Allergen Labelling Requirements: Warning - May Contain Penalties

Author:Mr Huw Morris
Profession:Reed Smith

Christmas is already a busy time for the food and catering industries but, in addition to this, the government has enacted new provisions regarding food labelling, which entered force on 13 December this year.

The Food Information Regulations 2014 (the Regulations) implement changes required by the EU Food Information Regulation 1169/2011 and their main focus is to standardise allergy information and labelling. While these represent only minor changes for those organisations which already adhere to the 1996 UK food labelling regulations, those that have not had to adhere to them before, such as small and previously exempt producers and those who sell unpackaged food, may be more drastically affected.

Application The Regulations have widened the scope of food labelling requirements to new areas, making it clear that they now apply to "any food intended for supply to the final consumer or to mass caterers". This includes all parties in the food supply chain, from raw material purveyors to wholesalers and restaurants, as well as all catering services where dispatch or departure takes place in the EU, such as airlines and cruise operators.

Allergens The Regulations' new labelling requirements are in relation to 14 key allergens. These are:

Eggs Milk Shellfish Molluscs Fish Peanuts Sesame Soya Sulphur dioxide Nuts Cereals containing gluten Celery Mustard Lupin Allergen Labelling The labelling requirements distinguish between food products that are supplied packed or unpacked.

Packed - e.g. food sold in sealed bags, boxes, bottles etc. where the product is delivered to an off-site location or sold via a wholesaler Unpacked - open food for sale (e.g. restaurants) but also packed on-site (e.g. at the customer's request or for take-away); where food is prepared, packed and sold on-site, this will count as unpacked. Packed food sold to the end user requires full labelling information. Products must list all allergens that are present in highlighted text in the list of ingredients, which must be...

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