Former Trading Standards Officer Pete Martin, from product and labelling compliance firm Ashbury, examines how bakers can ensure best practice in the complex area of allergen labelling.
Recent high-profile incidents may lead to a change in the law around allergen labelling and create a precedent that affects best practice. In the meantime, what is legal and what are the essential steps to ensure all allergens are clearly communicated?
Only ‘prepacked’ foods are required by law to declare specified allergenic ingredients on the label. These requirements do not apply to food sold unwrapped – for example in restaurants, bakeries or deli counters, or to foods sold ‘prepacked for direct sale’; foods that are generally wrapped on the same premises as they are sold, such as meat pies or sandwiches.
Often referred to as ‘non-prepacked’, there is no legal requirement to provide a full ingredients list on this type of product. Allergen information on non-prepacked food can be communicated through a variety of means – for example via allergen-trained staff – to suit the food business operator.
While detailed allergen labelling on unwrapped products may not be practical for smaller bakeries, it is essential to ensure there is signposting to where this information can be found. Given the practical difficulties some bakeries may face in displaying accurate allergen information, customers should also be able to obtain information for non-prepacked food from a designated and trained member of staff, whose availability must be displayed via a written notice, menu or label, clearly visible at the point where the food is chosen.
Signage indicating allergen information, available on request, is widely used and encourages consumers to manage their food, as well as satisfying your legal requirements.
If a customer with an allergy asks about the ingredients in a food, never guess. If you don’t know, try to find out and if you are unable to provide the information, say so. Ensure all relevant staff know the ingredients in your food and are advised of any changes or ingredient substitutions so they are up to speed with offering alternatives. If you use part pre-prepared ingredients – a ready-prepared sandwich mix for example – make sure you know what is in them.
Just as staff get food hygiene training from the first day in the job, they should receive training on handling allergy information requests. There should be an agreed practice for dealing with requests and all staff should have easy access to ingredients information.