Natasha's Law Update: July 2020

What is “Natasha’s Law”

The Food Information (Amendment) (England) Regulations 2019 will come into force in the UK in October 2021. The new regulations require pre-packed for direct sale items (e.g. filled sandwiches) to have a label which clearly shows:

• Name of the food
• Full ingredients list
• Allergenic ingredients emphasised (for example in bold, italics or a different colour)

However, a number of aspects of this were not initially clear. Following a consultation period, the Food Standards Agency published their technical guidance in June 2020 (was originally expected October 2019). This adds some clarification on the following questions:

What is the definition of pre-packed for direct sale? i.e. to which types of sales item will the new legislation apply?

How is the full ingredients list to be constructed? i.e. exactly what information needs to be sourced, maintained, and displayed or printed for these products?

FSA Technical Guidance i.e. what enforcement guidance will be given to Operators and Trading Standards officers

Fourth's Product team, alongside digital publishing and label-printing partner Ten Kites have explored a number of possible solutions which address the expected requirements. Based on what we think we know, the solution might comprise the following elements:

• An ingredient-level “ingredients list” property - with allergenic ingredients indicated - to be provided by the supplier for every bought-in ingredient.
• A recipe-level “full ingredients list” property, compiled automatically by Fourth according to defined business rules (similar to intolerance, nutrition, and costings calculations today)
• Auditing of all changes
• The full ingredient list for each dish - with allergenic ingredients indicated - to be available to customer or third-party printing/display solutions via the Fourth API

Before we begin development on the solution, we need to gather customer feedback on our proposal.  If you would like to participate in an upcoming workshop devoted to this topic please contact your Customer Manager.