Operators with complex supply chains are running out of time to implement the new allergen labelling rules for pre-packed for direct sale (PPDS) food by the 1 October deadline.
In an Allergens Webinar organised by The Caterer on 31 March and sponsored by Nutritics, industry experts discussed the challenges facing operators who are having to change their processes when it comes to ingredient labelling in the coming months.
To comply with the upcoming Natasha's Law, operators must label all PPDS food with full ingredients, with allergenic ingredients emphasised within the list. But operators with complex supply chains may find gathering the required information in time difficult if they don't begin the process immediately.
Rachel Ward, scientific policy director at Institute of Food Science & Technology, said operators needed to receive the information from their suppliers in a sufficient level of detail to allow operators to confidently write the label highlighting any allergens from a list of 14. "'Spices' won't tell you if there's mustard or celery in there," she said.
Ward added that operators need to think about this as a simple step-by-step process: "Know what you buy, know what you make, and declare it. The complexity comes when you have 3,000 suppliers, 25 sites and a menu that changes every day."
Stephen Nolan, managing director of recipe management and food labelling software provider Nutritics, agreed, saying a complex supply chain is a "big red flag".
He said: "There is six months left, but as you get into more detailed supply chains, that's when time is really running out."
Planning early is key. Amy Roberts, managing director of operations at contract education caterer Holroyd Howe said operators need to get the right processes in place and not rush. Roberts and her team are beginning small trials at a group of their schools from 19 April. "None of the information of the labels will be shared until we are 100% confident the data is correct and we have 150 schools we need to have ready before 1 October," she explained.
But Nolan warned that operators can't be so focused on the 1 October deadline that they forget that this is an ongoing change to everyday processes. He said: "It's also about the 2nd and 3rd of October, and getting into Christmas – what happens when substitutions come in a Christmas sandwich?"
Ward said operators need to ensure they implement a change management principle: "If you swap from one dressing supplier to another and the new one contains mustard, you've got the information about what you buy, you'll always be able to label it correctly in what you are selling."
She added: "Everything you buy comes down a little checklist, find what works for you – it doesn't have to be fancy – but the more data you get it might be helpful to put it into some sort of system. And it doesn't matter if it's handwritten, clearly legible and allergens highlighted, you'll be protecting your guests and providing them the information they need to make a safe choice."
Nolan added: "If you put the work in the compliance piece is actually very achievable – it's a fear of the unknown, but once you get into it it's actually straight forward and various ways through the process where it can be automated, from the way you get the information from suppliers, or the way you print the label."