Allergen Advice

Kafoodle was invited to contribute to an article around allergens by the publishers of Pizza, Pasta & Italian Food Magazine. Here is the article.

As of October 2021, all pre-packaged foods sold in foodservice outlets (that packed the food) will need to be labelled so that any allergens are clearly highlighted; the changing nature of the food business in recent times prompting businesses to act now.

ASSURED ADVICE FROM PAPA

A set of guidelines for labelling food to go products under the new Food Information regulations has been published by the Pizza Pasta & Italian Food Association (www.papa.org.uk - correct as of 13 May 2020).

These guidelines, which have Assured Advice status, have been designed to help member businesses comply with the regulations which in turn help operators to be able to provide more information to their consumers.

The Pizza Pasta & Italian Food Association agreed to take on a Statutory Primary Authority Role to represent its members and encourage consistent standards across the industry by providing Assured Advice on environmental health and trading standards issues.

Essentially, the Assured Advice Scheme means that issues directly affecting sandwich and food to go businesses can be dealt with consistently across the UK so that everyone is treated the same. By following the guidance PAPA produces under the scheme, all local enforcement officers (including environmental health and trading standards) must accept the procedures set out in that guidance.

On issues that affect the food to go industry as a whole, the Association will work with government agencies and its Primary Authority (Slough Borough Council) to produce and agree guidance for the industry which, once approved, becomes Assured Advice.

Under the Assured Advice scheme, this guidance must be respected by enforcement offi cers across the country and all members following that guidance are protected from being challenged on it. Furthermore, if members have any problems in relation to the advice, they can refer them to the Association who will take them up on their behalf.

The Labelling Guidelines that have been drawn up by the Association set out how current food labelling legislation should be applied by UK food to go businesses, and the scheme has the full backing of the Department of Business, Energy and Industrial Strategy (BEIS).

This guidance applies to the Food Information (Amendment)(England) Regulations 2019, and these guidelines apply to England only at this time (it is expected that the legislation will be replicated for the devolved nations in due course).

After 1 October 2021, all pre-packaged foods sold in foodservice outlets (that packed the food) will be required by law to be labelled with the name of the product and an ingredients list, with any allergens highlighted. This new legislation brings the foodservice sector closer in line with the requirements for packaged foods sold through retail outlets.

There are currently 14 allergens that are required by law to be listed, and these are ingredients which have been identified as causing illness, allergic reactions and in some cases severe illness and occasionally death.

• celery
• cereals containing gluten – including wheat, rye, barley and oats
• crustaceans – such as prawns, crabs and lobsters
• eggs
• fish
• lupin
• milk
• molluscs – such as mussels and oysters
• mustard
• tree nuts – including almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts
• peanuts
• sesame seeds
• soybeans
• sulphur dioxide and sulphites (if they are at a concentration of more than ten parts per million)

THE REGULATIONS

The new regulations amend the Food Information Regulations 2014 (FIR) which requires food businesses to adhere to Regulation (EU) No. 1169/2011 and ensure that all mandatory food allergen information is accurate, available and easily accessible to their customers.

Currently, foodservice businesses are able to provide this information in a number of ways, including orally on request, but are not required to print it on labels. From 1 October 2021 all foods that are pre-packed (except those that are loose and packed at the request of the customer) must be labelled with the name of the product and an ingredients list with any allergens highlighted clearly – emphasised, usually in bold lettering.

DELIVERED FOOD

The new rules do not alter the requirements for food that is sold remotely, such as via deliveries. In this case, if the order is placed remotely, such as via a website or telephone, the information about allergens must be provided at the point of purchase as well as being available at the moment of delivery.

In the case of websites, customers should be provided with ingredients including allergen information at the point they make the decision and before payment is made. In this case the only information that needs to be provided is the list of allergens as there is no requirement for an ingredient list for foods sold by distant selling.

Where orders are placed over the telephone, those taking the orders should have information about allergens they can refer to and should ask every customer if they have any intolerances and inform them of any allergens that the products they are ordering may contain.

In both the above cases, if there is any risk of cross contamination, this should also be made clear to customers.

In addition, the regulations also require that information about ingredients and allergens must also be available at moment of delivery. This can be done by labelling the product, on a menu that is delivered with the product, verbally by those making the deliveries or by providing a telephone number on the packaging that customers can call for the information.

In all the above cases, care must be taken to ensure that the information provided is accurate and the allergen information must be clearly linked to the individual product it relates to.

Details of PAPA’s full Assured Advice on Allergen Labelling (revised May 2020) can be found at https://www.papa.org.uk/index.php/assured-advice/701-assuredadvice-on-allergen-labelling

A NEW WAY OF OPERATING

Even before the re-opening date for the hospitality industry had been confirmed in the wake of Covid-19, food businesses up and down the country had been trying to prepare themselves for a new way of operating.

No-contact dining, pre-order, click and collect, and social distancing are all concepts that were almost unheard of just a few months ago, but these are fast becoming the new normal for many hospitality businesses now.

