IFST has responded to FSA’s consultation on amending allergen information provisions contained within UK domestic food information legislation for food prepacked for direct sale.
IFST believes that policy and legislation must result in a step change in consumer protection, characterised by clarity, simplicity, consistency and enforceability. The definition of PPDS should include pre-prepared foods that are only partially packed, and food prepared and packed on the sales premises at the consumer's request. Since teenagers and young adults typically communicate and interact via modern technology, all aspects of allergen labelling and information transfer should be ‘future-proofed’ in line with innovation.
IFST responded that a combination of the proposed options would be preferable. These include additional activities to promote best practice, and mandatory ‘ask the staff’ labels, clarifying that the product is prepacked and not fully labelled, and hence written supporting allergen information should be obtained from staff. The proposed requirement for PPDS foods to have a label on the packaging to tell the consumer which of the 14 allergenic ingredients (re FIC Annex II) they intentionally contain, is also a possibility, if it addresses last-minute ingredient substitutions and does not discourage dialogue about food allergies.
IFST responded that understanding the differences between fatal and non-fatal incidents is beneficial for the food industry, allergic consumers and the wider public, highlighting that consumer concerns should be captured, reviewed and actioned on, as lessons should always be learned.