As of May 2019, the FSA has recommended ministers adopt strict new rules, which include highlighting the 14 major allergens.

The BBC explains that:

Supermarket sandwiches: already have to list full ingredients including allergens

Over-the-counter sandwiches: if they are made to order in front of you, they don’t currently need a label. This will not change under the new plans.

Pre-prepared sandwiches: if made on the premises, they don’t currently need a label, just a sign nearby prompting customers to ask about allergens. But when these recommendations are adopted, any sandwich that is wrapped and picked from a shelf will need to carry a label listing all ingredients, and highlighting major allergens. 

Ministers still have to decide whether to proceed with the FSA recommendations. If they do food outlets will be required to provide a full list of ingredients on each product, highlighting nuts, eggs and dairy and other products that are frequent allergens. However, the new legislation will not apply to sandwich shops and those that package and prepare food at the point of sale, since it is assumed that there will be face to face contact and if there are concerns about allergens, that a conversation will occur between staff and customer. These outlets will still need to display signage, telling customers to ask for information on allergens.


Earlier in 2019, we wrote how new proposals for tougher labelling on food set out by the government this week, aimed to protect the 2 million food allergy sufferers in the UK, and give them greater confidence in the contents of and safety of their food, and crucially, to prevent further deaths.

UK allergy figures

In the UK there are 100 food allergy deaths each year, 4,500 UK hospital admissions from food allergies and 8% of children are affected by food allergies or intolerances.

Proper labelling of food is critical so people actually know what they are eating and are able to avoid ingredients they are sensitive to. For those with the severest form of allergies it can be the difference between life and death.

New proposals

New proposals, unveiled by environment secretary Michael Gove, will begin with a consultation on various labelling options. From all pre-packed food being clearly labelled to show all ingredients including allergens so that allergen sufferers can easily decide whether it is safe for them to eat – or not, to lesser labelling options.

Natasha’s Law


Known as Natasha’s Law, these new proposals were sparked by the death of teenager Natasha Ednan-Laperouse, who died in 2016 after suffering an allergic reaction to sesame in a Pret A Manger baguette she bought at the airport. The ingredient wasn’t listed on the label. She suffered a cardiac arrest on a British Airways flight to Nice.


The current law


The current law came into force in December 2011 focusing on the 14 most common allergens.


The law states that to sell food and drink products all vendors must label ingredients and the label must be:

  • clear and easy to read
  • permanent
  • easy to understand
  • easily visible
  • not misleading
  • must show certain basic information, list the ingredients and show certain warnings

For those running a catering business, selling food loose or packaged for sale in your shop, they only need to show:

  • the name of the food
  • if any of the ingredients have been irradiated, or have come from genetically modified sources
  • certain warnings
  • any food additive you have added
  • allergen information
  • those selling loose meat products are required to show more information


Under current guidelines, takeaways and restaurants are only required to flag up foods containing 14 allergens most commonly implicated in allergic reactions, listed below:

Information according to Food Standards Agency: these are the 14 most dangerous allergens that need to be labelled on pre-packed foods when used as ingredients:

  1. Cereals containing gluten, namely: wheat (such as spelt and Khorasan wheat), rye, barley, oats
  2. Crustaceans for example prawns, crabs, lobster, crayfish
  3. Eggs
  4. Fish
  5. Peanuts
  6. Soybeans
  7. Milk
  8. Nuts; namely almonds, hazelnuts, walnuts, cashews, pecan nuts, Brazil nuts, pistachio nuts, macadamia (or Queensland) nuts
  9. Celery (including celeriac)
  10. Mustard
  11. Sesame
  12. Sulphur dioxide/sulphites, where added and at a level above 10mg/kg in the finished product. This can be used as a preservative in dried fruit
  13. Lupin which includes lupin seeds and flour and can be found in types of bread, pastries and pasta
  14. Molluscs like clams, mussels, whelks, oysters, snails and squid

Under the law, all businesses working with food must:

  • make sure food is safe to eat
  • make sure they don’t add, remove or treat food in a way that makes it harmful to eat
  • make sure the food is the same quality that they say it is
  • make sure they don’t mislead people by the way food is labelled, advertised or marketed
  • keep records on where they got food from and show this information on demand – known as ‘traceability’ (PDF, 90KB)
  • withdraw unsafe food and complete an incident report
  • tell people why food has been withdrawn or recalled, for example by using a leaflet or poster
  • display your food hygiene rating (if you sell food direct to the public)

The four new options

The four options being put forward for food that is made, packaged and sold on the same premises are:

  1. Full ingredient list labelling – all vendors have a duty to know exactly what is in their food, this takes it further obliging them to list all these ingredients clearly on their labels.
  2. Allergen-only labelling – inline with restaurants to be required to list just the 14 most common allergens. However, many people are allergic to many more foodstuffs than just these 14.
  3. Ask-the-staff labels with supporting information available for consumers in writing – obviously an easier and cheaper option for vendors.
  4. Promoting best practice around communicating allergen information to customers (meaning no change in the law)
Allergy UK’s response

Carla Jones, chief executive of Allergy UK said that the food allergy community is already very vigilant, taking a lot of responsibility for looking at food labelling.  The food industry could do more to help.

Have your say

Food businesses and allergy sufferers are invited to have their say on the four options they think are most beneficial. To have your say click here:

The consultation closes on 29 March 2019.

It is strongly advised that you complete an online or attend a practical or online first aid course to understand what to do in a medical emergency. Click here or call 0208 675 4036 for more information about our courses. First Aid for Life provides this information for guidance and it is not in any way a substitute for medical advice. First Aid for Life is not responsible or liable for any diagnosis made or actions taken based on this information.

Emma Hammett
Author: Emma Hammett