More and more food operators are either starting or expanding, their takeaway offerings, making the ‘food to go’ market one of the success stories of lockdown. The adoption of technology has played a vital role in how a business communicates and interacts with its community and customers, allowing them to set themselves apart and thrive in the current landscape.

TRUST AND TRANSPARENCY

Many businesses have been quick to adopt new technologies to support social distancing, whether it’s using click and collect software to reduce queues at busy times or communicating allergen information with their customers.

If customers with food allergies can see allergy information with the touch of a button, they can make safer and better informed choices and will be more likely to purchase something. Trust and transparency are key to getting this right.

Even the largest food companies face challenges with complying consistently with existing legislation and providing the right level of information that customers want and that keeps them safe. Small operators with limited time and resource find this even more challenging. However, this will only get more challenging as legislation and enforcement tightens, and consumer expectations and the level of allergy sufferers rise.

Whilst most businesses have been quick to adapt with regards to social distancing, the underlying issues have not gone away. Legislation and enforcement tighten, and consumer expectations and level of allergy sufferers rise, and for the most part, it is still difficult for foodservice businesses to obtain and maintain complete and accurate food data (some still work from printed Excel sheets).

Food operators now have a huge choice of digital solutions to choose from to enable them to operate with minimal or no-contact, but many do not consider the level of detailed allergen and ingredient information required to meet existing and future legal obligations with regards to allergen communication, i.e. at point of order, and point of delivery or collection.

FOOD SAFETY

Despite some of the focus shifting onto social distancing and keeping Covid-19 at bay, food safety is just as important now as it has ever been. And although many new businesses may have pivoted to a takeaway model, they still need to follow the FSA’s guidelines with regards to communicating allergens.

The FSA’s guidance states that if food is sold online or over the phone, allergen information must be provided at two stages of the ordering process:

• before the purchase of the food is completed - this could be on a website, or on a digital or printed menu or over the phone.
• when the food is delivered - this can be an allergen sticker on the box or an enclosed copy of a menu containing allergens, or over the phone.

Alongside current legislation, from 1 October 2021 ‘Natasha’s Law’ will come into effect, requiring food businesses that sell pre-packed directly for sale (PPDS) foods to have to include product labels providing the full ingredients contained, with allergenic ingredients emphasised within it. This will certainly be a challenge for many operators who struggle to meet existing legislation.

SINGLE SOURCE SOLUTION

Helping to meet these challenges is Kafoodle - a full kitchen management system as well as a robust click and collect system providing foodservice businesses with an integrated single source solution that is invaluable now, but essential for the future, feel its creators.

Recipes are created using supplier ingredient data, and then the ‘brain’ behind Kafoodle Kitchen does all the hard work by calculating the nutritional values, assigning allergens, and generating compliance labels. It can even work out per-serving costs allowing the businesses to improve compliance and operational policies, whilst still keeping an eye on costs, say the company.

Have a change to a recipe or an updated ingredient? Then simply enter the new details into Kafoodle, and it will recalculate the nutritional values, update allergen information and have updated labels ready to print at the click of a button. The digital menus that customers see will also automatically update in real time, making sure that they are always getting the correct information at the point of purchase, point out Kafoodle.

As well as ‘does contain’ allergy warnings, food outlets should also be able to inform customers of any risks of cross-contamination, feel Kafoodle’s creators - i.e. where a menu item ‘may contain’ an allergen as a result of operational processes.

Kafoodle enables food businesses to track and communicate ‘may contains’ as well as ‘does contains’, allowing customers to make a more informed decision about what they eat depending on their specific sensitivity.

TAILORED

The powerful food preference filtering within Kafoodle’s digital menus also helps to reinforce the customer’s trust by allowing them to filter the menus based on their individual needs and requirements. By selecting an allergen to avoid, or dietary preference, or even down to individual nutritional values (calories, fat, salt etc), for example, the customer can fine-tune the menu to only show what is appropriate for a truly personal and safe customer experience.

Kafoodle worked with the Metropolitan Pub Company (a division of Greene King) for the launch of their much anticipated click and collect service. Launched on 22 May (a Bank Holiday weekend), they saw an influx of orders over the first week which the Kafoodle system and the pubs themselves were able to handle expertly. The launch exceeded expectation and the planned roll-out to their wider estate has been brought forward; the chain is also expanding on their pub meals selection to also offer a grocery click and collect service for their local communities.

Kafoodle works with a wide range of customers, from small independent restaurants to national contract caterers and across hospitality, healthcare, education and corporate catering, supporting OCS, Havering Catering Service, Pizza Pilgrims, Kurbside Kitchen, Kalimera and The Vurger Co with all aspects of digital kitchen management and allergen control.

As a modular system, Kafoodle can be as streamlined or powerful as a business needs it to be. Starting with its Essentials package, for example, it can be set up in just a few hours and offers overnight payments (rather than weekly) so that the revenue can get to the business when it’s needed.

To read the full article please head over to Pizza, Pasta & Italian Food Magazine: https://www.pizzapastamagazine.co.uk/