Wednesday, 10 September 2014

FDIN Roundup; “Free From” Retail and Foodservice!10th and 11th September 2014!!Arriving at the Holiday Inn Bloomsbury I was immediately confronted by the issue of the following 2 days-there were no bacon butties, as the hotel couldn't guarantee they would be "Free From"! !!There was a bit more space in the room than usual, and after Jeffrey had assured us that the space was not a dance floor, we made a start with the usual history of FDIN, the table briefings, and so on..!!Jeffrey Introduced Michelle Berriedale- Johnson (MBJ) in her trademark hat as the" fount of all wisdom and knowledge- who happens to live around the corner from Jeffrey. He apparently used to be invited to her house for tastings of new free from products, which used to be "absolutely disgusting".!!Michelle's charts are an excellent overview of "The rise and rise of free from". This was the !7th or 8th Free From event, and the sector has in the meantime grown from being comprised of just "small and disgusting products" to be one of the fastest growing sectors in food.!Michelle pointed up all of the speakers, who represented a good mix of data, science, and personalities.!!Michelle started with the consumer- who eats our products?!First the medically diagnosed; a large group, not just coeliacs, but also including allergy sufferers and those with IBS (Irritable Bowel Syndrome). Then there are the self diagnosed food intolerants, who have chosen Free From products as a healthier, more acceptable lifestyle. Benefits are attributed to gluten free but that may only be part of the story.!The fastest growing sector is those who choose for lifestyle reasons-the lifestylers.!!Timeline- things started around 2005 with poor quality products aimed at coeliacs. There was growing interest from major manufacturers about 2010. Smaller manufacturers then sorted product quality; the Brits (Genius) sorted bread, the Italians did pasta, and the Belgians did soya milk. There was serious engagement from supermarkets, started probably with Tesco.!Online shopping has helped the small suppliers to get established.!Prices have started to come down, but are still too high.!In 2014, improved quality and availability means it's easier to find and to choose, especially for those who do not need to eat FreeFrom.!!Regulation- allergy has always been covered under general food law, but suppliers could plead ignorance! Until now. EU legislation in 2003 and 2006 required declaration of allergens in packaged foods, not Foodservice. It is this revision that gave rise to the FIR regulations; a major pain for Foodservice - to be covered tomorrow.!However the Gluten free- 20 ppm 'safe' limit established in 2009, and now in force since 2012, has had a positive impact on supply and market growth. There is a massive amount of research ongoing to establish safe levels of other allergens and so allow declaration. This would then reduce the 'May contain' labelling which is a bugbear for

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Wednesday, 10 September 2014sufferers as it doesn't define the level of risk. The changes have however failed to address the issue of contamination.!!What's holding back development?!Lack of action levels and poor distribution (including food on the move, but MBJ gave a good plug for Costa in petrol). Price premium has to be limited to 10-15% not up to 200%. Nutritional profile has to be improved generally to improve all round health and keep the lifestyle “FreeFromers" on board. !!The Future!There is huge optimism for future growth in the sector, as not only allergies and intolerances that require a restricted diet continue to rise, the obesity and diabetes increases in particular also drive growth, as eating FreeFrom products is seen as helpful in weight control.!Food service and eating out is a major opportunity for manufacturers to produce prepared and segregated products. !Family catering- producing FreeFrom products that can be consumed as the “normal” product by the whole family even though only one member may medically need them.!Food to go, in line with overall trends is a growth area.!Worldwide expansion; Europe and US are where the conditions and the diets started, now they are both growing in Asia, the Middle East, Africa, and South America.!!www.freefrommatters.com!!!!Louise Vacher, from YouGov, then took over, happily taking time out from Scottish poll research.!YouGov have conducted new research, called 'Understanding food allergies and intolerances-the consumer viewpoint‘ using an online survey of 1000, with a nationally representative sample, boosted for allergies and families. Note when using the very useful slides that the figures are all self reported.!!22% of the population now consider themselves to have a food allergy or intolerance. This is 5% up on 2011, and equates to 31% of households being affected by allergy or intolerance.!Dairy and gluten are the most common issues and about 2/3 overall are self diagnosed or suspected. !There is a huge bias towards women who say they suffer; 63% vs 37% male. Other skews are minor- class and geography, but there is some up-market and southern bias.!5% of all households have a child with intolerance or allergy, which means that 17% of households with children have an allergy or intolerance.!Attitudes among the general population are

