Food Allergy and Intolerance

Online Training
Module 2 Transcript

Providing accurate allergen information

for prepacked and non-prepacked food
Module 2 Transcript

Contents

Lesson 1: Introduction 3
Module objectives 3
Lesson 2: Food information legislation 3
Food information provisions 3
The 14 allergens 4
Food additives and processing aids 4
Omission of the list of ingredients 5
Lesson 3: Prepacked and non-prepacked food 5
Prepacked food 5
Allergen information for prepacked food 5
Non-prepacked food 6
Allergen information for non-prepacked foods 6
Prepacked for direct sale (PPDS) 8
Identifying what PPDS food is 9
Allergen information for PPDS food 9
Lesson 4: Distance selling 10
Lesson 5: Unassessed quiz 10
Lesson 6: Summary 11
Module 2 Assessment 11

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Module 2 Transcript

Lesson 1: Introduction
This module addresses the requirements for Food Business Operators (FBOs) in
providing allergen information to consumers.
Any business that manufactures or supplies food must make sure that the food they
provide is safe to eat. The labelling and information that is provided on the food,
including the setting in which the food is displayed, must not mislead consumers.
Food must also not be provided or sold if it is unsafe (injurious to health or unfit for
human consumption).

Module objectives
After working through this module, you will be able to:

• identify which legislation underpins food information provisions

• identify the main 14 allergens which consumers must be informed about
• understand how information about allergens should be communicated to
consumers for both prepacked and non-prepacked foods

Lesson 2: Food information legislation

Food information provisions

The EU Food Information to Consumers Regulation (EU FIC), introduced in
December 2014, sets out the way allergen information must be provided to
consumers. The EU FIC is enforced by local authorities under the Food Information
Regulations 2014 (FIR).
The Food Standards Agency (FSA) is responsible for food safety and food hygiene in
England, Wales and Northern Ireland. However, local authorities are responsible for
monitoring and enforcing food safety regulations in their local area, to ensure that
standards are met.
Food businesses must follow the allergen information rules, which are set out in
Regulation (EU) No. 1169/2011 on the provision of Food Information to Consumers
(EU FIC).

This means FBOs must:

• provide allergen information to the consumer for both prepacked and non-
prepacked food and drink
• handle and manage food allergens adequately

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The 14 allergens
Food businesses must tell their customers if any food they sell or provide contains
any of the main 14 allergens as an ingredient. Throughout the training, the ‘main 14
allergens’ will be referred to as such or as ‘allergens’.
The main 14 allergens (as listed in Annex II of the EU FIC) are:

• cereals containing gluten, namely wheat (such as spelt and Khorasan wheat),
rye, barley and oats
• crustaceans
• egg
• fish
• peanuts
• soybeans
• milk
• nuts (namely almond, hazelnut, walnut, cashew, pecan nut, Brazil nut,
pistachio nut and macadamia nut (Queensland nut))
• celery
• mustard
• sesame seeds
• sulphur dioxide and/ or sulphites (if they are at concentrations of more than 10
parts per million)
• lupin
• molluscs
Consumers may be allergic or have intolerance to other ingredients, but only these
14 substances are required to be declared as allergens by food law.
For further information on the main 14 allergens, including exceptions, see Annex II
of the EU FIC or the FSA Technical Guidance.

Food additives and processing aids

The allergen information rules apply to the main 14 allergens listed in Annex II which
are used as food additives or processing aids and are still present in the final product.
Processing aids and food additives are substances which are not consumed as a food
but are intentionally used in food production to perform a technological purpose either
directly in the food, or during its treatment and processing.

For example, sulphites, which are often used to preserve dried fruit, might still be
present after the fruit is used to make chutney.

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Omission of the list of ingredients

There is no need for an additional allergen declaration for food consisting of a single
ingredient where the name of the food is identical to the ingredient name; or the
name of the food enables the nature of the ingredient to be clearly identified. For
example, a box of eggs or a bag of peanuts.
However, where the name of the food is less familiar, allergen information must be
provided. For example, gingelly oil is sesame oil. Therefore, it must be labelled
‘contains sesame’.

