The Food Standards Agency has launched a public consultation on a proposal to make allergen refresh training mandatory for all food handlers at three-year intervals. The consultation, which opened this week and runs until 23 May 2026, covers England, Wales and Northern Ireland. Scotland operates under separate legislation administered by Food Standards Scotland.
The proposal follows a review of allergen compliance data collected since the implementation of Natasha's Law in October 2021, which extended mandatory full ingredient labelling requirements to pre-packed for direct sale food. The FSA's review found that while awareness of allergen legislation has improved significantly since 2021, practical compliance — particularly around verbal allergen communication, cross-contamination protocols and menu accuracy — has not improved at the same rate.
"Legislation alone does not change behaviour in kitchens," the FSA's consultation document states. "Evidence from our inspection data and from incidents reported to us suggests that knowledge acquired during initial training decays, and that the frequency of allergen-related incidents correlates with time elapsed since a food handler's last formal training."
What the Proposal Covers
Under the FSA's proposals, all individuals involved in the preparation, handling or service of food in a registered food business would be required to complete accredited allergen refresh training at least once every three years. The training would need to cover the 14 major allergens specified in retained EU law, cross-contamination prevention, allergen communication with customers and the legal responsibilities of food businesses.
Refresher training would be required in addition to — not in place of — induction-level training for new staff. Records of completed training would need to be retained on the premises and made available to environmental health officers on request.
The consultation asks whether the three-year interval is appropriate, whether the training should be accredited by a specific body, and whether there should be provisions for small businesses or seasonal operators.
Industry Response
Initial responses from the sector have been mixed. Several large hospitality groups have indicated support for a consistent national standard, arguing that it creates a level playing field and removes the competitive disadvantage faced by operators who already invest heavily in allergen training.
Smaller operators have raised concerns about cost and practicality. The Nationwide Caterers Association has pointed out that for a sole trader or micro-business, the requirement to send staff on accredited training every three years represents a meaningful overhead — both in direct cost and in lost working time.
Training providers contacted by The Mise have noted that existing allergen qualifications from bodies including RSPH, Highfield and CIEH already provide the content the FSA is describing. The question for the consultation is whether those existing qualifications would be accepted, or whether new accreditation criteria would be required.
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Natasha's Law: Five Years On
The consultation arrives five years after Natasha's Law came into force, a landmark that the FSA marked earlier this month with a review document noting both the progress made and the areas where compliance remains inconsistent.
That review found that the majority of registered food businesses are now meeting the labelling requirements for pre-packed for direct sale products. However, EHO inspection data for the period 2023–2025 shows that allergen cross-contamination incidents remain a persistent problem in high-turnover food service environments, with the majority occurring in kitchens where staff turnover is highest.
The consultation document is available on the FSA website. Businesses, trade associations and individuals are invited to submit responses before the 23 May deadline.