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Wednesday, 10 September 2014interesting- 77% believe there seem to be more people with allergies and intolerance, but 62% believe too many people self diagnose their food allergies and intolerances.!!Only a small minority avoid allergens altogether. Most eat differently but together.!Avoidance is the main strategy, and reading labels is crucial.!There was a barrage of statistics which are well worth perusing…!!Dealing with children's allergies is similar to overall strategies but more so. 58% stick to safe foods and cook from scratch, but 48% agree that there are not enough FreeFrom products for children.!Most find it easy to find and understand information on labels, but “on the go” and children's parties present the biggest challenge. !45% say it's easy to find foods that meet their requirements when eating out in restaurants, ,but improved menu information would be welcomed. 38% say they have to ask staff as well as look at the menu. Only 14% agree that restaurants offer sufficient information to allergy sufferers!!Who is buying?!Half the population are not aware of FreeFrom foods- this was a surprising statistic and provoked quite some discussion in breaks. For what it's worth, my personal suspicion is that consumers responding to research may not recognise this term that has been invented by the industry. That is not to say that they don't recognise the collection of products that satisfy the general needs for allergen avoidance. Maybe we've got too wound up with our own terminology? !69% of purchasers are female, and 55% do not suffer from or have anyone who does suffer from food allergies in the family.!In terms of outlets, Sainsbury, CoOp, Marks and Spencer, and Holland & Barrett over index vs national.!Generally FreeFrom Foods provide more choice, are generally healthier, and are ethically better. !Expense and poor taste are still holding the category back, but there is strong awareness that range and quality are improving, although there remains room for improvement.!The main barrier to purchase is lack of need due to avoidance of the food altogether, plus cost, and availability.!!!!!!�3

Wednesday, 10 September 2014!!Key takeouts;!This is an issue for 1/3 of households, and one of the main coping strategies is avoidance, so not only is there an upside potential to providing specifically designed food products, but there is a downside in that your products could be "avoided" by this important group.!!MBJ's comment in the link was that the most amazing thing is 55% of buyers are life-stylers.!!!!!!!Then we were on to more numbers from Chris Brockman, from Mintel.!He took a global perspective, with "gratuitous mention of beer and pizza" on his front slide, and later...!Expansion of the concept is driven by Fear; recalls, allergies, awareness of ingredients etc. !But fear translates to opportunity. Less than half of consumers agree that the food industry provides food that is safe.!"Naturally good for you" brands are growing very strongly - Chobani and Pom are good examples. The US is by far the most developed market. 72% consumers are "not diagnosed".!The concept of "FreeFrom" blurs however; to some it includes sugar, meat, preservatives, additives, salt etc. To me, this is a significant factor- when measuring "Free From" foods, are we in danger of obscuring the true core of allergy avoidance by including all or any foods that merely claim to have an absent ingredient? How big a factor is this in the excitement around "Free From" growth I wonder?!The point was underlined by Chris's rhetorical question, "is sugar-free chocolate about to boom"? With Stevia based chocolate targeting mainstream, it would appear so, but doesn't including foods like that in our definition rather blur the distinction of allergy avoidance?!On the same tack, "Suitable for diabetics" claims could be set for a boom as attention to diabetes grows, and products based on the FODMAP diet, originally designed for IBS sufferers for digestive comfort are set to grow. There is also an increase in personalised diets- "one of the strongest trends we are seeing". It felt to me as though there was some conflation of trends and categories going on here...!

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Wednesday, 10 September 2014!Launch activity of FreeFrom Foods is increasing. Globally more than 10% of all launches claim gluten free. The US, UK, Germany, Canada, Italy, and Spain are the main markets for gluten free, and lactose intolerance is a similar list but with the addition of Finland and Austria.!Company activity is more fragmented, and in Europe 4/10 of the most active are retailers (Tesco, Asda, Morrisons, Aldi ) but Dr Schwars and UDIs are becoming prominent dedicated brands.!Big brands launching in the last year include Braille, Weston Foods, and Kraft. But there have been failures, notably Heinz, who overplayed the Gluten Free positioning in a category where it is not so relevant. !Almost half of all consumers think that FreeFrom foods are higher in additives, fat, and sugar than regular foods.!The successful products seem to be the ones that have a holistic approach to health, designed from the bottom up, with a range of genuine health benefits including Free From.!Indulgence is still important, with Ilumi and UDIs given as examples that draw in a wider consumer base based on enjoyment and appetite appeal.!Chris returned to beer and pizza to illustrate these 2 "laggards" in a chart that shows penetration of gluten free products in grain based products. Contrast with snack bars, where 22% of US and 13% of European products claim Gluten Free.!Mintel (Chris's) quote in 2013 was attributed to the success of Schwan Freschetta pizza. It is now outselling mainstream products compared to average evolution rates since launch.!Mintel are starting to see some Gluten Free beers in the US. They are very limited in the off trade, but major brands are apparently on their way, based on their interest in the Mintel figures.!In lactose free, Germany leads the way, where it's moving to mainstream. Other platforms based on intolerance and digestion are emerging. There is also huge growth in the US in dairy free- nut based milks etc are predicted to travel over here, as they have begun to do.!!Chris admitted that his annual market growth figures will be updated in 2 weeks time, but in general the growth rates are slowing but it's still a very significant category.!!!!!�5