Lesson 3: Prepacked and non-prepacked food

While allergen information is always required, the way in which it must be
communicated to consumers differs between prepacked and non-prepacked food.

Prepacked food
Food is considered prepacked when it is put into packaging before being offered for
sale and:

• is either fully or partly enclosed by the packaging

• cannot be altered without opening or changing the packaging
• is ready for sale to the final consumer or mass caterer

Examples

Most prepacked foods are sold in retail outlets such as supermarkets. Examples of
these include tinned food, ready-made meals and frozen food products.

Allergen information for prepacked food

With some exceptions (see Module 4 - providing accurate allergen information for
prepacked and non-prepacked food, for more details of these) prepacked food must
have an ingredients list which can be identified by a suitable heading and includes
the word ‘ingredients'. Any of the 14 allergens must be emphasised in a way that
clearly distinguishes these from the rest of the ingredients every time they appear in
the ingredients list. For example, allergens can be highlighted in bold.

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Non-prepacked food
Non-prepacked foods include:

• foods sold loose in retail outlets

• foods which are not sold prepacked, such as meals served in a restaurant and
food from a takeaway
• prepacked for direct sale food (PPDS), such as sandwiches placed into
packaging by the food business and sold from the same premises
• food packed on the sale's premises at the consumers’ request, such as
a sandwich prepared in front of the consumer

Note

From 1 October 2021 PPDS food will require the name of the food and a full
ingredients list with the allergens emphasised.

Examples

• In a retail environment, non-prepacked food includes food which is sold loose

from a deli counter (such as cold meats, cheeses, quiches, pies and dips),
fresh pizza, fish, salad from a salad bar, bread sold in bakery shops, etc.
• In a catering environment, non-prepacked food includes food ready for
consumption such as meals served in a restaurant, café or purchased from a
takeaway.

Allergen information for non-prepacked foods

• Allergen information must be provided for each food that contains any of the
14 allergens.

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• Allergen information may be provided by any means the FBO chooses, for
example, in writing or orally.
• There must be clear signposting to where consumers can obtain this
information, when it is not provided upfront.
Example of written format

Example of signposting to obtain oral information

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Module 2 Transcript

Prepacked for direct sale (PPDS)

PPDS food is food that is packed before being offered for sale by the same food
business to the final consumer:

• on the same premises

• on the same site
• on other premises if the food is offered for sale from a moveable and/or
temporary premises (such as marquees, market stalls, mobile sales vehicles)
and the food is offered for sale by the same food business who packed it

Note

In this instance ‘site’ refers to a building complex such as a shopping centre or airport
terminal in which the same food business operates from more than one unit within
the building complex.
Any food that is packed on the premises by the same food business in anticipation of
an order, before being offered for sale, would be considered to be PPDS food. This
can include food the consumer self-selects from a chiller cabinet or has to obtain
from a member of staff.

Examples

• sandwiches placed into packaging by the food business and sold from the
same premises
• a cafe giving away packaged samples of a new range of cakes they have
made on the same premises
• foods packaged and then taken by the same operator to their market stall to
sell
• a butcher who makes burgers or sausages which are prepacked to be sold on
the same premises

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Identifying what PPDS food is

For a food to be PPDS, it must meet all of the following criteria:

1. Is the food presented to the consumer in packaging*?

• Yes - the food is ‘prepacked’

• No - this is non-prepacked food

2. Is it packaged before the consumer selects or orders it?

• Yes - the food is ‘prepacked’

• No - this is non-prepacked food

3. Is it packaged at the same place** it is sold?

• Yes - the food is ‘prepacked for direct sale’

• No - this is pre-packed food

If the answers to all three questions above are yes, the food is PPDS.

Notes:
* A single item (the food and its packaging) presented to the consumer. The food is
completely or partially enclosed and cannot be altered without opening or changing
the packaging. Foods in such packaging sold to other businesses are prepacked
food and already require allergen labelling. (See Article 2(2)(e) of the FIC)
** Food (a) packaged by the same food business on the same site from which it is
sold or (b) sold from temporary or moveable premises (such as a food truck or
market stall) by the same food business that packaged it.

