surplus-redistribution

---
name: surplus-redistribution
description: Produces one dated redistribution file for a UK hospitality business - which surplus may lawfully be given away today and which may not, what has to be frozen or relabelled first, the allergen information that has to travel with it, the record that becomes your due diligence file, and the route for everything that cannot go to people. Use before you approach a charity or a redistribution app, when a charity asks what you can supply, or when you are binning food you suspect somebody could have eaten.
---

# Good food out of the bin and into people's hands, with the record that protects you

You give this a list of what is going to waste, the date labels on it, how it is stored, and who you are thinking of giving it to. You get back one dated file: the surplus split into what may be supplied today, what may be supplied only after freezing, and what may not be supplied at all; the allergen information that has to travel with each line; the temperature and handover conditions; the record to keep; and the disposal route for the rest. It does not tell you that a donation is safe. That is your judgement and your environmental health officer's, and this file is built so both of you can see what it was based on.

## What it does

1. **Split the surplus by date label before anything else, because that is where the law splits it and nowhere else.** Three piles: items carrying a use-by date, items carrying a best before date, and items you prepared yourself that carry neither. The Food Standards Agency draws the line in one sentence for each: "A use-by date is required on food that spoils or goes off quickly that will be a danger to health if consumed after the given date. It is an offence to supply food after the use-by date." And: "Best before dates relate to quality, not food safety. You can supply food after the best before date, but the food may not meet the quality expected by the consumer." Write the count and weight of each pile into the file. Most of the arguing about whether surplus can be donated dissolves once somebody has sorted it into these three.

2. **Giving it away is, in law, the same as selling it, and that goes at the top of the file.** Section 2(1) of the Food Safety Act 1990 says that "the supply of food, otherwise than on sale, in the course of a business" "shall be deemed to be a sale of the food, and references to purchasers and purchasing shall be construed accordingly". Section 2(2)(b) extends the Act to food which, "for the purpose of advertisement or in furtherance of any trade or business, is offered as a prize or reward or given away, as if the food were, or had been, exposed for sale by the person offering or giving away the food". So a staff meal, a box handed to a charity, a raffle prize and a bag sold for a pound on an app all sit under the same duties as a plated dinner. There is no reduced standard for free food in the UK.

3. **Freeze the use-by pile before midnight on the date, relabel it, and never move a printed date.** This is the only lawful route by which use-by stock survives its own date. GOV.UK and the FSA state the condition precisely: "Food must be frozen before midnight on the use-by date and re-labelled correctly, following our guidance on bulk freezing of ambient and chilled foods." Two things follow. The decision has to be made while the food is still in date, so the surplus check happens in the morning and not at close. And the new label records the freezing rather than erasing or overwriting the use-by date. Anything already past its use-by date when you look at it is out of the file entirely, and the FSA's instruction for it is four words: "If the date has already expired, throw it away."

4. **Assess the best before pile by eye, by line, and record what you saw.** WRAP's Surplus Food Redistribution Guidance, published in 2017 and updated in November 2024, "includes information for six key food categories that typically carry a 'Best Before' date, to support the assessment and handling for redistribution": ambient products, bread and bakery, uncut fresh produce, dairy products, chilled products (non dairy), and frozen foods. Its method is a visual check of the food and of the packaging to confirm the food is of acceptable quality and safe to consume, and the November 2024 edition adds a decision tree for labelling decisions including freezing. Record per line: the category, the date on the pack, the pack condition, and the name of the person who looked. A pile signed off as "checked" with nobody's name on it is not an assessment, it is a hope.

5. **Make the allergen information travel with the food, because it does not travel by itself.** GOV.UK introduces the list with "The 14 allergens are:" and then names them: celery; cereals containing gluten (such as wheat, rye, barley, and oats); crustaceans; eggs; fish; lupin; milk; molluscs; mustard; peanuts; sesame; soybeans; sulphur dioxide and sulphites; and tree nuts. Copy the page's own wording for four of them rather than the short form, because the qualification is the useful part: "sulphur dioxide and sulphites (if the sulphur dioxide and sulphites are at a concentration of more than ten parts per million)", and the worked examples given for crustaceans, molluscs and tree nuts. Food handed over loose is non-prepacked, and the duty is flat: "If you provide non-prepacked foods, you must supply allergen information for every item that contains any of the 14 allergens." If you pack it on your own premises to hand straight over, it is prepacked for direct sale, and "Prepacked for Direct Sale (PPDS) foods need to have a label with a full ingredients list with allergenic ingredients emphasised within it." The FSA settles the format argument: "Our advice to food businesses providing non-prepacked food is that written allergen information, supported by a conversation, works best for consumers." Write the sheet, send it with the food, keep a copy.