Wednesday, 10 September 2014Chris left us some suggestions for future growth strategies ;!• Adaptation of "on the go" products to gluten free!• Think indulgence!• New demographics- kids and baby food!• New geographies!!Chris's summary was that growth rates will slow but it's a big market that's here to stay and represents a fundamental shift in the way consumers approach food. Also customisable diets and individualistic eating patterns will become the norm. !!After the table team brainstorm and anchoring we had a break, during which at least some of the discussion was around "what's new?", but there was surprise from some about the prevalence of life-stylers. My concern remains that growth at the edges of Free From (in the heart of mainstream grocery) will the weaken Free From core.!!MBJ then introduced Dr Andrew Clark from Addenbrokes Hospital to the stage. He is a !Paediatric allergy doctor and sees children with real food allergies, not intolerance. We weren't his usual audience, but how telling for the FDIN audience that he was by no means the first clinician to address us. (apologies that his slides are not available)!Andrew gave us the facts and definitions of allergies and intolerance. Allergies cause immediate reactions. Intolerance causes slow burn troublesome symptoms, primarily digestive and skin problems. Anaphylaxis is at the severe end of the allergy spectrum. Food is responsible for about 1/3 of anaphylaxis in the US. The main focus of research is peanut allergy. Reactions include mouth itching, abdominal pain, diarrhoea and vomiting, skin rash and swelling, wheezing, collapse and low blood pressure.!In a graphic explanation of the impact of Anaphylaxis Andrew showed us a video, shot by a sufferer of himself at various times into his reaction. It's available on YouTube, and brings home the real and severe health issues for true food allergy sufferers.!Looking at trends data shows 1.2 points per decade increase in incidence overall, and significant differences between ethnic groups.!Having said that, most allergies are most prevalent in the young and resolve over time. Peanuts are the most common cause. !Again the current best practice is to avoid the foods containing allergies- it may be stating the bleeding obvious, but if you are allergic to, for example strawberries, you will stop eating strawberries.!Then there is a need for the collaborative education of the wider family, and correct diagnosis (but a plea not to over-diagnose - rickets is not unknown in London as a result of well meaning but misguided Mums giving their children an unbalanced diet).!Deaths and near fatal reactions still occur, and peanut allergy sufferers are measured as having a worse quality of life than diabetes sufferers.!The major point is that clinicians are working on thresholds for allergens other than Gluten, the only one to have an agreed threshold of 20ppm. The studies are Trace Studies, and take account of the many other extrinsic factors that are involved, including the time of day, exercise taken etc. Andrew is undertaking a study with 100 adults with nut allergy being fed chocolate with varying amounts of peanut, after varying conditions including sleep and exercise.!!Immunotherapy is one way of reducing the impact of food allergies, and it is an old and well known approach. 100 years ago it was introduced in the treatment of egg allergy, where egg in small but progressively larger doses was administered.!Peanut immunotherapy starts with 2 mg peanut protein, with the dose again increasing over time. Patients can eventually eat up to 5 peanuts a day, and their quality of life improves immensely.!!�6

Wednesday, 10 September 2014Dr Clark and his team have had some great publicity- except the Cambridge Evening Telegraph aligning his picture with a cocaine dealer headline...!!Q&A!Does early life avoidance lead to intolerance? - the jury is out on whether this is a cause.!Accuracy of diagnosis is key- over-diagnosing will lead to over avoidance!Mainstream merchandising or specialist section? It's up to retailers. It's not clear cut which sufferers would prefer.!Is "free from everything" a positive trend? - it's complex, but expansion of the category is good...!Pricing as a barrier - premiums are justified by low volumes and high costs. Premium is good for some (producers and retailers), but not for sufferers. !How to use an adrenaline pen? Carefully.!!The after lunch slot was perhaps not the ideal schedule for a session on legal compliance and regulation, but Brian Kelly, a senior Food and Drink Lawyer, from Covington and Burling valiantly gave it a go. He is experienced in the defence of companies and labelling issues, and he focussed on the "incentives to comply" which is, on reflection, an elegantly positive alternative expression to the penalties for breaking the law. These can be civil or criminal, and the main defence against a criminal act (actus reus) is a lack of guilty intent or guilty mind- (mens rea).!There is a due diligence defence enshrined in law, and prosecution must be beyond reasonable doubt. !At this point I should probably add a disclaimer of my own, i.e. that these notes should not be taken as the basis of legal advice, and you should check Brian's charts directly and consult your own adviser before taking any decisions!!For civil remedies- (see list) the main redress is damages. In the case of product liability- if product is defective, there is automatic liability. The key area in labelling is failure to provide warnings. !!Brian then described an Allergen Case study, where unintentional cross contamination may have constituted a defective product. The "may contain" disclaimer may be a defence in these circumstances but it depends....!Food still on the market after it's "use by date" is deemed unsafe, for which the are penalties, but this opens the door to frivolous claims, for example in 24 hr outlets one minute after midnight!!