Allergen information for PPDS food

Currently prepacked for direct sale (PPDS) products can provide allergen information
in the same way as for non-prepacked foods. However, this will change.
From 1 October 2021, PPDS food will need to display, on its packaging or on a label
attached to it, the name of the food and a list of ingredients with any of the 14
allergens emphasised. This change will only affect PPDS food.
A detailed explanation of the allergen information requirements, including how food
must be labelled, can be found in our technical guidance. Module 4 – Providing
accurate allergen information for prepacked and non-prepacked food, will also cover
these requirements in more detail.

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Module 2 Transcript

Lesson 4: Distance selling

Allergen information must be provided if food is sold through distance selling (for
example online or by phone). This must be done at two stages in the process:

• before the purchase of the food is completed - this could be in writing (for
example, on a website, catalogue or menu) or orally (for example, by phone)
• the moment the food is delivered - this could be in writing (for example, on
allergen stickers on food or enclosed hard copy of menu) or orally (for
example, by phone)
As best practice, the allergen information should be available to a customer in a
written form at some point between a customer placing the order and receiving the
delivery.
Takeaway meals should be labelled clearly so customers know which dishes are
suitable for those with an allergy.
For more information on allergen information rules, see the allergen guidance for
food businesses on the FSA website.

Lesson 5: Unassessed quiz

You can complete the assessment when you are ready. If you wish, you can test
your knowledge by completing this short unassessed quiz first.
If you have any difficulties in completing this, it is recommended that you review the
session.

Quiz question 1
Which of the following does not need to be declared as allergen under the
regulations?
Select one answer:
1. Hazelnut
2. Coconut
3. Almond
4. Walnut
Take a moment to think about it.
The correct answers is 2: Coconut

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Quiz question 2
Which of these is not on the list of the main 14 allergens?
Select one answer:
1. Peanuts
2. Sesame seeds
3. Ginger
Take a moment to think about it.
The correct answer is 3: Ginger

Quiz question 3
Which of these answers refers to prepacked food?
Select one answer:
1. Any food put into packaging before being placed for sale
2. Any food put into packaging after being sold
Take a moment to think about it.
The correct answer is 1: Any food put into packaging before being placed for sale

Lesson 6: Summary
This module has looked at the different requirements for providing allergen
information to consumers.
You should now be able to:

• identify which legislation underpins food information provisions

• identify the main 14 allergens which consumers must be informed about
• understand how information about allergens should be communicated to
consumers for both prepacked and non-prepacked foods
If you are unsure about any of these areas, go back and reread the relevant
section(s) of this module.

Module 2 Assessment
Now that you have finished this module you can complete the assessment for
Module 2 when you are ready by returning to the main course menu.

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Module 2 Transcript

The 14 allergens
Food businesses must tell their customers if any food they sell or provide contains
any of the main 14 allergens as an ingredient. Throughout the training, the ‘main 14
allergens’ will be referred to as such or as ‘allergens’.
The main 14 allergens (as listed in Annex II of the EU FIC) are:

• cereals containing gluten, namely wheat (such as spelt and Khorasan wheat),
rye, barley and oats
• crustaceans
• egg
• fish
• peanuts
• soybeans
• milk
• nuts (namely almond, hazelnut, walnut, cashew, pecan nut, Brazil nut,
pistachio nut and macadamia nut (Queensland nut))
• celery
• mustard
• sesame seeds
• sulphur dioxide and/ or sulphites (if they are at concentrations of more than 10
parts per million)
• lupin
• molluscs
Consumers may be allergic or have intolerance to other ingredients, but only these
14 substances are required to be declared as allergens by food law.
For further information on the main 14 allergens, including exceptions, see Annex II
of the EU FIC or the FSA Technical Guidance.

Food additives and processing aids

The allergen information rules apply to the main 14 allergens listed in Annex II which
are used as food additives or processing aids and are still present in the final product.
Processing aids and food additives are substances which are not consumed as a food
but are intentionally used in food production to perform a technological purpose either
directly in the food, or during its treatment and processing.

For example, sulphites, which are often used to preserve dried fruit, might still be
present after the fruit is used to make chutney.