Food Allergy and Intolerance

Online Training
Module 4 Transcript

Providing accurate allergen information

for prepacked and non-prepacked food
Module 4 Transcript

Contents

Lesson 1: Introduction 3
Module objectives 3
Lesson 2: Requirement for non-prepacked food 3
Lesson 3: Requirements for prepacked foods 5
How to label allergens on prepacked products 6
Food products without an ingredient list 7
Applicable requirements – voluntary information (Article 36) 7
Lesson 4: Unassessed quiz 7
Quiz question 1 8
Quiz question 2 8
Lesson 5: Summary 8
Module 4 Assessment 9

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Module 4 Transcript

Lesson 1: Introduction
The way allergen information must be provided for prepacked and non-prepacked
food is different.
For more details on what is prepacked and non-prepacked food, see Module 2 – The
rules for allergen information.

Module objectives
This module explains how to provide allergen information to consumers, both for non-
prepacked and prepacked food.
After working through this module, you will be able to:

• explain how allergen information for non-prepacked food must be

communicated to consumers
• explain how allergen information for prepacked food must be communicated to
consumers

Lesson 2: Requirement for non-prepacked food

Businesses have some flexibility in how they can provide allergen information for
non-prepacked food to consumers.
Allergen information may be provided by any means the FBO chooses, for example,
by:

• having the information written upfront (for example, on a menu or menu board)
so the consumer doesn’t have to ask for the information
• signposting the consumers to where written information can be found
• signposting the consumers to obtain oral information from a member of staff
Where allergen information will be provided orally, there must be a label or ticket
attached to the food or a clearly displayed sign or notice informing the customer
about how the information will be provided.

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Module 4 Transcript

If information on allergens is provided orally, the FBO must put a system in place to
ensure its accuracy. This means the FBO must have processes in place to capture
information from recipes or ingredients lists from products bought in and make this
available to staff. For example, recipes or ingredients lists could be kept in a folder,
with allergens highlighted. If ingredients, menus or recipes change, the FBO should
make sure they update the list of ingredients with allergens as well.
FBOs could use an allergen chart to help the team keep track of dishes and the
allergens they contain; or a chef recipe card for recipe substitutions or occasional
‘specials’.
It is important that consumers with food allergies or intolerances can make safe and
informed choices when selecting their food.
Any staff who are serving customers should know the potential risks to customers'
health if they provide them with incorrect allergen information. If a member of staff is
unsure of the answer to a customer's question, they should never guess and must
ask somebody who knows.
Customers are strongly advised to speak to staff regarding their allergy requirements.
For instance, they should:

• ask how the food is handled and cooked, and whether there is a chance of
cross-contamination from cooking equipment or ingredients
• be very clear about their dietary requirements and give examples of the foods
that make them ill

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Module 4 Transcript

Reminder: From 1 October 2021, all foods that are prepacked for direct sale
(PPDS), must have on the package 1 or on a label attached to the package:

• The name of the food.

• An ingredients list 2 including allergenic ingredients. The allergenic ingredients
within the food must be emphasised every time they appear in the ingredients
list. For example, the allergens in the food can be listed in bold, in contrasting
colours or underlined.

More information
For information about food allergy and intolerance and about food allergen labelling
and information requirements refer to the following:
You can find a detailed explanation of the allergen labelling and information
requirements in our Technical guidance.
For allergen guidance for food businesses, visit the FSA website.
For an overview of food allergy, visit the NHS website.

Lesson 3: Requirements for prepacked foods

Depending on the product, some or all of the following information will be required
on the label:

• name of the food

• list of ingredients
• ingredients or processing aids causing allergies or intolerances, that are
stated in the 14 Allergens of Annex II of the EU Food Information to
Consumers - see Module 2 The rules for allergen information
• quantity of certain ingredients or categories of ingredients
• net quantity of the food
• date of minimum durability or the ‘use-by’ date
• special storage conditions and/or conditions of use
• name or business name and address of the FBO

1 See Article 16(2) of Regulation (EU) No. 1169/2011 for the requirements applicable
to packaging or containers with a surface area less than 10cm2, so far as it relates to
the particulars required by Article 9(1)(b).
2 See FIR for more rules on the required format of the ingredients list. Article 19 of

Regulation (EU) No. 1169/2011 for foods which are not required to bear a list of
ingredients.

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Module 4 Transcript

• country of origin or place of provenance

• instructions for use where it would be difficult to make appropriate use of the
food in the absence of such instructions
• the alcohol strength by volume for beverages containing more than 1.2% of
alcohol
• nutritional declaration
A minimum font size applies to mandatory (compulsory) information. The font size is
determined by the letter 'x’ and if it is the same height or bigger than 1.2mm (6). If the
largest surface area of packaging is less than 80cm squared, a minimum x-height of
0.9mm can be used.