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Wednesday, 10 September 2014!Negligence. There is a duty of care for operators who must take all reasonable steps to ensure safety. The case of Bhamra v Dubb illustrates this. A guest at a Sikh wedding, who reasonably expected no egg to be present, ate product containing egg and suffered an allergic reaction. This was caused by the operator, having run out of a certain dish, who outsourced supply and didn't check the product was egg free. Sadly the customer died, and the operator was fined £0.5m for not taking adequate care.!!Fraud. There is heightened awareness after "Horsegate". Fraud is the false description or presentation of food. Cases were shown that that illustrate the need to be accurate in description. Stark Naked Foods was one, where ingredients that didn't match their description were used.!Common Law fraud - is covered by the Fraud Act 2006, illustrated by the fraudulent trade in non organic food marked as organic. !!Unfair commercial practices. The CPUT regs prohibit unfair commercial practices, including web and advertising material.!!Health claims. "FreeFrom" may be interpreted as a health claim and so has to comply with EC regulations. There have been a number of asa adjudications and some prosecutions.!!!!!!!!In Summary...!Mind the gap- think beyond food labelling laws to others that might apply and adopt a process of continuous risk assessment.!!!!!!!!Brian was followed by another expert, Dr Rachel Ward, from RWard Consultancy, who covered the important area of Action Levels and Allergen Thresholds.!Starting with a warning that a lot of slides will be skipped, Rachel moved fast over some very technical content. Faster than my typing at times I'm afraid, but here are the key points:!!Allergenic Foods are unique- 160 + foods are known to provoke reactions in sensitive individuals. Adverse reactions can be at very low

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Wednesday, 10 September 2014levels. !There is a need for the industry to be clear and consistent across products, brands, and markets.!For products where allergens are intentionally present, labelling declaration is mandated. Risk communication is expected but not mandated. However given the absence of agreed thresholds for most allergens declaration depends on a degree of risk management that will differ from company to company, hence inconsistency and consumer confusion. !The future needs a quantitative approach based on clinical thresholds and agreed action levels. !Risk and Hazard. Hazard is the allergen, risk is the likelihood of an adverse effect.!!!VITAL labelling scheme in Australia created a calculator to translate Reference Dose into Action Level for individual foodstuffs.!!!!!!EFSA is a mess. Working to the lowest threshold, below “free from”!!!!!!!!!Rachel suggests two categories- Free From foods and mainstream foods. - with “may contain” and “Free From” actions levels. !!!I got the distinct impression that there was much more work to be done in this area before we get clarity on what can be safely and legally declared. !!!!!!!�9

Wednesday, 10 September 2014!!Following some serious brain strain, the Genius case study was welcomed as something altogether "Lighter and more entertaining....".!Lucinda Bruce-Gardyne, founder and Roz Cuschieri, CEO, made a good double act, covering the story of this now almost iconic "FreeFrom" brand.!Lucinda first covered the "Indicators of product success":!!Sales- an unsurprising metric, a simple rapid growth in top line. Based on early sales growth, Genius took the decision to build quality capacity early on, and move into new channels and markets quickly. Demand for new products then grows, based on success of the core.!!Endorsement from stakeholders- which includes excitement from consumers, and feedback from children - they never lie. Other obvious signals are enthusiastic write-ups from journalists, product demand from retailers, manufacturers wanting to work with you, whether they are trying to collaborate, copy, or compete.!!But with success comes challenges- IP protection, sticking to the right priorities, and maintaining product quality.!!Roz talked about the Expansion Options; asset rich, asset light, or a combination.!They started with asset light- with the benefits of low team numbers, avoiding resource and operations challenges, and allowing available investment to be targeted at brand building. They followed this model for 4 years. However it comes with challenges around Quality, IP protection, and trade relationships. Clear and concise contracts help to mitigate the challenges.!!The asset rich model brings freedom, quality, innovation, recruitment of skilled resource, fuller relationships with customers, control over costs, and tangible assets.!!They bought 2 of Finsbury Foods bakeries last February and haven't looked back since.!Since Feb 2013 they have launched over 15 products in 7 countries, but with progress comes new challenges and change.!!!!�10

