In the guide
Sandwiches must be labelled with certain food information, which will differ depending on how they are sold.
This guidance is for Wales
There are different labelling requirements depending on whether sandwiches are sold by mass caterers and/or sold prepacked or non-prepacked. Prepacked labelling requirements are significantly more complex.
The term 'sandwich' includes a roll, bap, baguette, pitta, wrap, panini, bagel and similar products.
These are premises at which the sandwiches are prepared for consumption at the time of purchase; they include pubs, restaurants, cafés, stalls, school canteens, vans and sandwich bars.
The following information is required:
The information does not have to be labelled on the product and can instead be placed on a notice. The notice should be visible / available at the point(s) where the consumer can place an order (at the counter, in the menu if food can be ordered at the table, etc).
Allergen information can be given verbally, in which case a notice must be placed on display inviting customers to ask a member of staff for allergen information.
Full information on the provision of allergen information can be found in 'Food allergens & intolerance'.
You are not required to name the product but any name or description given must be accurate; areas that can cause problems are:
If prepacked sandwiches are being sold from a mass caterer the requirements for prepacked products (below) will apply.
The rules for mass caterers also apply to van sales, although if you purchase prepacked sandwiches to sell from your van the normal prepacked rules will apply (see below).
Non-prepacked includes the following:
Non-prepacked food has the same labelling requirements regardless of whether it is being sold from a mass caterer, shop, stall, etc as follows:
The information can be on a label attached to the product or on a notice.
Further information can be found in 'Labelling of non-prepacked foods'.
If you purchase sandwiches from another food business that are supplied without packaging they will be non-prepacked and you should follow the rules above.
If you purchase sandwiches from another food business that are supplied in packaging these will be classed as prepacked. Please refer to the labelling requirements below.
'Prepacked food' is defined in EU Regulation (EU) No 1169/2011 on the provision of food information to consumers as "... food and the packaging into which it was put before being offered for sale, whether such packaging encloses the food completely or only partially, but in any event in such a way that the contents cannot be altered without opening or changing the packaging …".
If you package sandwiches for sale to consumers from another premises you operate, or to supply another food business that will sell them to consumers, then the sandwiches are prepacked.
Prepacked sandwiches require the following labelling:
Manufacturers of small quantities supplying only local retailers may be exempt from needing to label their products with a nutrition declaration; further detail can be found in 'Labelling of prepacked foods: nutrition declaration'.
If the product contains any of the 14 allergens below they must be highlighted in the ingredients list:
Further information can be found in 'Food allergens & intolerance'.
If applicable the product will also need to be labelled with:
A full explanation of how to label your products can be found in 'Labelling of prepacked foods: general' and the other guides on prepacked foods that it links to.
Failure to comply may result in an improvement notice being issued, requiring compliance to be achieved. If the improvement notice is not complied with it is an offence under the Food Safety Act 1990. The maximum penalty is a fine and two years' imprisonment.
If allergen information does not comply with the requirements it is an offence under the Food Information (Wales) Regulations 2014. The maximum penalty is a fine.
Last reviewed / updated: October 2018
This information is intended for guidance; only the courts can give an authoritative interpretation of the law.
The guide's 'Key legislation' links may only show the original version of the legislation, although some amending legislation is linked to separately where it is directly related to the content of a guide. Information on amendments to UK legislation can be found on each link's 'More Resources' tab; amendments to EU legislation are usually incorporated into the text.
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