There is just over one year now before the changes to the FIR take effect, requiring that prepacked food for direct sale (PPDS) be labelled with the name of food and ingredients list with allergens highlighted

Is my food PPDS?

Head over to the Food Standards Agency here to download some well written and pretty clear guidance.

The thing to note is that it is is important to recognise and understand the definition of PPDS, so you can be clear whether it applies to your business or not. If it does, food will need to be labelled (a label that is clear and can be read by the customer) highlighting the allergens.

Some useful examples are given in the FSA guide, some obvious and some not so obvious, we’ve summarised here and added a few further points:

  1. One obvious one is when you think about a sandwich made by a high street such as Pret, Eat, Caffe Nero etc and you buy a sandwich already made and packaged from the chiller cabinet
  2. In a supermarket the sandwich example can also apply if the supermarket cafe staff have made and packed sandwiches for sale in anticipation of orders.
  3. The sale of boxed salads and rotisserie chicken at a supermarket is also offered as an example
  4. Head over to the del counter in a supermarket and you might be picking up cheeses, and meats such as burgers which have been prepacked in anticipation of orders, or indeed you might be visiting a high street butcher to pick up the same
  5. And don’t forget, a fast food chain that might have wrapped burgers or boxed chicken in a hot counter, which have been prepacked in anticipation of orders

Look carefully at the guidance, particularly point 92 for something that really helps. We’ve also alluded to it in the points above. I’ve repeated some of the text in point 92 for clarity (thanks FSA): Any food that is packed on the premises by the same food business in anticipation of an order, before being offered for sale, would be considered to be PPDS food.

Non PPDS food

The other type of food that might be packed on the premises, relates to food packed at the time of customer order, and is covered well in point 93 again reproduced for clarity: Food placed into packaging after a consumer orders it (for example a freshly prepared sandwich or burger that is made and wrapped after taking an order) is not PPDS food. Although these items are packed, they are not packed before being offered for sale and therefore cannot be prepacked for direct sale. The same rules apply to these foods as apply to other forms of non-prepacked foods such as meals served in a restaurant.

So going to a buy a sandwich (think Subway and similar) and ordering a sub that is filled whilst you are there (imagine standing there and watching them do it), from ingredients contained in a chilled display counter, is not PPDS food. Instead, the Food Information Regulations continue to specify that allergen information must be available but can be communicated orally or in written form (for instance holding an allergen matrix for all foods and going through it on a request with a customer).

Don’t forget to visit HygieneCheck – the app for internal food safety auditing. This includes allergen management.

We are also delighted to offer CIEH Allergen Management training, on site or as a virtual training option!

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