Wednesday, 10 September 2014!Lucinda returned to talk about the "really important factors" - maintaining brand and cultural values. This is achieved, in no small part, by establishing a permanent team, training them, having clear lines of communication, and providing the right tools for the job.!!In summary, they welcomed the expansion and the asset based strategy they followed to provide the capability. !But there are lessons to be learned- see this slide.!!The most important thing is that they enjoy the ride...!!!!The final Q&A was not too enlightening, as the main questions were about crystal ball gazing and the core message back seems to be to expect "more of the same". We can expect growth of FreeFrom in more categories, lower prices, better quality, better shelf life, etc etc. There will be more integration of products into mainstream. There will be more gluten- and lactose-free products in the freezer, the chiller, and in food on the go. Perceptions are changing to be more mainstream, with retailers giving more space and better availability. !The downside seems to be legal and regulatory; EC harmonisation, more recalls, more advertising disputes etc, etc.!!So that was it, for retail at least. For those of us staying on for the following day's Foodservice session there was more to contemplate in terms of legislation and implementation challenges. However the abiding thought in my mind for retail was that although the growth and "normalisation" of Free From is without doubt a great benefit to allergy sufferers, the "bandwagon" of FreeFrom may prove to be rolling along so fast that there are unintended consequences ahead. The attraction of all those "lifestylers" and the ambitions of retailers and manufactures alike may lead to a collective watering down of a core proposition that is founded on an important clinical functionality.!!!!Day 2 was devoted to Foodservice and it's special challenges of meeting the new FIR regulations coming in December this year.!The audience was about 70, a more select group, understandably so. There was some repetition of Day 1, again understandably, especially in the introductions. Michelle Berriedale-Johnson (MBJ) was however introduced by Jeffrey today as the "very vortex of Free From" - and he again recounted the story of the early years of poor quality products available in Free From, and the huge improvements in quality that have taken place since.!!MBJ then briskly introduced Louise Vacher from YouGov, to repeat her excellent presentation from yesterday. See above for the notes...!!�11

Wednesday, 10 September 2014Michelle's key takeout was that 75 % of all respondents agreed that restaurants should cater for allergies but 47% do not think that allergens are sufficiently well flagged. Her key point is that this represents a major opportunity for pre-packed, segregated, uncontaminated foods, plus training, packaging, and recipe and menu development. As many of the audience will have gathered, the business opportunity of providing a solution for those searching for a suitable or safe restaurant on a restricted diet is not just about selling the single meal, it's about selling the meals to the party that accompanies the allergic or intolerant consumer.!!Emma Read from Horizons, a specialist Foodservice insight agency, joined us to take us through !"The numbers game" or how Gluten Free and Wellbeing are creeping up the data tables.!Horizons pull together data from various sources to interpret insight for Foodservice. !The scale context is of course huge; 260,000 outlets and £45bn sales in Foodservice in total.!Emma showed some interesting slides demonstrating that the focus of data on sales value obscures the outlet numbers, and masks the importance of small independent outlets where communication and penetration are important.!In a separate survey to YouGov, the bias to wellbeing and gluten free foods among females was repeated, and awareness of labelling legislation is increasing, although 2/3 are still unaware of the impending changes.!Again, and rather tantalisingly, new numbers will be available in October. Emma also stated that awareness in the industry is increasing, but the current numbers don't show it.!!Gluten free is the top issue affecting the dishes operators serve now and in the future.!Horizon's Menu survey from 115 operators shows a general increase in healthy/lifestyle eating, with a specific and significant increase in gluten free, wheat free, and "flourless" options.!23% of restaurant brands now have gluten free options, up from 21% in summer 2010, and the number of gluten free lines available has increased by 300% since summer 2011.!There are some good examples of chains menus that have taken the opportunity seriously and developed dedicated gluten free menus (Carluccios, Las Iguanas, Pizza Express etc)!In conclusion it's changed from a marketing message to what consumers want and expect, and is now an active and significant reason for choosing a location. !!Q&A!Do we know why Foodservice doesn't have such a price premium compared to retail?- Some speculation, but not really known.!What's the difference between allergy and intolerance? Allergy is medically diagnosed and acute in nature.!

