Labelling: a matter of life and death

March 11, 2019 6:19 am Published by Leave your thoughts

This month, we’re looking at food labelling. It’s an issue that featured prominently in the news in 2018, following the death of a young woman, Natasha Ednan-Laperouse, who had a severe allergy to sesame seeds. Natasha ate a baguette that contained sesame seeds but which hadn’t been labelled as such – and while the labelling technically met legal requirements, her death highlighted the fact that loopholes in these requirements can have tragic consequences.

Do you understand allergen labelling rules?

Safe to eat?

Today, we’re going to take a look at the rules for allergen labelling. We’re also going to note the current gluten-free labelling requirements, pointing out which bits have recently changed. If you’re allergic to a particular ingredient – or intolerant – are you sure you know how to understand the labels you see?

Allergy labelling rules

Our allergy labelling rules in the UK are derived from EU requirements. Food allergens used as ‘ingredients or processing aids’ must be declared on the packaging or at the point of sale. For pre-packaged food, the information must be given on the packaging; in places where food is prepared on the premises, the information may be given orally. It was this distinction that caused Natasha’s death: she purchased a baguette which she assumed was pre-packaged. It had in fact been prepared on the premises of the Pret a Manger concession at which she bought it and therefore was not obliged to list allergens on the wrapping.

There are 14 allergens that must be declared. These are:

  • Cereals containing gluten
  • Crustaceans
  • Eggs
  • Fish
  • Peanuts
  • Soybeans
  • Milk (including lactose)
  • Nuts
  • Celery (including celeriac)
  • Mustard
  • Sesame
  • Sulphur dioxide/sulphites, where added and at a level above 10mg/kg or 10mg/litre in the finished product. (Sulphur dioxide is frequently used as a preservative in non-organic dried fruit.)
  • Lupin, including lupin seeds and flour
  • Molluscs

If a food contains ‘allergenic ingredients’, these must be declared ‘with a clear reference to the allergen’. For instance:

  • tofu (soya)
  • tahini paste (sesame)
  • whey (milk)

Allergens can be indicated on a label in a number of ways, such as by listing them in bold or in a different colour or by underlining them.

If there is a risk of cross-contamination from an allergen, a food product label should include a statement indicating this, for instance:

  • ‘may contain X’
  • ‘not suitable for someone with X allergy’.

Is the law changing?

Following the recent publicity about Natasha’s death, it seems likely that the law on allergen labelling will change.

‘The onus should not be on the consumer to hunt for allergy information’ said Tina Patel, from the legal team representing Natasha’s family. Many customers will be unaware whether food for sale in a shop has been pre-packaged or prepared on the premises – many shops, of course, will sell a mixture of such foods. Tina argues that ‘Natasha’s Law’ is needed, closing up the distinction:

‘A relatively straightforward solution might be to require food businesses which offer food for sale in any type of packaging (regardless of where the food is prepared) to include allergen information on a label secured to the packaging. Of course, even without legislative change food retailers could elect to include labels on all products which are packaged up for sale.’


In the meantime, those suffering from allergies should take every step in their power to ascertain whether a product contains allergens. Following Natasha’s death, many Pret a Manger customers reported that they used their phones to google ingredients, rather than relying on asking staff in the shops themselves.

How do we manage at NGF?

All our pre-packaged food meets the legal requirements. For the food we package ourselves, the labels show what the package contains (‘soybeans’, ‘peanuts’, ‘sesame’ and so on) and we indicate on every label that our packing environment is one in which nuts, gluten and sesame are handled.

Free from labelling

We don’t pack any ‘free from’ food ourselves at Naturally Good Food, because we are unable to guarantee that there has been no cross-contamination. We do stock a great range of ‘free from’ pre-packaged food, however, which is prepared in non-contaminated environments elsewhere. To be labelled ‘free from’, food must be rigorously tested and meet very specific requirements.

Gluten-free labelling

This is most relevant to our customers as it affects gluten-free food. New rules regarding the labelling of gluten-free food came into effect in February 2018 in the UK. They’re now known as the Gluten in Food (Information for Consumers) (England) Regulations 2016, with equivalent measures for the other parts of the UK.

To be labelled ‘gluten free’ under the Regulations, the level of gluten in a foodstuff must be tested and found to be no more than 20 ppm (parts per million).

Certain foods may be labelled ‘very low gluten’ if they contain cereal ingredients that have been specially processed to remove the gluten. The level permitted for these foods is higher than for ‘gluten-free’, at 100 parts per million of gluten or less.

Things become slightly more tricky when we consider ‘no gluten-containing ingredients’ foods (NGCI for short). If you’re a producer of tinned tomatoes, you’re probably not interested in testing for gluten, so can’t officially declare your product ‘gluten free’. If you’re a caterer producing a gluten-free cottage pie, but in an area that handles wheat flour, you can’t call the pie ‘gluten-free’, as it may have been contaminated. As with the producer of tinned tomatoes, however, you’d like to be able to say that your product has ‘no gluten-containing ingredients’. Can you do so?

Under the new rules, ‘NGCI’ cannot be used as a term to label individual products on a supermarket shelf or individual dishes on a menu. You might still see the NGCI term used, however, as a kind of ‘group description’ on a menu, on an overhead sign in a supermarket, as a category or filter in an online shop, or as a section in a food catalogue. In these instances, it will indicate that all the items in question do not have gluten-containing ingredients.

This blog explains it all further:

‘NGCI cannot be attributed to a single dish e.g. cottage pie (NGCI). However, if you have a menu with sections listing starters, main courses and desserts, a section on NGCI choices is permissible. It is also acceptable to use NGCI in menu titles provided that all the items do not use gluten containing ingredients, such as “No gluten containing ingredients menu” or statements such as “All dishes on this menu do not use gluten containing ingredients”.’

Accompanying terms

The Regulations also specify the kind of accompanying descriptions that can be used, and how these may be applied. The Food Standards Agency UK explains:

‘the Regulation specifies that food businesses using the terms ‘gluten-free’ and ‘very low gluten’ can  accompany those terms with ‘suitable for people intolerant to gluten’ or ‘suitable for coeliacs’. Or, if the food has been specially produced, prepared and/or processed to:

  • reduce the gluten content of one or more gluten-containing ingredients; or
  • substitute the gluten-containing ingredients with other ingredients naturally free of gluten,

food businesses may include the additional statement ‘specifically formulated for people intolerant to gluten’ or ‘specifically formulated for coeliacs’.’

Labelling matters

Labelling is a difficult issue, and it’s something that continues to evolve. It’s recognised as a very important matter: it prevents misleading claims being made, it promotes the production of high-quality food through rigorous testing regimes and stringent legal requirements, and it allows customers to make an informed choice.

At times, it’s also, quite literally, a matter of life and death. If you have allergies or intolerances, keep an eye on the changing law, as well as on labels themselves.

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This post was written by Yzanne

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