mouth
• Vomiting.

Anaphylactic shock

This is the most serious allergic reaction and it is life threatening. Anaphylaxis includes all of the above symptoms plus breathing difficulties, light headedness and eventually loss of consciousness. You should always act fast because this is a medical emergency so calling 999 is imperative because the sufferer’s life is in danger.

A food allergy is not the same as food intolerance. Food intolerance may cause troubling symptoms such as bloating or diarrhoea such as with yeast, gluten or milk intolerance, but it is not potentially fatal.

The 14 Food Allergens

There are 14 food allergens that you need to be aware of and these ingredients must be clearly marked and declared on any food offered for sale.

• Nuts (almonds, hazelnuts, walnuts, pecan nuts, sesame, Brazil nuts, pistachio, cashew, Macadamia or Queensland nut).
• Peanuts.
• Eggs including egg derived substances such as albumen.
• Milk and dairy.
• Crustaceans such as crab, lobster or prawns.
• Molluscs such as mussels, oysters or cockles.
• Cereals containing gluten such as wheat, spelt, Khorasan wheat, barley, rye and oats.
• Celery.
• Lupin.
• Mustard
• Sesame seeds
• Soya
• Sulphur dioxide (when added and above 10mg/ kg in the finished food or drink).

Gluten free and coeliac disease

The term “gluten free” has become a selling point for weight loss. Many people suffer from gluten intolerance and for some people gluten can be extremely dangerous.

Gluten is a protein found in three types of cereals: wheat, barley and rye. And as the name suggests, it is the gluey substance which gives bread its chewy texture. Because it is in cereal, gluten is present in numerous foods such as pasta, cakes, sauces and more, so it can be extremely hard to avoid. Gluten is not bad for health for most people but for those who suffer from coeliac disease it is extremely dangerous.

Coeliac disease is an auto immune digestive condition triggered by gluten which means that the body’s immune system attacks healthy tissue in an attempt to remove the perceived threat of gluten. This can cause a wide range of symptoms including diarrhoea, nerve damage and fatigue and it is a serious medical condition.

The only way to manage coeliac disease is to avoid consuming gluten entirely, so it is crucially important that foods which contain gluten are marked as such. It is also important that those food products which are gluten free really do contain zero gluten.

What are the possible allergen risks?

If you mislabel food or fail to provide the full ingredients list, you could cause someone to choose food that may do them harm and cause an allergic reaction.

Natasha’s Law was created out of a tragedy that was easily preventable. Her baguette contained sesame seeds, and had this small ingredient been highlighted on the packaging of her baguette, she would have known to avoid it and would still be alive today.

Incorrect labelling on pre-packaged food could cause someone to have an allergic reaction so it is crucially important to ensure that all labelling is accurate. If there are any doubts you should seek advice from the food manufacturer, whether you have bought food in from a supplier or it has been made by hand in the kitchen.

What could happen to your business?

If you mislabel food or fail to provide adequate allergen information and somebody suffers, it will damage your business reputation and negatively impact custom.

According to industry watchers, Prêt a Manger went from being the darling of the high street to industry bogeyman following the death of Natasha Ednan-Laperouse.

This once popular chain has never fully recovered and, even worse, many labelling malpractices carried out by the company have since been revealed. An earlier customer died following eating a so-called dairy-free flatbread which contained yoghurt, and this once popular fast-food chain is no longer seen as trustworthy.

Even if your food outlet is on a local scale such as one sandwich shop or a burger van, adverse publicity will certainly have a detrimental effect upon custom.

Fines for breaching food information and safety laws

Failure to adhere to food labelling requirements could be very expensive. If you are convicted for an offence under the Food Safety Act 1990 in the magistrates’ court, the level of fine is an unlimited amount (which is also the case for trial in a higher court). Previously the maximum fine was set at £20,000 but this cap has now been removed so your fine will depend upon the size of your business and the offence.

Offences include the sale of food which does not comply with safety requirements and falsely describing or presenting food especially when undisclosed allergens have been used.

If somebody has died following ingesting undisclosed allergens you could be facing a charge of manslaughter. In addition, anyone who suffers from an allergic reaction thanks to mislabelling could sue your business for damages.

Failure to maintain correct food standards, including allergen labelling, is likely to lead to the enforced closure of your business.

So how do you ensure your food labelling complies with requirements?

First up you need to know exactly what is contained in the food that you sell, and if any ingredient is on the list of 14 food allergens, these must be clearly highlighted and marked.

So if, for example, you are selling a Victoria sponge – either in slices or as the whole cake – the allergen content must be made visible to customers. A Victoria sponge contains wheat flour (gluten) and eggs. It also may contain dairy produce such as milk and butter. These potential allergens must be labelled in order to avoid any misunderstanding.

Even with food items that seem obvious, you will still need to provide an allergen label. It may seem obvious that a cheese and ham sandwich contains cheese, ham and bread but not everyone will make the connection with potential allergens. Marking the sandwich with a food label that states that this sandwich contains dairy produce, gluten and sulphites – which are used as a preservative in numerous meat products – is therefore essential.

Precautionary labelling

Phrases such as, “may contain nuts”, or “may not be suitable for those with a specific allergy” are not legal requirements, but if there is any risk of cross-contamination they will help your customer make informed choices.

The importance of food labelling

Food allergy labelling is crucially important for your business and for the safety of your customers. Every year on average 5,500 people attend hospital because of serious reactions to food, and this figure seems to be rising each year by 10%.

Younger people, who tend to eat out more, are more at risk than the older age group, with teenagers and people in their 20s most at risk.

It is important to remember that not everyone may know they have a food allergy to a specific ingredient. Seafood especially can be a common issue because it is not commonly eaten in the UK, so if you have something on the menu, such as crab, there is a chance that your younger customers may be trying this for the first time. If they do suffer an allergic reaction from an ingredient, and some allergens are fairly obscure, the allergy warning will help the customer (and the hospital) identify the issue.

Download your free allergen labels here:

The only way to ensure that at-risk customers stay safe is to make sure that all your food products come with clear ingredients information and visible allergy warnings.

If you sell loose food or repackage food into individual boxes or bags, you do need to provide allergen information in order to keep customers safe.

Allergen advice should be provided in your outlet, such as by the till or by the self-service area. It should also be printed on the takeaway packaging so that the customer has a reference if the food is for someone else or is to be eaten off the premises.

To help you and your customers stay safe, we have produced a set of fully printable PDF allergen labels which you can use for your food products.

Readers can download a free set of fully printable allergen labels above.

In conclusion

Providing comprehensive allergy warnings for customers may seem like yet another example of red tape, and when you are running a food business it may seem like yet another job on the endless “to do” list. However, these rules are important, they do have a very necessary function and they are a legal requirement, so you will face penalties if you fail to comply.

However, it is not just about the law. It is important that your customers can trust your food and, if adequate labelling prevents even one tragedy, we should all embrace the new rulings on allergen labelling.