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Wednesday, 10 September 2014!!After a coffee break, Sarah Sleet of the Coeliac Society and Rupi Zani of Pizza Express did a double act of accreditation and the operators story.!Sarah started by outlining the history (long) and scale (big) of the Coeliac Society, a charity that works to improve the lives of coeliacs, increasingly working with manufacturers and operators.!Because of the strong connection to their members, Coeliac UK are a source of insight and understanding for the Industry. One of the key issues for sufferers is eating out.!!Coeliac disease is not an allergy or intolerance, it's an autoimmune response, with similarities to type 1 diabetes. It can lead to more serious problems and can be clearly diagnosed. Approximately 1% of the population suffer and approx 24% of them are diagnosed. !The opportunity for gluten free catering was restated- 600,000 customers who don't eat alone. !Non coeliac gluten sensitivity is an additional condition that is yet to be quantified, but covers some of the self diagnosis that is happening among some groups of consumers.!The FreeFrom market growth in retail is mirrored in Foodservice and is not a fad. The catering opportunity hinges on the numbers who would eat out if more gluten free options were available. Coeliac UK's estimate of the opportunity is £100m, plus the "lifestylers".!Over last 10 years the awareness of coeliac disease among chefs has grown from 10 to 80%, mirroring the population as a whole.!Gluten is a protein found in wheat, barley, rye, and oats (a similar protein)- but pure oats can be used in a gluten free dish. Gluten legislation is covered by an EC regulation that allows a standard of less than 20ppm for a GF claim. There is another claim of "no gluten containing ingredients"- a voluntary claim to cover foods where no guarantee is given, but the operator has minimised cross contamination in addition to not actively including gluten containing ingredients.!The new EC regulation represents an opportunity for suppliers and operators.!Coeliac UK conducted research with operators that showed it would be possible to deliver gluten free. They have developed a training and accreditation programme that has been very popular in both private and public sector. The accreditation signposts establishments that can cater for gluten free, and benefits customers and operators alike.!!Rupi from Pizza Express took over. She has taken the whole process from start to finish. It started with customers arriving with their own pizza bases for chefs to make up. Pizza Express worked first on the product quality then worked with CUK on accreditation, and testing. They went to NGCI (no gluten including ingredients) first, then did research that showed that

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Wednesday, 10 September 2014consumers wanted complete confidence. Late in the process they decided to move to gluten free flour for the restaurants, and got accreditation for full gluten free. The strategy is to maximise the confidence and minimise the fuss around gluten free. So they don't have separate menus and every topping can now be made on a gluten free base.!!In summary, Sarah underlined the importance of accreditation to giving consumer confidence, and showed a video which told the human stories behind Coeliac disease from sufferers and their families. Trust is obviously the issue for consumers.!!We were left with the thought "Is gluten free the new vegetarian? - 30 years ago vegetarians were trusted as fussy eaters, today it's on every menu.!!Sara Adams from "Happen", an NPD agency, was then introduced by Jeffrey, who explained the background to the "FreeFrom everywhere" challenge, reframed as an opportunity.!!After the introduction to Happen's proposition and thorough mention of their credentials and client list, Sara ran through a couple of non food examples, Sanex Zero, built on taking things out, and Arla's move into formula milk, built on purity and organic; "Baby and Me organic".!!FreeFrom is not just for the "super users", it includes the lead users and the "tag along" users- these larger groups are driving the volumes and are particularly important to caterers who make an inclusive offer. !The difference is to offer a positive lifestyle choice rather than a negative, "cannot" approach.!They have identified the "Gen Z" parents who over-protect, reduce risk, and want to do the best for their kids. Gluten Free foods are typical purchases for them.!Trends that "Happen" have identified:!Cutting out not controlling - The Pendulum has swung from too much to none- eg the 5:2 diet.!Nutritional Density!Positive Eating, the example of Kallo Foods was used.!!We should consider what eating out should be rather than what it is- it should stress free for all groups.!Free From growth can come from market growth, share growth, or new markets.!Happen's proposition includes innovation around existing assets- so they have some advice on how to use current assets to supply free from everywhere: reframe the current portfolio, provide the support framework, and develop new foods and packaging.!!�14

