Natasha’s Law

  • Published 10th Feb 21
  • Categories Blog

New Food Labelling Requirements

The new allergen labelling rules, which are now enshrined in legislation in England, Wales and Northern Ireland, will come into effect from 1 October 2021. The new allergen labelling requirements will apply to a category of food called pre-packed for direct sale.

This is food which is packaged at the same place that it is offered for sale to consumers. This will apply to food that is in the packaging before it is ordered or selected. It can include food that customers select themselves, as well as pre-wrapped products kept behind a counter and some hot foods.

Why the changes to allergen information are being introduced

At present the allergen information for these products can be provided by any means, this includes being informed verbally by staff. Currently the onus is on the consumer to ask, or be guided by packaging, and they would not know the difference between food packed on site or in a factory. So now this brings the way allergen information is provided in line with other pre-packed food and reduces consumer confusion.

Governments across the UK have decided that these foods will need to have full ingredient and allergen information provided on the label.

Pre-packed for direct sale foods (PPDS)

Pre-packed for direct sale food is determined by three criteria:

  • when it is packaged
  • where it is packaged
  • how it is packaged

Each of these criteria has to be met for food to be classed as pre-packed for direct sale and for the new labelling requirements to apply.

Spotlight On Allergens


Eggs are one of the most common foods to trigger allergic symptoms in babies and young children. Most children with an egg allergy will start to outgrow it by the time they go to school. In some cases it will persist into later childhood or in rare cases, adulthood. Egg allergy can occasionally develop in adult life.

Reactions to egg are usually triggered by the protein part of the egg (mainly in the egg white). Babies who have eczema are at an increased likelihood of developing an egg allergy. Having another type of food allergy, for example to cow’s milk or a family history of allergy (atopy), also increases the risk.

Let them eat cake”

Some people with an egg allergy can eat egg that has been well cooked (e.g. egg as an ingredient in a cake) and will only develop allergic symptoms if they eat loosely cooked egg (e.g. scrambled egg) or raw egg (e.g. fresh mayonnaise or chocolate mousse).

This is because the structure of the egg protein is changed by heat from cooking which makes it less likely to cause allergic symptoms. Around 80% of people with an egg allergy can tolerate a well baked egg in a cake.

Therefore not all people with an egg allergy need to avoid all forms of egg and this should be decided on an individual basis.

It is easy to avoid eggs that are served on their own when they look like an egg; however they are often hidden in prepared and manufactured foods so beware…

Avoid foods that contain eggs or any of these ingredients:

  • Egg (dried, powdered, solids, white, yolk)
  • Lysozyme (enzyme in egg white)
  • Mayonnaise
  • Meringue (meringue powder)
  • Ovalbumin (protein in egg white)
  • Surimi

Eggs are sometimes found in the following:

  • Baked goods (although some people can tolerate these foods)
  • Egg substitutes
  • Ice cream
  • Lecithin (fat in egg yolks)
  • Marzipan
  • Marshmallows
  • Nougat

Egg free cooking:

Baking powder helps a recipe rise, but it’s usually the egg that’s used to bind the ingredients together – pureed apple, mashed banana and beetroot are just some examples of binding agents that can be used instead of eggs. Chia seeds, flax and chick pea water (aqua faba) are some other very useful egg replacers that will help you add more variety into your egg free recipes.

Strange but true –

In an odd clause to the FIR where the name of the product consists of a single ingredient (e.g. a box of eggs), further indication of the presence of the product is not required. Therefore a box of eggs would not need to declare the presence of egg.


The lupin is well-known as a popular garden flower with its tall, colourful spikes. The seeds from certain lupin species are also cultivated as food and classed as a legume. It is more frequently consumed and used in the Mediterranean, especially in the form of lupin flour. Lupin allergy can present in both peanut-allergic and non-peanut-allergic patients. Because lupin and peanut belong to the legume family, there is known cross-reactivity.

What products may contain lupin?

  • Lupin beans may be eaten whole, boiled or dry and are a common snack in European and Asian countries.
  • Lupin beans can be ground into flour or bran and used to add fibre, texture, and protein in food manufacturing.
  • Lupin is gluten-free and may be found in gluten-free products as a substitute for wheat. Beverages may also contain lupin as a milk or soy alternative.
  • Lupin may be found in products such as pasta, chocolate spreads, vegetarian sausage, sauces, stews, baked onion rings, salads, lupin hummus spreads, ice creams, antipasto, bread, rolls, biscuits and baked goods (e.g. cookies, cakes).
  • Lupin may be used as a soy substitute in products
  • Lupin flour may also be mixed with other flours

Lupin is sometimes labelled as lupine, lupin flour, lupin seed or lupin bean. By law, the presence of lupin in pre-packed foods must always be declared and highlighted in the ingredient list (for example, in bold). If you are allergic to lupin, it’s vital to read ingredient labels every time you buy a product.

Although we believe lupin to be present in only a minority of products manufactured in the UK, it can be found in European bakery and pasta products, some of which are imported to the UK.

These bakery products include:

  • Pastry cases
  • Pies
  • Waffles
  • Pancakes
  • Crepe
  • Products containing crumb
  • Pizzas
  • Deep-coated vegetables such as onion rings
  • Some vegan products – where lupin is a substitute for milk
  • Some gluten free products

One particular case was highlighted in the Lancet medical journal in 2005. A 25-year-old woman was taken to hospital because of severe anaphylaxis following a restaurant meal of chicken, French-fried potatoes, and onion rings. The onion rings were found to have been made in the UK using a batter mix made in Holland and containing unlabelled lupin flour.

Coming up next month…

We detail the differences between PPDS and ‘over the counter’ sales and how this affects schools.

In our ‘Spotlight on Allergens’ feature we will focus on the allergens Fish and Mustard, the foods that are most likely to contain them and the possible alternatives available.

If you are concerned what Natasha’s Law means for you – exactly what information your food labelling should now include along with the costs, logistics and man hours of updating allergen information on packs, then look out for our monthly blog.

Need help with your allergen compliance?

CMC can give you advice and support on all aspects of your food safety in school.

Contact us today to see how we can help you.
01254 351887

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