‘Natasha’s Law’ – One year to go

In 2019, the Government set out new legislation placing stricter requirements on pre-packaged foods to carry a full list of ingredients - known as ‘Natasha’s Law’. Natasha’s Law follows the tragic death of Natasha Ednan-Laperouse, the teenager who died after suffering an allergic reaction to a Pret a Manger baguette. The reforms cover labelling requirements for foods that are prepared and packed on the same premises from which they are sold – such as sandwiches, salads or bakery items made in store.

Inevitably, plans to prepare in 2020 have had to adapt as all our lives and plans were impacted by Covid-19, but Natasha’s Law will come into force in October 2021, so just under one year to go. We know that there will be a focus on ensuring the accuracy of information required to comply with the legislation.

Most retailers have some form of Project Lifecycle Management (PLM) or compliance solution as the repository for their own brand product information, with Oracle Retail Brand Compliance (ORBC) the most prevalent in major UK grocery. Oracle have partnered with Solutions for Retail Brands (S4RB) offering retailers the chance to integrate the Affinity™ platform into their ORBC systems. With the opportunity to improve collaboration, accelerate new product development and improve data accuracy and compliance. In addition to this, however, most retailers also have a stringent approval process around label/artwork approval for pre-packaged own brand products. This can sometimes, therefore, make up for any inaccuracies in the master data (as artwork is amended and approved to ensure legal compliance) with expert services available from companies such as Ashbury Labelling or Campden BRI.

However, the requirements of Natasha’s Law are for labels that will most often be printed in store at the point of packaging because those labels will also include dynamic information such as weight, price and use-by date. Therefore, the need for accurate information will be greater than ever. Utilising S4RB’s Three Pillars of Supplier Engagement (which includes Communication, Transparency and Support) can help retailers deliver and maintain this accuracy. 

For suppliers to have complete clarity on the impact of the requirements on them, communication is key. Key to managing change and ensuring the increased importance on accuracy is understood.  There will be products, which potentially, were not previously included in compliance systems (because they were made onsite and to a different process) but will now need to be included, to ensure ‘one truth’ of accurate information. Good Supplier Engagement involves clear communication, not just in regard to the what (is required), but also regarding the why and the how to ensure adoption and compliance.

At S4RB we use AffinityTM to deliver measurable results in relation to the Three Pillars of Supplier Engagement.

  • Communication: Ensuring the right contacts at each supplier are actively engaged, using this to conduct product level surveys to aid the change process. This could be in the form of risk assessments (readiness, comprehension and impact) but also to then deliver the change (e.g. confirm products which should be de-listed or out of scope).
  • Transparency: In the context of Supplier Engagement, transparency is about clear performance metrics. As a supplier ‘How am I doing?’ for example, Affinity augments these communications with key performance indicator (KPI) dashboards to demonstrate accuracy. Such as identifying products on sale without active or up to date specifications, or similarly specifications which should be archived because products are no longer on sale. These KPIs are used to deliver on change, and to provide all stakeholders clear visibility of where action is required. For retail own brand teams, this is important given the scale of the task at hand; there is the need to ensure suppliers are informed and empowered to act where required.
  • The final pillar is Support. Establishing that Communications relates to the what, the when and the why. Transparency is, as a supplier, how am I doing? The Support element is then how to do it, and how to improve. Providing suppliers with a simple ‘how to’ video, or the all-important FAQ section, or facilitating a platform to ask questions, to minimise the impact on internal teams to support suppliers and allows suppliers to achieve more, on-time, right-first time.

To achieve compliance with Natasha’s Law will mean retailers need to risk assess across their own brand portfolio of in-store products. They will then be required to ensure accurate information is collected; Supplier Engagement will help to ensure this is achieved. Not just in order to achieve the deadline in a years’ time, but to sustain this. Utilising KPI dashboards to ensure that new products continue to launch (or products de-listed) with the accurate information at hand. Suppliers will be informed of what is required of them and when. Ultimately, own brand retail teams and suppliers working together as one team.

Tags: Food trends, Packaging innovation, COVID-19, law

James Butcher

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