One of our fundamental rights, as consumers, is to know what’s in our food so we can make informed decisions about the products we buy. 

Food labelling exists to help us do just that — to ensure clarity, fairness and safety; and it’s an area of the food manufacturing world that’s continuously evolving. 

In this guest post by Caitlin Stewart from Ashbury Global, we explore some of the latest developments in food labelling and the drivers behind these changes — one of which dominated headlines in 2019, and led to the introduction of what’s now known as ‘Natasha’s Law’.  

Natasha’s Law: A beacon for food allergy sufferers

September 2019 was a watershed moment for food safety in the UK, marking the introduction of the UK’s Food Information (Amendment) Regulations 2019, commonly known as ‘Natasha’s Law’.

Natasha’s Law is rooted in tragic circumstances. It’s named in honour of 16-year-old Natasha Ednan-Laperouse who died from an anaphylactic reaction after eating a shop-bought baguette. 

Natasha’s baguette contained sesame seeds which she was severely allergic to. The allergen wasn’t listed on the product’s packaging because of an exemption in the labelling law for pre-packed for direct sale foods at the time.

Driven by their loss, Natasha’s family passionately campaigned for greater transparency and consistency around allergen labelling requirements, and the Natasha Allergy Research Foundation along with Natasha’s Law were introduced. The law aims to bring more clarity for consumers who suffer from allergies.

Natasha’s parents spoke to ITN on the day Natasha’s Law came into force, October 1, 2021. The law aims to help prevent deaths from food allergies.

Watch the clip at narf.org.uk/natashaslaw

The impact of Natasha’s Law

Natasha’s law meant that all ‘prepacked for direct sale’ (PPDS) foods must clearly display the following information on the packaging:

  •   Name of the food
  •   Full ingredients list and allergenic ingredients emphasised (for example, in bold, italics or a different colour). The 14 allergens that this law covers are:
    1. Celery
    2. Cereals containing gluten, such as wheat, rye, barley, and oats
    3. Crustaceans, like prawns, crabs, and lobsters
    4. Eggs
    5. Fish
    6. Lupin
    7. Milk
    8. Molluscs, like mussels and oysters
    9. Mustard
    10. Peanuts
    11. Sesame seeds
    12. Soybeans
    13. Sulphur dioxide and sulphites (at levels above 10mg/kg or 10mg/L)
    14. Tree nuts, including almonds, hazelnuts, walnuts, and others

PPDS products are those that are packed on the same premises before being offered for sale, such as salad pots, packed sandwiches, warm soup cups and sushi. Previously, allergen information could be provided through other means, such as verbally or through allergy charts. The change ensures allergens in food pre-packed for direct sale are labelled in the same fashion as pre-packed foods found on supermarket shelves.

Broader trends in food labelling to aid consumer clarity

The era of the conscious consumer means the demand for information and transparency is higher than ever before. Beyond Natasha’s Law, some other significant trends and changes include:

Precautionary allergen labelling (PAL)

Precautionary allergen labelling is a voluntary practice where food products are labelled to indicate the potential presence of allergens due to cross-contact at any stage of production. The phrase ‘may contain’ is often recognised, but specific phrasing is flexible. This nuanced phrasing has the potential to confuse consumers and there is a perception that this statement is used unnecessarily to remove liability, resulting in decreased choice for consumers living with allergies.

As a result, the Food Standards Agency (FSA) launched a consultation in 2023 and industry responses suggest a shift towards standardised risk assessment methods and wording on labelling. FSA guidance documents were updated to reflect the responses and the consultation could also influence future regulations in this space.

RELATED: Explore our interview with Ashbury’s CEO Zoe Jordan and Head of Regulatory Affairs, Brigid McKevith, which featured as part of the Food & Drink: Powers our Nation 2024 programme.

This film is produced by the ITN Business commercial team and is not created by ITN news staff journalists.

Clearer nutrition information

UK consumers are familiar with the traffic light labels on food packaging, which aims to provide an at a glance assessment of nutritional quality. In the EU, various front of pack labelling schemes are used on a voluntary basis, however, the proposed harmonised front-of-pack labelling as part of the ‘farm to fork’ strategy, seeks to standardise the approach across Europe.  

Whilst there is no agreed approach yet, the Nutri-Score scheme has been adopted by countries such as the Netherlands, France, Spain, Switzerland and Germany. However, it has sparked debate about its effectiveness and potential to oversimplify complex nutritional information.

Sustainability and ethical labelling

In response to consumer demand for clarity, the proliferation of sustainability labelling, such as information on packaging recyclability, animal welfare and green claims, has taken industry by storm. Of course, the considerable novelty of such labelling and inconsistent data, has led to accusations of ‘greenwashing’, albeit mostly unintentional.

Additionally, carbon footprint labels that identify the environmental impact of products are appearing on shelves. Despite there being some talk of mandating eco-labels, the government has stated it has no plans to endorse or enforce eco-labelling. What we can expect is to see OPRL recycling labelling become mandatory in the UK from 2026 in efforts to lead consumers towards better disposal practices for packaging. In the long-term, changes to labelling to support the implementation of deposit return schemes (DRS) in 2027 are also expected.

Health and wellness

The health and wellness obsession has seen brands increasingly highlight functional benefits on their labels. Strict regulations are in place to ensure that health claims are scientifically backed and whilst this isn’t a matter of safety, it’s important to get these claims right to prevent consumer deception and avoid action from the Advertising Standards Agency.

New technology

This rise in demand for more product information has occurred simultaneously with the increased formats that information can be accessed. Digital platforms, blockchain technology and QR codes all offer alternative ways beyond the label for brands to share additional information about their products. QR codes are fast-becoming the space-saving tool of choice for non-mandatory information, such as sharing links to website pages, social media channels and providing recipe ideas. And in the EU, the alcohol industry was the first to see an official regulation that allows the provision of nutritional information via a QR code on the label. Whilst this is not yet the case for other food and beverage products, it does indicate the potential for future regulation in this space.

We’ve also seen innovations such as air fryers, drive the development of additional cooking instructions on packaging to help consumers cook products that are safe to eat. 

Clarity of confusion? ‘Not for EU’ Labelling

In the aftermath of Brexit, changes continue to take shape, such as the controversial introduction of ‘Not for EU’ labelling in early 2024. Unlike Natasha’s Law, this change wasn’t intended to support the consumer, instead it was to support easier trade with Northern Ireland. However, consumers were left baffled by the new labelling, misinterpreting it as an indication of product quality rather than a matter of customs clearance – an example of labelling unintentionally creating confusion instead of clarity for consumers,

Navigating compliance

The ever-growing demand for more information raises the question: how much information is too much? Brands must face the challenging task of balancing mandatory legal information with marketing and branding objectives. Remember, whilst it is important for brands to communicate their positioning effectively to sell their products, this should not be at the expense of the mandatory information on labels that ensure the safe storage, cooking, and consumption of foods. 

To stay compliant and protect brand reputation, it’s important businesses engage with industry bodies, governments, and compliance experts like Ashbury to mitigate reputational risk and protect consumer safety.

Natasha’s law exemplifies how regulations can develop around the needs of consumers. But labelling evolution doesn’t end here. As consumer expectations grow and regulations evolve, brands must adapt to provide transparent and accurate information. While compliance can be challenging, it is essential for protecting brand integrity and consumer health.

 Explore our Food & Drink: Powers our Nation programme for 2024 here.