Anaphylaxis Campaign

Supporting people at risk of severe allergies

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Consultation on allergen information on products pre-packed for direct sale

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Friday 25th January 2019

The Department for Environment Food & Rural Affairs have today opened a consultation on the proposed amendments to the domestic Food Information Regulations 2014 (FIR) (England) and parallel FIR regulations in Northern Ireland, Scotland and Wales relating to allergen information for foods that are prepacked for direct sale to the consumer on the same premises from which they are sold.

This timely review of allergen labelling legislation follows from the tragic death of Natasha Ednan-Laperouse who died after eating a baguette from Pret a Manger at Heathrow airport in July 2016. The coroner who presided over the inquest of Natasha Ednan-Laperouse concluded that the current legislation is not adequate and requested a review. The Anaphylaxis Campaign would like to say how fantastic Nadim and Tanya Ednan-Laperouse have been in raising the issues around food safety for all individuals with food allergy at this very difficult time for them personally.

The Anaphylaxis Campaign believes that food allergic individuals must be able to make informed decisions and to assess risk and self-manage their condition when eating out. We welcome the government’s consultation as a way of understanding the views of all stakeholders and arriving at the best approach for all stakeholders and, in particular, those who suffer with food allergies.

We hope all food business that sell food pre-packed for direct sale engage with this consultation to ensure that feasibility across all business sizes is taken into consideration. We also hope food allergic individuals actively take part in this consultation and share their views on how they want this incredibly important information shared with them.

What is the current legislation for a food business that makes and sells food on the same site?

At present when a food business sells prepacked food for direct sale the same regulations apply as to non-prepacked food under the EU Food Information for Consumers Regulation No. 1169/2011 commonly known as EU FIR 2014. This means food business preparing their products freshly on their premises are exempted from the obligation of labelling them with a list of ingredients including the provision of allergen information. This is because it is expected that the customer is able to speak with the person who made or packed the product to ask about ingredients. All mandatory allergen ingredients information (the 14) should be available and easily accessible for the consumer and this can be communicated through a variety of means to suit the business format of the food business operator.

What are the proposed options put forward in this consultation?

Policy option 1 – Promote best practice

Policy option 2 – Mandate “ask the staff” labels on packaging of food prepacked for direct sale, with supporting information for consumers in writing

Policy option 3 – Mandate name of the food and allergen labelling on packaging of food prepacked for direct sale

Policy option 4 – Mandate name of the food and full ingredient list labelling, with allergens emphasised, on packaging of food prepacked for direct sale

How to respond to the consultation

Please, first view and consider the consultation document, which explains the current legislation, the scope of the consultation and explains in detail the four different policy options. The document can be accessed here

Then provide your responses to the questions via an online survey, which can be accessed here

If you cannot respond online, you can request a copy of the survey and a response form by e-mailing [email protected] Queries and completed surveys can also be sent here.

Please respond by 29 March 2019

You can find out more information about this consultation on the Department for Environment Food & Rural Affairs website here and can view the impact assessments here.

If you are any enquires, please contact our helpline on: 01252 542029 or [email protected]

BSACI – Early Feeding Guidance

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The British Society for Allergy & Clinical Immunology ‘s Paediatric Allergy Group (PAG) and the Food Allergy Specialist Group (FASG) of the British Dietetic Association (BDA) have developed guidance for UK Healthcare Professionals on preventing food allergy in higher risk infants. This includes advice on the earlier introduction of potential allergenic foods into the infant diet to reduce the risk of food allergy.

This is guidance, not a guideline and is designed to provide practical advice on implementing the evidence available from the EAT, LEAP and other studies. The guidance complements the recent review and joint statement from the Scientific Advisory Committee on Nutrition (SACN) and the Committee on Toxicity of Chemicals in food, Consumer products and the Environment (cot) – “Assessing the health benefits and risks of the introduction of peanut and hen’s egg into the infant diet before six months of age in the UK, which acknowledge that targeted advice may be appropriate for infants at higher risk of developing food allergy.

The Early Feeding Guidance for Healthcare Professional can be accessed here.

A summary of the guidance can be accessed here.

SACN: Publication of report Feeding in the First Year of Life

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Scientific Advisory Committee on Nutrition (SACN) has published its report on ‘Feeding in the first year of life’, providing recommendations on infant feeding from birth up to 12 months of age.

The last review of infant feeding was undertaken by SACN’s predecessor Committee on Medical Aspects of Food Policy (COMA) in 1994 and formed the basis for government recommendations in the UK.

SACN recommends babies are exclusively breastfed until around 6 months of age and continue to be breastfed for at least the first year of life. Additionally, solid foods should not be introduced until around 6 months to benefit the child’s overall health. This represents no change to current government recommendations.

SACN has recommended strengthening advice regarding the introduction of peanuts and hen’s egg – advice on complementary feeding should state these foods can be introduced from around 6 months of age and need not be differentiated from other solid foods. The deliberate exclusion of peanuts or hen’s egg beyond 6 to 12 months of age may increase the risk of allergy to these foods.

The findings of the systematic review on the timing of introduction of a number of the major food allergens (milk, hen’s egg, fish, shellfish, tree nuts, wheat, peanuts and soya) and later risk of allergic and autoimmune disease (Ierodiakonou et al, 2016) which helped inform the decision;.

  • There was moderate quality evidence that early introduction of peanut (between 4 to 11 months) was associated with reduced risk of developing peanut allergy.
  • There was moderate quality evidence that early introduction of hen’s egg (between 4 to 6 months) was associated with reduced risk of developing hen’s egg allergy.
  • There was low quality evidence that early introduction of fish (before 6 to 12 months of age) was associated with reduced allergic rhinitis and very low quality evidence that fish introduction before 6 to 9 months was associated with reduced allergic sensitisation
  • There was no association between the timing of introduction of other allergenic foods and risk of food allergy or allergic sensitization

You can read the full report here.