6. **Fix the temperature and the handover before you fix the schedule.** The FSA sets the chilled line as a legal one: "Fridges and chilled display equipment should be set at 8°C or below as a legal requirement." So the file records, per collection, who carries the food, in what, how long it will be out of refrigeration, and what the receiving site will put it into. Chilled surplus that sits in a car boot for forty minutes in July has not been donated, it has been moved to somebody else's bin with your name on it. Where the receiving organisation cannot hold chilled stock, the chilled lines come out of the plan rather than being sent in hope.

7. **Ask the registration question in both directions, yours and theirs.** The FSA's guidance for food banks and charities is explicit that being free does not remove the duty: "You may need to register as a food business if you, or your operation, provide food to the community, even if it's free, 28 days before you start providing food." A registered restaurant does not register again for giving food away, but the receiving organisation may need to be registered and often does not know it. Ask them for their local authority and whether they are registered with it, record the answer and the date you asked, and treat "we've always just done it" as an unanswered question rather than a yes.

8. **Build the outbound record now, because it is the only thing that will be a defence later.** The FSA's traceability instruction is written for goods coming in: "You must keep an up-to-date record of your suppliers. Records should include: name and address, type and quantity of food, date of transaction and delivery." Mirror it outbound, line by line: what went, how much, to whom, on what date, at what temperature, with which allergen sheet, checked by whom. Section 21(1) of the Food Safety Act 1990 is why: in proceedings for an offence "it shall, subject to subsection (5) below, be a defence for the person charged to prove that he took all reasonable precautions and exercised all due diligence to avoid the commission of the offence by himself or by a person under his control." You prove that with a record made on the day, not a recollection made afterwards.

9. **Send everything that cannot go to people down the hierarchy in order, and date the whole file.** Defra's hierarchy runs: "1. Prevent surplus and waste in your business. 2. Redistribute surplus food and drink. 3. Make animal feed from former food. 4. Process surplus food to make biomaterials. 5. Recycle - anaerobic digestion and composting. 6. Recover waste by landspreading. 7. Recover energy from waste. 8. Dispose - send to sewer and landfill." Its rule on step 2 is the one this file exists to honour: "You must only donate food that's safe and fit for human consumption. Never donate food that's past its 'use-by' date." Step 3 is closed to a kitchen, whatever a farmer offers: "You must never send catering waste to be used as farm animal feed or to be used as pet food." So the realistic route for the rest is separate food waste collection. Date the file and record when each source was read, because date labelling guidance and the workplace recycling duties are both moving.

## Then it checks

1. Every line is in exactly one of the three date-label piles, and the file states the count and weight of each rather than "some" or "a few trays".
2. No line whose use-by date has passed appears anywhere in the plan, and every line saved by freezing names the date and time it was frozen and the wording of its new label.
3. No printed date has been altered, overwritten or extended on any item in the file.
4. Every best before line carries a recorded visual assessment with the WRAP category, the pack condition and the name of the person who looked.
5. Every line has an allergen entry naming which of the fourteen it contains or stating that it contains none, and the file names the format the information will be given in and who hands it over.
6. Every donation row records the recipient, the date, the quantity, the handover temperature and the person who checked it, and the file nowhere states that the donation is safe, lawful or compliant.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is. An allergen sheet going out with a delivery carries the name of the person who prepared it, because that is the person the charity will ring.
- Refuse to extend, alter, overwrite or re-print a use-by date, and refuse to list a use-by-expired item as redistributable for any reason, including that it looks and smells fine. Supplying food after its use-by date is an offence and no operational pressure changes that.
- Never tell an owner that a donation is safe, lawful or compliant. That is a judgement for them and their environmental health officer, and an owner told "you are fine" by a document stops asking the person who could actually tell them.
- Never treat a charity's assurance that it is registered, insured or able to hold chilled food as established. Record who said it and when, and leave it open until a document or a registration number arrives.
- Never state a percentage of food waste that redistribution will divert, a typical number of meals per kilogram, or a saving figure. No published figure exists for a single independent UK venue, and an owner who plans from a borrowed number will conclude their own site is failing.
- Never carry a date-labelling rule forward from an earlier file without re-reading the source. A quote that was right in March can be wrong by September.
- This output is a working document prepared for the owner to check with their environmental health officer, their receiving charity or redistribution partner and their own adviser before it is relied on. It gathers published requirements, records what the site holds and names the gaps. It is not food safety advice and it does not certify compliance with anything.

