Allergen Label & Matrix Maker (Natasha’s Law PPDS, EU, US, FSSAI)

About the Allergen Label & Matrix Maker (Natasha’s Law PPDS, EU, US, FSSAI)

Food that is packed where it is sold, before the customer orders it — sandwiches, salads, pasta pots, bakery and butcher’s products packed on site — is prepacked for direct sale (PPDS). In England, Wales and Northern Ireland its label must show the name of the food and the full list of ingredients with each of the 14 allergens emphasised in the list (Natasha’s Law). This maker builds those labels and an allergen matrix for the menu.

Enter each product with its ingredients, giving a compound ingredient (bread, mayonnaise, a sauce) its own ingredients. Allergens are suggested from the ingredient words and each one must be confirmed or dismissed; the checks then catch what a label must not miss — a word like “tahini” or “whey” that needs its allergen named in brackets, a flour whose cereal is not named, a type of nut left out — and fix most of them in one click. “May contain” stays apart from the ingredients. The same products also follow the EU rules, the US major food allergens with a “Contains” statement, or FSSAI’s allergen declaration with the vegetarian or non-vegetarian symbol.

Each label is drawn at the largest text that fits it and never below the smallest size its rules allow; a label that would not fit is left out and named, never printed cut short. Labels go on A4 or US Letter sheets or label rolls for thermal printers, as many copies of each as you need, or from a CSV file of products. Without a pass the label sheets and the matrix show as pages marked “not for use”, and their PDF and CSV downloads unlock with a Premium pass; the test page, the CSV template, your products’ CSV and backups always download. The business remains responsible for the accuracy of every label.

Common uses

• A café, deli, bakery or butcher packing food on site for the counter or the chiller cabinet.
• A school, care home, hospital or caterer labelling food packed before it is ordered.
• Putting an allergen matrix by the till or in the kitchen for staff and customers.
• A small food business in the US or India labelling packed food with the “Contains” statement its rules ask for.

What a PPDS label needs

The FSA’s introduction to PPDS labelling: the name of the food and the ingredients list with the 14 allergens emphasised within it, following the rules for naming the food and listing ingredients. Under Regulation (EU) No 1169/2011, which applies in Northern Ireland and, as assimilated law, in England and Wales: the list is headed “Ingredients” and runs in descending order of weight as the ingredients were used (Article 18); each allergen is indicated in it with a clear reference to its Annex II name, emphasised by font, style or background colour (Article 21). A “Contains” statement is only for foods with no list, so the label does not add one. Distance selling (phone and online orders) follows other rules.

Emphasis and clear references

As the FSA’s technical guidance explains: only the allergen’s own word is emphasised — “skimmed milk powder”, “egg white”, “sodium metabisulphite”. Cereals are named by the cereal (wheat, rye, barley, oats; spelt and Khorasan as wheat), nuts by the nut (almonds, hazelnuts…). Where an ingredient’s name does not make its allergen plain it needs the Annex II word in brackets: “tahini (sesame)”, “whey (milk)”, “tofu (soya)”, “prawns (crustaceans)”, “cod (fish)”, “mussels (molluscs)”. Chestnuts, pine nuts and coconut are not among the nuts of the 14 and are not emphasised. An “Allergy advice: for allergens, see ingredients in bold” line may say how they are shown.

Text size

Article 13 of the regulation: an x-height of at least 1.2 mm, or 0.9 mm on packs whose largest surface is under 80 cm². In the US, letters at least 1/16 inch high (21 CFR 101.2); in India the letter heights of regulation 6(3) of the FSSAI labelling regulations by the area of the display panel. The maker measures the lower-case x of its font for every rule (the stricter reading where a rule measures whole letters) and shrinks the text to fit a label only down to that size.

US labels: the “Contains” statement

The nine major food allergens — milk, egg, fish, Crustacean shellfish, tree nuts, wheat, peanuts, soybeans and sesame — are declared in the ingredients list or in a “Contains” statement right after it, in the same type size, naming the type of tree nut, the species of fish or shellfish, and the animal or bird for milk not from cows or eggs not from chickens (“goat milk”, “duck eggs”); if a “Contains” statement is used it lists all of them (FDA guidance, Edition 5). Tree nuts are those of FDA’s Table 1, which includes pine nuts and leaves out coconut; molluscs, and cereals other than wheat, are not major food allergens there (FDA, food allergies).

India: FSSAI’s allergen declaration

Regulation 5(14): cereals containing gluten (declared by the cereal’s name), crustacean, milk, egg, fish, peanuts and tree nuts (declared as Nut), soy and sulphite at 10 mg/kg or more are declared separately as “Contains …”, and cross-contamination may be declared as “May contain …”. Packaged food also carries the vegetarian (green dot) or non-vegetarian (brown triangle) symbol near its name (regulation 5(4)); the maker draws it at the size the regulation sets for the label’s area.

“May contain”

A precautionary statement is only for an unavoidable risk of cross-contamination found by a risk assessment, which cleaning and separation cannot control; it is not a substitute for good practice and may mislead if the risk is not real. Name the allergen, and the food within a group: “may contain peanuts”, not “may contain nuts”, since peanuts are not nuts; “may contain hazelnuts (nuts)”. A food cannot contain an allergen and also “may contain” it.

Limitations

• The business is responsible for its labels: confirm every allergen from your recipes and your suppliers’ specifications, and check each label before you use it. The suggestions only read words.
• It makes the name, the ingredients and allergen information, with your own lines (storage, use by). Other information some foods need — the quantity, a use-by date, nutrition, the business’s name and address on fully prepacked food — is yours to add.
• Scotland sets the same PPDS requirement in its own regulations, with Food Standards Scotland’s guidance; other countries and alcoholic drinks have their own rules, and the US rules here apply to foods the FDA regulates (not meat and poultry under the USDA).
• Your products are kept in this browser on this device: download a backup to keep or move them.
• Print at actual size on the label stock chosen; check one sheet on plain paper first with the test page.

Privacy

On this device; its files download once

Everything happens in your browser. What you enter or open here is not uploaded or stored by MySmartCoPilot. Downloads the PDF engine and its fonts from this site the first time you draw a label; your products never leave this browser.