Pre Packed for Direct Sale foods are those which are prepared and packed in the same premises from which they are sold. For example, a packaged sandwich or salad that has been made earlier in the day, wrapped then displayed in a fridge for sale, all in the same shop.
Participants in the consultation were asked their opinion on four options, each one increasingly detailed in nature. The options ranged from leaving things as they are now but investing in supporting businesses with implementing the legislation, to applying full ingredient labeling with allergens highlighted.
The results have now been shared and are somewhat surprising.
The FSA has concluded that the ‘ultimate goal’ should be for full ingredient labeling on PPDS foods to be mandatory, the last and most detailed option and in line with the views of allergic customers and consumer groups.
However, full ingredient labeling is being met with some opposition from hospitality industry stakeholders who believe the best way to keep consumers safe is to encourage them to talk to food businesses about food allergies instead of simply being told.
This difference in opinion highlights the difficulty in finding a solution. The food industry has a legal and moral responsibility to protect consumers, but the solution also needs to be practical and cost-effective in order to be accessible and maintainable.
Does full ingredient labeling increase the risk of incorrect ingredient labeling due to having to list every detail? Will consumer choice of food be reduced due to it being too time-consuming to fully list ingredients? Can food businesses, especially small businesses) financially afford to print accurate food labels? These are just some of the questions that have arisen with the proposed solution.
Additionally, full ingredient labeling does not prevent the risk of cross contamination of non-allergenic foods with allergens during preparation and other processes. Could adding full ingredient labeling stop consumers talking about food allergies with food businesses as they may well assume that the food item hasn’t come into cross contamination with an allergen?
The above are all issues that the FSA recognises. During the public board meeting confirming their decision, Chair Heather Hancock did re-iterate that full ingredient labeling isn’t the holy grail of solutions as:
· There are still issues regarding the content of food at supplier level
· It’s imperative staff are fully trained when it comes to allergens and should be confident when discussing allergens with consumers
· Funding will be needed to provide support to small businesses in implementation
It is encouraging that the FSA acknowledges that it will take time to work through a series of steps to get to the point of full ingredient labeling and that the route to get there will not be quick, with further consultation and assessment being required first. It will be interesting to see, further down the line, exactly how they anticipate getting food businesses from A to B.
Although the government is yet to decide whether or not to implement this recommended change, the FSA has openly encouraged the food industry to move forward with full ingredient labeling to PPDS foods now, should they feel able to, and to share their findings (including what goes wrong) with the FSA and the food industry.
Overall, the FSA’s decision will be very much welcomed by consumers with food allergies but it will be a challenge for some food businesses to implement, especially smaller ones. It is also important to remember that this is the FSA’s recommendation. It’s the government who will ultimately decide on what changes are made to the existing legislation, if any.