Q: I am looking to increase the food offer in my pub because I have noticed a growing demand for vegan products. Other than coming up with the new menu is there anything else that I need to consider?
A: You are right and the demand for vegan offerings is growing, this is evidenced by the statistic that 400,000 people signed up for Veganuary this year, which is an increase of 60% on last year.
However, you do not just need to consider the new dishes you will offer, but also the legal implications of introducing a new menu.
It is not simply enough to list the dishes you are selling as vegan on the menu, they must also contain all of the allergen information, as with your other offerings to comply with the Food Information Regulations.
In practice, it should not be too challenging to ensure that your vegan offerings comply with the regulations, as you will already have measures in place to deal with this for your existing menu. However, you should ensure that both staff training takes place and any documentation is updated prior to the launch of your new menu.
It is also important to ensure that there is no cross-contamination with non-vegan products, by keeping ingredients separate, for example, and make your staff aware of the consequences should they serve a vegan meat for example. This would be a breach of the Food Safety Act and could also have implications under human rights and equality legislation.
I appreciate that the above may sound slightly daunting, but with careful planning and preparation a vegan menu offering could be a valuable addition to your business, attracting new customers and making you stand out from the crowd.
Q: I am a restaurant operator and have seen a lot in the press recently regarding allergens and ‘Natasha’s Law’ – does this affect me?
A: The short answer is yes it does. ‘Natasha’s Law’ as it is named is new allergen regulations and expected to come into force in October 2021.
I appreciate this may seem a lifetime away, but with recent research showing that one in five food samples contains at least one undeclared allergen, there is clearly work to be done.
The Government delayed the implementation of the new legislation with the hope being that operators such as you will have time to prepare for the change and ensure they are complying.
Once in force, it will require you to label all products, including products prepared and packaged on-site, with a full ingredients list, which is an addition to the current requirements and will no doubt have an impact on your business.
There is, therefore, no harm, and possibly even advantages, to being ahead of the game here and ensuring that you will be able to comply, or will already be complying, with the new legislation when it comes into force next year.
You will already have procedures in place to ensure that staff are trained on what the 14 food allergens are and on how to communicate these to customers, but you should begin to consider additional measures/training to ensure that staff are aware of the changes, when they come into force and the additional obligations in respect of food labelling.
You will also have measures in place to identify specific allergens in your food so that these can be highlight, but you may wish to consider something more robust.
While technology can be expensive, it may be advantageous for you to look into this to see if there is anything that can help you with identifying ingredients and more specifically allergens as an additional safeguard or check. This may take the form of an app or a database.
It is likely that there will be further updates and advice as implementation nears and so it is worth keeping an eye on.
For any legal enquiries please visit Poppleston Allen's website.