From 1 October 2021, Prepacked for Direct Sale (PPDS) food will need to have a label with a full ingredients list with allergenic ingredients emphasised within it under The Food Information (Amendment) (England) Regulations 2019.
According to the new rules, PPDS food will have to clearly display the following information on the packaging:
- name of the food,
- full ingredients list, with
- allergenic ingredients emphasised (for example in bold, italics or a different colour)
As there is no legal definition, the current Food Standards Agency (FSA) interpretation for PPDS is that it applies to foods that have been packed on the same premises from which they are being sold.
Establishing whether food is PPDS is more tricky for catering establishments where some food is prepared ahead of time, while some is prepared fresh for the customer.
An establishment may both prepare sandwiches ahead of time – in which case they would fall into the PPDS category and would need full ingredient labelling – and also prepare a sandwich fresh on the request of a customer. In the latter case the food would fall out of the definition of PPDS so would not require full ingredient labelling.
In any event, it is expected that the customer is able to speak with the person who made or packed the product to ask about ingredients.
The FSA is currently developing a revised working interpretation of the types of food covered by the PPDS definition. This will give greater clarity on the types of food covered, and how they are made available to the consumer. The consultation on this technical guidance opened 23rd January and closes on 6 March 2020.