PPDS (Pre-packed for Direct Sale) Allergen Rules Explained
The Food Standards Agency has updated their technical guidance to take into account legislative changes that require allergen labelling on PPDS (pre-packed for direct sale) food.
Currently, food businesses can provide allergen information for PPDS food by any means that they choose. This could include on menus, boards or verbally by a member of staff who refers to allergen data held elsewhere.
However, often PPDS packaging is like that of pre-packaged foods, and in the past, some consumers have suffered allergic reactions assuming no allergy information meant no allergens were in the food. To reduce confusion, from 1st October 2021 PPDS food must be labelled with a list of ingredients with allergens emphasised.
Failure to comply with these new allergen provisions could result in a business being served an improvement notice or a criminal prosecution being brought against a food business.
What food falls under the PPDS definition?
Whether a food is PPDS depends on whether, where and when it is packed in relation to the point at which it is offered for sale.
To fall under the definition, PPDS food must be presented to the customer in packaging and packaged at the same site that it is sold. It does not cover food which is packaged only when the customer selects or orders it.
- The food is either fully or partly enclosed by the packaging; and
- cannot be altered without opening or changing the packaging;
- and is ready for sale to the final consumer.
‘packaged at the same site that it is sold’
This would include:
- on the same premises
- on the same site
- on other premises if the food is offered for sale from a moveable and/or temporary premise e.g. Market stall and the food is offered for sale by the same food business who packed it.
What are examples of PPDS foods?
- A ham roll wrapped in a clear film sealed with a label and placed in a chilled cabinet on the same premises it was made.
- Soup placed into a lidded takeaway pot and hot held in a cabinet on the same premises that it was made.
- Cakes presented in a cardboard box and sold from a market stall owned by the same food business operator.
- Snack pots sold from a unit on the same premises that it was made
N.B It is also worth noting that any food items packaged up in anticipation of demand before a busy period even if it kept behind the counter, would also be classed as PPDS.
What needs to be on the label?
- The name of the food
- An ingredient list (in descending order of weight) which must also include:
- the allergenic ingredient emphasised in some way e.g. bold, italics, capitals.
- QUID (Quantitative Ingredients Declaration) of the percentage of meat
- any ingredients contain genetically modified or irradiated ingredients
- additives along with the additive class (the technological function of the additive in that product) followed by either the additive name or its E number e.g. Preservative: potassium sorbate or Preservative: E203
Cross-contamination statements are still voluntary. It is best practice to only use these, if after undertaking an allergen risk assessment, there is still potential for allergens being present. This should be communicated with a cross-contamination statement such as ‘may contain’ or ‘not suitable for’ message on the label but these allergens should not be highlighted in bold.
Safer Food Scores provide a food label examination service to ensure that labels are legally compliant. Please contact us on 01442 877322 or email us at firstname.lastname@example.org if we can help further.