Mandatory (compulsory) food information must be easily visible, clearly legible and
where appropriate, indelible (cannot be erased). This information must not be in any
way hidden, disguised, covered by or interfered with by any other writing or pictures.
If an ingredient is made up of other ingredients (compound ingredients), these must
also be declared in the ingredients list.

More information
For more information, visit the packing and labelling page on the FSA website.

How to label allergens on prepacked products

Allergens used as ingredients need to be clearly emphasised within the ingredient
list.
The allergenic ingredients need to be emphasised using a typeset that clearly
distinguishes them from the rest of the ingredients, for example by means of the font,

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Module 4 Transcript

style or background colour. Food businesses can choose what method they want to
use to emphasise the 14 allergens on their product label.
The allergenic ingredients also need to be indicated with a clear reference to the
allergens as listed in Annex II of Regulation (EU) No 1169/2011 (EU FIC).
For example: ‘prawns (crustaceans)’ or ‘cod (fish)’.
Where several ingredients or processing aids in a food originate from a single
allergenic ingredient, the labelling should make this clear for each ingredient or
processing aid concerned. For example, skimmed milk powder: (whey (milk), lactose
(milk)).

Food products without an ingredient list

Some foods - such as alcoholic drinks with more than 1.2% by volume of alcohol - do
not require an ingredient list (Article 16 (4) of EU FIC). In this case any substances or
products derived from the Annex II list which are present and not clear from the name
of the food need to be listed, using a ‘contains’ statement followed by the name of the
allergens.
For example, a bottle of wine must have a statement such as: ‘Contains: sulphites’ if
the finished product contains sulphites at more than 10 mg/kg or 10 mg/litre.

Applicable requirements – voluntary information (Article 36)

Article 36 of the EU FIC covers the applicable requirements for voluntary food
information and the implementing measures that the European Commission needs to
take on the application of the requirement.
In particular, the EU FIC does not permit the voluntary use of allergen advisory
statements such as ‘Contains: wheat, egg and milk’ to repeat mandatory allergen
ingredients information. This is relevant where an ingredient list is not required but is
voluntarily provided.

Lesson 4: Unassessed quiz

You can complete the assessment when you are ready. If you wish, you can test
your knowledge by completing this short unassessed quiz first.
If you have any difficulties in completing this, it is recommended that you review the
session.

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Module 4 Transcript

Quiz question 1
A deli-counter is offering a selection of cold meats, quiches and pies for sale. How
can allergen information be provided?
Select one answer:
1. Using a signpost that indicates where the customer can obtain the information
2. There is no signpost, but if asked, a member of staff will be able to provide the
information
Take a moment to think about it.
The correct answer is 1: Using a signpost that indicates where the customer can
obtain the information

Quiz question 2
James is dining at a restaurant and asks the waiter which allergens are present in a
prawn samosas dish he has seen on the menu. A sign that says 'Food allergies? Ask
our staff' is displayed at the bar counter.
The waiter is unsure about which allergens are present in the dish and decides to ask
his manager before answering James. Are the restaurant and the waiter providing
allergen information in the correct way to James?
Select one answer:
1. No, the waiter should have known which allergens are present in the dish
without asking his manager
2. Yes, there is signposting to where allergen information can be obtained, and
the waiter checked with his manager to ensure he could provide accurate
allergen information
3. No, allergen information must be present on the menu
Take a moment to think about it.
The correct answer is 2: Yes, there is signposting to where allergen information can
be obtained, and the waiter checked with his manager to ensure he could provide
accurate allergen information.

Lesson 5: Summary
This module highlighted the importance of creating an environment where
conversations about allergens between FBO staff and consumers are encouraged. It
also explained how to communicate mandatory allergen information to consumers.
You should now be able to:

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Module 4 Transcript

Lesson 1: Introduction
The way allergen information must be provided for prepacked and non-prepacked
food is different.
For more details on what is prepacked and non-prepacked food, see Module 2 – The
rules for allergen information.

Module objectives
This module explains how to provide allergen information to consumers, both for non-
prepacked and prepacked food.
After working through this module, you will be able to:

• explain how allergen information for non-prepacked food must be

communicated to consumers
• explain how allergen information for prepacked food must be communicated to
consumers

Lesson 2: Requirement for non-prepacked food

Businesses have some flexibility in how they can provide allergen information for
non-prepacked food to consumers.
Allergen information may be provided by any means the FBO chooses, for example,
by:

• having the information written upfront (for example, on a menu or menu board)
so the consumer doesn’t have to ask for the information
• signposting the consumers to where written information can be found
• signposting the consumers to obtain oral information from a member of staff
Where allergen information will be provided orally, there must be a label or ticket
attached to the food or a clearly displayed sign or notice informing the customer
about how the information will be provided.