Allergen Labelling Changes for Prepacked for Direct Sale (PPDS) Food

From 1 October 2021, the requirements for prepacked for direct sale (PPDS) food labelling will change. The new labelling will help protect consumers by providing potentially life-saving allergen information on the packaging.

Any food business that produces PPDS food will be required to label it with the name of the food and a full ingredients list. Allergenic ingredients must be emphasised within this list.

What is PPDS food?

Prepacked for direct sale or PPDS is food which is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected.

It can include food that consumers select themselves (e.g. from a display unit), as well as products kept behind a counter and some food sold at mobile outlets.

Food that isn’t PPDS

• Any food that is not in packaging or is packaged after being ordered by the consumer. These are types of non-prepacked food and do not require a label with name, ingredients and allergens emphasised. Allergen information must still be provided but this can be done through other means, including orally.
  
  
• Food packed by one business and supplied to another business. This is prepacked food and already must have full labelling, including the name of the food and a full ingredients list, with allergenic ingredients emphasised within it.

Distance Selling

The new labelling requirements do not apply to PPDS food sold by means of distance selling, such as food that can be purchased over the phone or on the internet.

Businesses selling PPDS food this way will need to ensure that mandatory allergen information is available to the consumer before they purchase the product and also at the moment of delivery.

You must provide allergen information:

• Before the purchase of the food is completed – this can be in writing (on a website, catalogue or menu) or orally (by phone)
• When the food is delivered – this can be in writing (allergen stickers on food or an enclosed copy of a menu) or orally (by phone)

Allergen information should be available to a customer in written form at a point between a customer placing the order and taking delivery of it.

Takeaway meals should be labelled clearly so customers know which dishes are suitable for those with an allergy.

Examples of PPDS food

Prepacked for direct sale (PPDS) food can include the following:

• Sandwiches and bakery products which are packed on site before a consumer selects or orders them
• Fast food packed before it is ordered, such as a burger under a hot lamp where the food cannot be altered without opening the packaging
• Products which are pre-packaged on site ready for sale, such as pizzas, rotisserie chicken, salads and pasta pots
• Burgers and sausages pre-packaged by a butcher on the premises ready for sale to consumers
• Samples of cookies given to consumers for free which were packed on site
• Foods packaged and then sold elsewhere by the same operator at a market stall or mobile site
• PPDS food provided in schools, care homes or hospitals and other similar settings will also require labelling

Specific examples of PPDS food for food businesses can be found in the relevant guidance.

What needs to be on the label?

The label needs to show the name of the food and the ingredients list with the 14 allergens required to be declared by law emphasised within it.

These need to be in line with the legal requirements that apply to naming the food and listing ingredients.

Why are the changes to allergen information being introduced?

At present, the allergen information for these products can be provided by any means. This includes information being informed verbally by staff.

Governments across the UK have decided that these foods will need to have ingredient and allergen information provided on the label from 1 October 2021. This follows the death of Natasha Ednan-Laperouse, who had an allergic reaction caused by a baguette which did not require allergen labelling at the time.

The Environmental Health team are available to provide advice to businesses who think they may be affected by these changes and can be contacted on +44 1624 685894 or via e-mail: ehenquiries@gov.im