## Built from
- Food Standards Agency and GOV.UK, "Food safety and hygiene guidance for food banks and charities", https://www.gov.uk/government/publications/food-safety-and-hygiene-guidance-for-food-banks-and-charities/food-safety-and-hygiene-guidance-for-food-banks-and-charities, updated 28 August 2026, read 16 September 2026: the use-by offence and the "throw it away" instruction in step 1, the freeze-before-midnight condition in step 3, the best before quality wording in step 1 and step 4, the 8°C legal requirement in step 6, the 28 day registration wording in step 7, and the supplier record contents in step 8.
- Food Safety Act 1990, section 2 "Extended meaning of 'sale' etc", https://www.legislation.gov.uk/ukpga/1990/16/section/2, read 16 September 2026: the deeming of free supply in the course of a business as a sale, and the giving-away provision at section 2(2)(b), both in step 2.
- Food Safety Act 1990, section 21 "Defence of due diligence", https://www.legislation.gov.uk/ukpga/1990/16/section/21, read 16 September 2026: the wording of the defence that step 8 builds the record for.
- GOV.UK, "Allergen guidance for food businesses", updated 17 July 2026, https://www.gov.uk/government/publications/allergen-guidance-for-food-businesses/allergen-guidance-for-food-businesses, read 16 September 2026: the list of the fourteen allergens as the page words them, the non-prepacked duty, the PPDS labelling requirement and the written-plus-conversation advice, all in step 5.
- WRAP, "Surplus Food Redistribution Guidance", https://www.wrap.ngo/resources/guide/surplus-food-redistribution-guidance, originally published 2017 and updated November 2024, read 16 September 2026: the six best before categories, the visual assessment method and the freezing decision tree in step 4.
- Defra and GOV.UK, "Food and drink waste hierarchy: deal with surplus and waste", https://www.gov.uk/government/publications/food-and-drink-waste-hierarchy-deal-with-surplus-and-waste/food-and-drink-waste-hierarchy-deal-with-surplus-and-waste, updated 1 January 2024, read 16 September 2026: the eight-step order and the donation rule in step 9.
- GOV.UK, "How food businesses must dispose of food and former foodstuffs", https://www.gov.uk/guidance/how-food-businesses-must-dispose-of-food-and-former-foodstuffs, published 21 October 2014, read 16 September 2026: the definition of catering waste and the ban on sending it for farm animal feed or pet food, in step 9.
- GOV.UK, "Understanding food labelling: best before and use-by dates", https://www.gov.uk/understanding-food-labelling/best-before-and-use-by-dates, no publication date shown on the page, read 16 September 2026: the consumer-facing wording that use-by dates "tell you when the food is no longer safe to eat" and that after a best before date "the food is usually safe to eat but may not be of the same quality", used to word the three piles in step 1.

This is a working document prepared for the owner to check with their environmental health officer and their receiving partner before it is relied on. It is not food safety advice and it does not certify compliance.

# surplus-redistribution

## You are given
One UK hospitality site's surplus position for a stated period, already judged by Claude. Specifically: the site name and address and its food business registration details; a line by line list of the surplus, each line carrying the product name, the quantity and unit, the date label type and the date printed on it, the storage state and temperature it was held at, and the date and time the line was identified; Claude's judgement for every line of which of the three date-label piles it belongs to and whether it may be supplied today, supplied only after freezing, or not supplied at all; for any line saved by freezing, the date and time it was frozen and the exact wording of the new label; the recorded visual assessment for every best before line, naming the WRAP category, the pack condition and the person who looked; the allergen content of each line against the fourteen named allergens, or the word `none`; the receiving organisation's name, address, local authority, registration status and the date that status was asked for; the collection or handover arrangements including carrier, container and expected time out of refrigeration; and the quoted source wording Claude relied on, each with its source URL and the date it was read. Where a judgement is missing it arrives as the words `not supplied`.

