Evaluation of the implementation of prepacked for direct sale (PPDS) allergen labelling requirements Executive Summary - PPDS evaluation

The Food Standards Agency (FSA) and Food Standards Scotland (FSS) play an important role in ensuring members of the public with food hypersensitivities are protected from potentially life-threatening reactions. They work with the food industry to ensure that food labelling allows consumers with food hypersensitivities to make informed, safe choices. In December 2014, food labelling and allergen information requirements were updated. Food Business Operators (FBOs) were then required to provide allergen information for non-prepacked foods, including those prepacked for direct sale (PPDS). PPDS foods are those that are packed before being offered for sale by the same food business on the same premises or location (or from moveable or temporary premises). The law at this time allowed for allergen information for these foods to be communicated in writing or verbally. In 2016, Natasha Ednan-Laperouse died from an allergic reaction to a baguette which was PPDS. Following this, there was a campaign for the expansion of legislation to bring the labelling requirements of PPDS foods more in line with prepacked foods. Under this legislation, often known as ‘Natasha’s Law’, it has been a legal requirement since 1 October 2021 for PPDS food labels to clearly display the name of the food and a full ingredients list with the 14 regulated allergens emphasised within the list. One year after it became a legal requirement across the United Kingdom (UK), the FSA and FSS wanted to evaluate its implementation and the effect it has had on three key groups: Food Business Operators (FBOs), Local Authorities (LAs) and consumers with food hypersensitivities (FHS). This evaluation aimed to understand: • Awareness of the new requirements across FHS consumers, FBOs and LAs • Uptake and compliance with the new requirements • The effect of PPDS legislation • LA experience of supporting compliance • Success factors and lessons learned from the implementation of PPDS legislation and how this could be applied in future. IFF Research were commissioned to conduct this evaluation on behalf of the FSA and FSS, taking a mixed-method approach. A quantitative survey was conducted with each of the key audiences followed by qualitative interviews between November 2022 and February 2023: • Consumer research: A total of 1,809 consumers who either had a food hypersensitivity themselves (n=1,610) or had a child with a food hypersensitivity (n=199), most of whom (92%) had an allergy to at least one of the 14 regulated allergens, took part in an online survey. This included consumers residing in England (n=1,539), Northern Ireland (n=102) and Wales (n=168), consumers in Scotland were not included in the research as FSS are conducting their own research which will be published separately. A total of 31 consumers also participated in a follow-up qualitative interview. • FBO research: 900 FBOs across the UK took part in a telephone survey, this included FBOs in England (n=612), Northern Ireland (n=52), Scotland (n=161) and Wales (n=75). A total of 19 completed a follow-up qualitative interview, 5 of whom were market traders. • LA research: All 398 LAs across the UK were contacted to take part in an online survey, with 126 completes across 124 different LAs,2 in England (n=85), Northern Ireland (n=11), Scotland (n=20) and Wales (n=10). A total of 21 LAs also took part in a follow-up qualitative interview.