This is obviously a very serious subject. Our hearts go out to the family of Natasha Ednan-Laperouse who so very sadly lost her life due to an allergy to sesame seeds.
We have always taken allergens and dietary requirements very seriously. We take every possible care to avoid cross contamination even though we are not a quarantined kitchen.
Any cake containing a recognised allergen is labelled with a sticker and since the Covid pandemic all our cakes have been wrapped and heat sealed.
We have a spreadsheet with allergen information on the counter, and a folder with allergen information. Our staff are trained in allergen awareness and if in doubt will reluctantly advise customers not to make a purchase.
The new legislation requires us to label every prepackaged product with a full list of all the ingredients, including compound ingredients, and with the allergens highlighted in bold text. Of course we are more than happy to do anything that will keep our customers safe, but the new legislation does have its challenges,
Our priority has always been to ensure that a customer does not purchase something they are allergic to. We appreciate labelling may be one way of ensuring this, in particular in supermarkets and larger shops and bakeries. However for smaller neighbourhood businesses such as The Kitchen this will create an additional burden in terms of both cost and time, and we are not yet convinced that it will keep our customers safer overall.
At the moment a customer with an allergy will speak to a member of staff, check a product for allergy stickers, perhaps ask for a supervisor/manager and to look at our allergen information booklet and even our recipe if they wish. This process, along with an explanation of what it means to not be a quarantined kitchen should ensure no one makes an inappropriate purchase.
With the full list of ingredients on the label some customers may not stop to enquire. They are perhaps less likely to mention their allergy and receive the personal advice and attention that we as staff can offer them. Our concern is that purchasing a product with a label might lead to a false sense of security, along with the potential for human error.
Whilst we would of course take every precaution to ensure the wrong label is not placed on the wrong cake there can never be a guarantee that this will not happen. With the seemingly endless shortages of ingredients that we are experiencing we often have to substitute an ingredient. We would then need to make sure that an updated label is written and printed, and that the older version is set aside until the stock situation is remedied.
Natasha’s Law requires us to list all the ingredients used in all our pre-packaged cakes. In some cases this will pretty much mean revealing our recipes, exclusive to us, but we can live with that. There are some cases however where we genuinely wonder how we will manage.
A box of assorted cupcakes for example will need to be labelled with the ingredients in every cupcake. Since compound ingredients must be listed one boxed cupcake decorated with sprinkles may contain Sugar, Rice Flour. Potato Starch, Maltodextrin, Vegetable Fat (Rice Bran Oil). Stabilizers (Gum Arabic), Spirulina Extract. Colours (E171 Titanium Dioxide), Glazing Agent (Carnauba Wax), Anti-caking Agent (Potassium Aluminium Silicate) The label would also state that the sprinkles were made in a factory that may contain Nuts.
However another cupcake in the same box may contain Sugar, Potato Starch, Dextrose, Glucose Syrup, Un Hydrogenated Vegetable Fat, Sunflower Oil, Wheat Flour, Wheat Starch, Rice Flour, Maize Starch, Water, Emulsifier (rapeseed lecithin), Colours (E120, E122, E124, E132, E133, E151, E171, E174), Stabiliser (arabic gum), Gelatine (fish), Glazing Agent (shellac, acacia gum)
And that is just the ingredients in two of the dozens of sprinkle selections we have in stock. Take our Brownies as another example. A Biscoff Brownie will need a label to say that the Biscoff Spread contains Original caramelised biscuits 58%, (Wheat flour, sugar, vegetable oils (palm* rapeseed), candy sugar syrup, raising agent (sodium hydrogen carbonate),soya flour, salt, cinnamon), rapeseed oil, sugar, emulsifier (soya lecithin), acid (citric acid) *palm oil from sustainable and certified plantations. Not to mention the other ingredients in the Brownie batter itself of course!
So the labels may end up bigger than the cake slices, unless we reduce the font size to the absolute minimum required by law which may in fact make it difficult to read. Producing the labels is time consuming, open to error and of course costly in both financial and environmental terms.
As with anything we are more than willing to do whatever is required by law and necessary to ensure the health, well being and happiness of all our customers. Business owners carry out routine and regular risk assessments and keep up to date with insurance, licensing and a myriad other demands. On this occasion however we are unconvinced, as we said earlier, that the changes will overall keep our customers safer than our current due diligence model.
The new law does not require unpackaged cakes to be labelled in this way. If cakes are displayed unpackaged and packaged for a customer at the point of sale then the current legislation is sufficient. Information on allergens is clearly displayed, stickers identify the most common allergens and advice is available from all staff members who are trained to advise but will also defer to management if in doubt. This is the same as the way we manage our sandwiches which are made and packed to order (we will no longer be able to prepare and pack the most popular sandwiches in anticipation of a rush unless we have labels for them all which list all the ingredients in the bread, chutney, mustard, pesto…)
Not packaging slices of cake does of course mean that they may not last as long – the potential for waste is increased. Mystery Boxes as you know and love them will disappear – but we are determined to find a new way forward that continues to keep waste to a minimum.
The traybakes and brownies that we display on the way to the counter, along with our popular gingerbread cookies, rainbow cake slices and school sponge will also disappear until we find a way forward. It may be that pre-ordering is the way to go since the existing requirement to make all customers aware of the 14 major allergens prior to purchase remains valid for pre-orders with no legal requirement for full ingredient labels.
Thank you for your understanding as again we realise this will require us all to adapt again.
Of course the potential for cross contamination is increased if cakes are not packaged so if we go down this path we will invest in more cake stands and domes to display cakes baked with gluten free flour or cakes containing nuts separately.
The changes come into effect on October 1st. We are working towards them already and have been for many months but would ask for your understanding as we adjust. We’re continuing to speak to our regular customers to get feedback so thank you if you have responded in person or online. We still welcome your comments!