Wednesday, 10 September 2014!!Sara finished with 5 top tips for Foodservice:!• Sell it in to the business!• Be Positive!• Be Inclusive!• Think Smart!• Remember the cost of doing nothing - don't miss the bandwagon.!!Q&A!Does the lack of price premium in Foodservice reflect a more inclusive strategy on the part of operators compared to retail? Generally yes. Costs are absorbed in the mix, which often has higher margin items. The prize is of families and groups choosing the outlet.!Where do complaints come from? Reaction claims.!How does Coeliac UK advise competitors? With commercial confidentiality. !!After lunch, Simon Flanagan, RSSL's senior consultant for food safety and allergens spoke on the management and risks around food safety and allergen control. In broad terms, management can be proactive or reactive. Reactive usually takes place on Friday at 4.45pm!!Simon's work has an obvious connection to the avoidance of severe reactions, and he started with a perfectly permissible plug for the Anaphylaxis Charity, whose 20th Anniversary it is this year.!There are 20-30 deaths each year from Anaphylaxis, the majority occur eating away from home. Simon told the sad story of the 12 year old boy who died from eating a contaminated curry that his parents had been assured was safe.!He made the key point that the FIR regulations relate to allergens that are used as ingredients, not cross contamination.!Worryingly, 43% of restaurateurs are not aware of the allergen law deadline.!!Back to risk assessment and management:!There is a hierarchy of risks in Foodservice .!Risk assessment- the principles of risk analysis are covered by the Food Safety Act 2006.!Terminology and definitions come from the Health and Safety Executive. !Applying these principles to allergen risk assessment is tricky- the estimation of risk is subjective, the likelihood is subjective, the severity of hazard depends on the allergenic ingredient, the sensitised individual, and the spectrum of reaction.!The ultimate in risk management leaves an empty factory with no employees!!So the best practice is to have a targeted risk assessment incorporating hazard characterisation. !This starts with allergen mapping- listing the allergens used, what recipes they are in, and where in the factory the ingredient or product is, physically.!The process starts with labelling, of every primary and secondary unit. Storage needs to be organised and segregated. When ingredients are decanted, there is clear risk of contamination. In production or preparation, equipment must be dedicated and properly and safely labelled. Training is vital in everything, right down to the use of PPE for example, which might be contaminated. The higher the protein the higher the allergen. !

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Wednesday, 10 September 2014!!The 6 key considerations for hazard characterisation:!!Attention to the cleaning regime is critical- different allergens have different characteristics.!Then you need to define the allergen control plan. !!The opportunity in catering is huge, as we have already learned.!Recommended resources are available from the FSA for use in kitchens and front of house.!!!!Now we were to get down to the nitty gritty of Foodservice supply, with presentations from two operators. First, Graeme McKenzie from 3663, took the stage. He is in charge of offer development, and he started with 3 numbers that were intended to make us sit up and take notice; !• 23% of outlets serve Gluten Free!• 73% of outlets would consider adapting dishes to make them Gluten Free!• 137% growth in the number of Gluten Free Lines.!!The new FIR regs mean that this issue is on all outlets’ agendas, or should be. !Life in the commercial kitchen is not much of a breeze at the best of times, and 3663 aim to make the chefs lives simpler- by minimising complexity.!!In what was a corporate presentation of approach and policy, we heard that the key 3663 ingredients in general are choice, ease, value, delivering what's important, and doing what's right. Delivering Gluten Free ticks all the boxes. 3663 deliver brands and their own label, and offer advice and consultancy based on a comprehensive database. !NPD follows a strategic process with Salesforce input, and innovations must satisfy 5 key criteria to be part of the range: !Quality, relevant, credible, innovative, supported. !The Gluten Free dish must be able to stand on its own merits not just as a Gluten Free option. !Gluten Free has been identified as a key strategic development opportunity. 3663 worked with Coeliac UK to understand the issues and develop an appropriate offer.!Great progress has been made but Graeme admitted they need to step up innovation in main plate dishes.!!�16

Wednesday, 10 September 2014!Food has to be visually great first. Their FreeFrom range offers both scratch and convenient offers.!3663 work on adding value via support to their salesforce and operators, education of customers, making free from easier to digest. They have a rapid ingredients Checker.!FIR is a massive issue but they are nearly there with information on 15,000 products online.!They expect FreeFrom to follow the same path as the vegetarian revolution. !In the future, information is king; expect online access, QR codes, Google glasses etc to revolutionise choice in eating out.!!!!!!!Wan Mak, the Head of Nutrition and Dietetics from Sodexo followed Graeme. Sodhexo is a huge global operator. They operate in 80 countries and employ 43,000 in the UK and Ireland alone across 2,300 sites. Turnover is £1.1bn.!Their business is hugely diverse and operates in all sectors; corporate, health care, education, justice, defence, sports and leisure, and remote sites like oil rigs.!Allergies are particularly visible in the children's education sector. !The BHA (British Hospitality Association) estimates the implementation of the EU Food Information Regulations will cost around £200m per annum.!!Sodhexo’s approach in practice is that, as the regulations state, they, along with all Foodservice companies must have 100% knowledge of the 14 named allergens contained in the ingredients to consumers.!A 40,000 item database, with all ingredients, has been gathered since 2009. !There are quite some challenges with getting the correct and sense checked information from suppliers, particularly small artisan suppliers. !Providers can no longer say 'I don't know' or 'it may contain all allergens' so they have worked with consumers across all the different venues, that have different needs, and the different skill levels in their own staff via a vast training programme. An interesting point here- cooks follow recipes, chefs tend not to, so it’s the flexible and creative nature of Chefs that causes problems in the new regulated environment.!Their massive training package includes online packages, refreshers, validation, and a diet manual. !!!!�17

