Protecting allergic consumers beyond packaged foods
For consumers living with food allergies, buying a sandwich from an in-store deli, a pastry from a bakery or a meal from another catering establishment can involve more than simply choosing what to eat. Without conventional ingredient labelling, consumers often rely on staff to provide the information they need to make informed decisions.
This makes staff knowledge, access to accurate ingredient information and effective allergen management practices essential to helping allergic consumers make informed food choices.
This raises an important question: where does the responsibility lie for allergen safety?
Although allergic consumers have a responsibility to communicate their dietary needs and make informed decisions about the food they consume, food suppliers have an equally important role in ensuring that the information on which those decisions are based is accurate, accessible and reliable.
What the current law requires
R. 146 as amended exempts some ready-to-eat foods from full labelling requirements. The exemption can apply to food prepared and sold on the premises of a qualifying catering establishment, such as an in-store deli or bakery.
This means that retailers do not need to put a full ingredient list on every package.
However, the retailer remains responsible for making ingredient and allergen information available at the point of sale when a customer asks for it.
This information must be:
- Accurate and current
- Easy for staff to access
- Available before the customer buys the product
In addition, R. 638 requires appropriate food handling practices to prevent unintended allergen cross-contact. Together with the Consumer Protection Act’s broader consumer protections, these requirements highlight the importance of providing accurate information and managing allergen risks appropriately.
What this means for staff
Staff do not need to memorise every recipe or ingredient. However, they should know where to find the correct product information and be able to provide it without delay.
Consumers may ask whether a product contains a specific regulated allergen (South Africa’s Regulated Common Allergens). However, consumers may also have allergies to foods that are not included in South Africa’s regulated common allergen list, such as sesame. Staff should therefore be able to consult the full ingredient list to answer questions about these foods.
What this means for consumers
Allergic consumers – or those purchasing food on their behalf – are encouraged to communicate their specific allergies, ask questions where needed, and request ingredient information before purchasing. It is worth checking even when buying a familiar product, as ingredients and preparation practices may change over time.
If consumers are not satisfied that the information provided adequately addresses their concerns, they should consider choosing an alternative product, as well as raising the matter with the store manager or relevant person responsible for food safety.
Practical controls for catering establishments
Catering establishments should make sure that staff can access:
- Current product specifications
- Ingredient lists
- Allergen declarations
- Updates when recipes, ingredients or suppliers change
Allergen awareness training should also form part of the onboarding process for new staff, ensuring they understand how to access allergen information, respond to customer enquiries and manage allergen risks appropriately. Refresher training is particularly important where staff turnover is high or food preparation practices change.
Building allergen awareness
Ultimately, allergen safety relies on both reliable information and effective communication between food suppliers and consumers. Ensuring staff understand their role in allergen management is an important step towards helping allergic consumers make informed food choices.
Our team offers allergen awareness training for staff working with ready-to-eat foods in in-store delis and bakeries. The training helps staff understand food allergens, access relevant product information, and respond appropriately to customer enquiries.
Contact FACTS to learn more about our allergen awareness training and how we can support your team.