## Produce
Write into a `./surplus-redistribution-output/` folder:

1. `surplus-lines.csv` with these columns in this order: `line_ref`, `product_name`, `quantity`, `unit`, `date_label_type`, `date_printed`, `identified_date`, `identified_time`, `storage_state`, `storage_temperature_c`, `pile`, `disposition`, `source_url`, `source_read_date`. `line_ref` is S001 upward. `date_label_type` is exactly one of `use by`, `best before`, `no date label`. `pile` is exactly one of `use by`, `best before`, `unlabelled own production`. `disposition` is exactly one of `supply today`, `supply after freezing`, `do not supply`, `not supplied`. Every row whose `date_printed` is earlier than `identified_date` and whose `date_label_type` is `use by` must carry `disposition` `do not supply`.
2. `frozen-and-relabelled.csv` with columns: `line_ref`, `original_use_by_date`, `frozen_date`, `frozen_time`, `before_midnight_on_use_by`, `new_label_text_verbatim`, `frozen_by`, `storage_location`. `before_midnight_on_use_by` is `yes` or `no`. Any row reading `no` is listed in `gaps.md` and its `surplus-lines.csv` row must read `do not supply`.
3. `allergen-sheet.csv` with columns: `line_ref`, `product_name`, `allergens_present`, `contains_none_declared`, `information_format`, `handed_over_by`, `sheet_copy_retained`. `allergens_present` lists only names drawn from the fourteen supplied, separated by semicolons, copied exactly as supplied. `information_format` is exactly one of `written label`, `written sheet`, `written sheet plus conversation`, `verbal only`, `not supplied`. `contains_none_declared` and `sheet_copy_retained` are `yes` or `no`.
4. `handover-log.csv` with columns: `handover_ref`, `date`, `time`, `recipient_name`, `recipient_address`, `recipient_local_authority`, `recipient_registration_asked_date`, `recipient_registration_status`, `line_refs`, `total_quantity`, `temperature_at_handover_c`, `minutes_out_of_refrigeration`, `carrier`, `checked_by`. `recipient_registration_status` is exactly one of `registered`, `not registered`, `asked and not answered`, `not supplied`.
5. `assessment-record.csv` with columns: `line_ref`, `wrap_category`, `date_on_pack`, `pack_condition`, `assessed_by`, `assessment_date`. `wrap_category` is exactly one of `ambient products`, `bread and bakery`, `uncut fresh produce`, `dairy products`, `chilled products (non dairy)`, `frozen foods`. One row for every `best before` line and no rows for any other pile.
6. `disposal-route.md` - a short file listing, in plain sentences, every line with disposition `do not supply`, the hierarchy step it is being sent to, and the reason, with the source quoted for each. It never records catering waste as going to farm animal feed or pet food. No conclusion about whether the site complies.
7. `gaps.md` - a numbered list of: any line with `not supplied` in any judgement column; any use-by line frozen after midnight on its date; any line supplied with no allergen entry; any handover with no named checker, no temperature or no date; any recipient whose registration status is `asked and not answered` or `not supplied`; any best before line with no assessment row or no named assessor; any minutes out of refrigeration over the figure supplied by Claude; and any missing source URL or read date.

## Rules
- Codex measures, records, sorts and checks. It never invents, never moves a line from the pile it was assigned, never rewords the owner's product names or label text, and never makes the supply judgement that was supplied to it.
- Never alter, extend, re-print or reformat a date that was printed on a product. Dates are copied exactly as supplied, including the original format, into `date_printed`.
- Never write `supply today` or `supply after freezing` against a line whose supplied disposition is `do not supply`, and never write either against a use-by line whose printed date precedes the identification date.
- Never write `yes` into `before_midnight_on_use_by`, `sheet_copy_retained` or a registration status on inference. Each is set only where the input states it and names a date, a person or a document.
- Never state that a donation is safe, lawful or compliant, that the site meets its food safety duties, or that an environmental health officer would accept the arrangement. None of these goes into any file.
- Never write a benchmark, an industry average, a meals-per-kilogram figure, a diversion percentage or a saving. No such figure exists for a single independent UK venue and none is to appear in any file.
- Never record a legal requirement without its source URL and the date that source was read, both copied from the input.
- Quantities and temperatures are counted or read from a supplied record, never estimated. Where the site estimated a quantity, the cell says `estimated by site`.
- Use British English, GBP for money and DD Month YYYY for every date. No em dashes in any file you write, and any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with this line: this is a working document prepared for the owner to check with their environmental health officer and their receiving partner before it is relied on; it is not food safety advice and it does not certify compliance.

## Return
The absolute path of each file written, the row count of each CSV, the number of lines in each of the three piles with their total quantities, the number of lines by disposition, the number of use-by lines frozen before midnight against the number frozen after, the count of supplied lines with no allergen entry naming each one, the number of handovers recorded with the recipient name and registration status for each, the highest minutes out of refrigeration recorded and against which handover, the number of best before lines with a named assessor against those without, the lines listed in `disposal-route.md` with their hierarchy step, and the `gaps.md` item count.