Wednesday, 10 September 2014!They have worked to create a culture among chefs where allergies are inclusive, IE cater for everyone. Within the competitions they run internally, there are now gluten free and free from categories.!There are still challenges in auditing, developing consumer understanding, and data management and continual updating.!!!!!!!!!!Chris Hook, Warburtons Free From Director, from Warburtons Newburn Bakehouse was the last man standing, and he made quite an impact by throwing a number of stress balls into (or at) the audience. Not too much damage was done.!!His presentation was fundamentally the story of Newburn Bakehouse and the success of Warburton’s Free From business in developing a mainstream platform. The Newburn business started in 2010- and had a struggle at first, before appointing Chris who had just exited his own gluten free bread business. !The approach is to look at the main, general market trends in the healthy eating market as a whole, incorporating all the benefits demanded by the consumer seeking food with added benefits. The widest context is important here, it’s not developed as a specialist niche, clearly.!The factory is now gluten, wheat, and dairy free, not just gluten free.!Warburtons have researched not just among Coeliacs, who are at the centre of the market, but also the intolerants and the lifestylers. They are the ones that are driving the overall quality as their taste expectations are high having switched over from mainstream. !According to Chris, 30% of consumers are now eating gluten and wheat free regularly.!Consumer tends for core bakery are

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Wednesday, 10 September 2014also relevant for Free From NPD- health, indulgence, convenience.!Warburtons Sandwich Thins are the most successful new product introduction since the core Toasty loaf. So Newburn have gone on to launch Free From versions, and even better have achieved the same quality levels as standard product. The key desire for Coeliacs is to be “normal”, and for products, ranges and quality to match regular product.!Warburtons had not previously had any business in Foodservice, so there has been some learning to be done, but they have been very successful in gaining new listings.!The problem they face in retail is keeping products on the shelf. Chris told the story of a customer driving 147 miles when he heard that seeded wraps were available. FreeFrom products can become destination purchases.!Free From and Coeliac consumers become very brand loyal, and Warburtons have visited groups all over the country to build trust and confidence. Availability is crucial in Foodservice and especially in food to go.!They partnered with Starbucks to make a pre-filled wrap as a test that got rolled out before the end of the test. They had the same success story with Costa and Pret.!!Chris showed a Video of consumer vox pops that illustrated the opportunity in food to go, and the satisfaction that sufferers get when they choose a gluten free outlet or product.!Price is less important for them, compared to issues of trust.!Starbucks veggie wraps provoked great reactions from people being able to feel normal, and access gluten free food on the move in a national chain. They bring their friends....!!One overall message to be taken away was let's be normal!!!Chris listed some hazards and pitfalls and how to avoid them:!Understanding what's important to free from consumers - exactly the same as regular consumers!But there are some differences around defining the proposition, and managing demand vs waste. They are more a craft small batch bakery with high labour costs, and price, quality, allergen management and staff education are all key considerations. Newburn always comes out top in company wide engagement scores however.!!!!!!�19

Wednesday, 10 September 2014The benefits of a clearly thought through FreeFrom strategy are obvious to Warburtons in the capability they have in Newburn. Their bakery expertise in a dedicated facility supported by the UK's no 1 bakery brand and experts within free from has delivered award winning innovation and built the brand strength of Newburn Bakehouse. !!So that was that, and after some rather forgettable final Q’s&As and the presentation of the “tenacity award”, we were off into the Bloomsbury sunset. I was left thinking that the historic niche abnormality of FreeFrom, driven by those who really need true allergy avoidance is quickly being replaced by the mass market, inclusive approach to FreeFrom that makes sufferers feel normal and makes their lives a bit easier. In the process it makes marketers and developers feel there is still growth to be had in at least one sector of the UK food market, at least for now.!!!Comments and feedback welcome.!!!Tim Nicol!tim@mihcentre.co.uk!www.mihcentre.co.uk!@nicoltim!!(Written as a supplement to the slides available on the FDIN Website as a service to fellow delegates from FDIN and Tim Nicol. Views expressed are not necessarily the opinion of FDIN.)

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