Key takeaways
- Natasha's Law applies to prepacked for direct sale (PPDS) food: food packed on the same premises it is sold from, before the customer chooses it.
- A PPDS label must show the name of the food and a full ingredients list, in descending weight order, with the 14 allergens emphasised inside that list.
- A separate 'contains' statement does not replace the emphasised ingredients list.
- Loose food served after ordering is not PPDS, but allergen information must still be available in writing or verbally with clear signposting.
- The law is enforced by local authorities and applies to every food business, whatever its size.
Why the law exists
In July 2016, fifteen-year-old Natasha Ednan-Laperouse died after eating a baguette bought from a Pret a Manger at Heathrow Airport. The bread contained sesame, to which she was severely allergic. Under the rules at the time, a sandwich made and wrapped on the premises did not need an ingredients label, so there was nothing on the packaging to warn her.
The inquest in 2018 led directly to new regulations. In England they are the Food Information (Amendment) (England) Regulations 2019, with equivalent regulations in Wales, Scotland and Northern Ireland. All four came into force on 1 October 2021. The change is universally known as Natasha's Law, and it works by extending the existing UK food information rules, which are based on the retained EU Regulation 1169/2011 and the Food Information Regulations 2014, to a category of food that had previously been exempt from full labelling: prepacked for direct sale.
The Food Standards Agency publishes the official guidance for England, Wales and Northern Ireland at food.gov.uk. Food Standards Scotland publishes the Scottish equivalent. The requirements are the same in all four nations.
What counts as prepacked for direct sale (PPDS)
Food is PPDS when all three of the following are true: it is packed before the customer selects or orders it; it is packed on the same premises from which it is sold; and the packaging means the customer cannot change the contents without opening it. The test is about when and where the food is packed, not what kind of food it is.
| Situation | Category | What applies |
|---|---|---|
| Sandwiches made in the café kitchen each morning, wrapped and put in the chiller | PPDS | Name of the food plus full ingredients list with allergens emphasised |
| Boxed salads, wrapped cakes or pre-filled baguettes sold from the counter where they were packed | PPDS | Same as above |
| Burgers wrapped and held hot in a chute before anyone orders them | PPDS | Same as above |
| Food packed by a stallholder at a market stall and sold from that stall | PPDS | Same as above (a temporary or mobile site still counts as the premises) |
| A sandwich made and wrapped after the customer orders it | Non-prepacked | Allergen information must be available; no full label required |
| Food loose on a deli counter or served on a plate | Non-prepacked | Allergen information must be available; no full label required |
| Food packed by another business and delivered to you to sell | Prepacked | Full prepacked labelling: ingredients, allergens, nutrition, dates, quantity, address and more |
| Food packed at your central kitchen and sold at a different site of the same business | Prepacked | Treated as prepacked under FSA guidance, so full labelling applies |
| Food ordered by phone or online for delivery | Distance selling | Allergen information before purchase and again at delivery |
Two of those rows catch businesses out. The first is the central production kitchen: if you pack at one site and sell at another, even within the same company, the FSA treats the food as prepacked, and the full set of prepacked labelling rules applies rather than the shorter PPDS label. The second is the chiller full of pre-made food in a venue that mostly makes food to order. The made-to-order food is non-prepacked; the chiller stock is PPDS and needs a label.
What a PPDS label must show
The label must carry two mandatory pieces of information:
- The name of the food.This is the legal name, or a customary or descriptive name that tells the customer what the food actually is. “Chicken Caesar wrap” is fine; a brand name on its own is not.
- A full ingredients list, headed with the word “Ingredients”, listing every ingredient in descending order of weight as used when the food was made, with each of the 14 allergens emphasised within the list.
The ingredients list has to be complete. Compound ingredients, such as the mayonnaise you buy in or the pesto you make, are listed by their own ingredients, which is where most of the hidden allergens live. Water and volatile ingredients are listed according to their weight in the finished product, and the same ordering rules apply as on any other ingredients list. Our UK food labelling rules guide covers the ordering and naming rules in detail.
Both items must be printed in a minimum font size: an x-height of 1.2 mm, or 0.9 mm where the largest surface of the pack is under 80 cm². Nothing else is required by Natasha's Law itself. A date mark, storage instructions, net weight and nutrition declaration are not mandatory on PPDS food, though you may add them, and your general food safety duties around shelf life and storage are unchanged.
How to emphasise the 14 allergens
Every ingredient that is, or is derived from, one of the 14 allergens must stand out from the rest of the list by its typeface, style, background or colour. Bold is the most common choice; CAPITALS, italics, underlining or a coloured highlight are all acceptable. What matters is that the emphasis is applied consistently and only to the allergens, so a customer scanning the list can find them at a glance.
The emphasis goes on the allergen reference itself. For example:
Ingredients: Wheat flour, water, chicken breast (18%), mayonnaise (rapeseed oil, egg yolk, vinegar, mustard), romaine lettuce, parmesan (milk), anchovy (fish), salt, black pepper.
Allergy advice: for allergens, see ingredients in bold.
Note the cereal is named: “wheat” rather than “gluten”, because the law requires the specific cereal to be declared. The same applies to nuts, where the type of nut must be named, and to fish, crustaceans and molluscs where the species or common name is used. The full list of what each allergen covers is in our guide to the 14 allergens.
“May contain” and cross-contamination
A precautionary statement such as “may contain nuts” is voluntary. It is not a substitute for the emphasised ingredients list, and it should only be used after a genuine assessment of cross-contamination risk in your kitchen: shared fryers, shared slicers, open containers of flour or nuts, or a supplier whose own label carries a warning. Used indiscriminately on everything, a may-contain statement stops meaning anything and can leave allergic customers with nothing safe to choose. Used after a proper assessment, it is important safety information and belongs near the ingredients list.
Loose food, restaurants and takeaways
Food that is not packed, or is packed only after the customer has ordered, is non-prepacked. Restaurants, pubs, takeaways and counter service all fall here. The rules for non-prepacked food are different but not optional: information about the 14 allergens must be available for every item you sell.
- It can be given in writing, for example on the menu, a chalkboard, an allergen matrix or a folder at the counter.
- It can be given verbally, but only if a clear written signpost tells customers to ask. A sign saying “please ask a member of staff about allergens” is the usual form.
- Whichever route you take, the information must be accurate, consistent between staff, and backed by a record you can show an inspector. A blanket statement that all dishes may contain allergens is not acceptable.
A per-dish allergen matrix is the simplest way to meet this for a whole menu. You can build and print one in a few minutes with our free allergen matrix generator. A campaign known as Owen's Law has pressed for written allergen information on menus to be mandatory, and the FSA has recommended written information as best practice; check food.gov.uk for the current position in your nation.
Online, phone and delivery orders
Food ordered remotely is distance selling. The customer must be able to see allergen information before they buy, for example on the website, app or a menu you send them, and again when the food arrives, on a label, sticker, delivery note or enclosed sheet. If you run a food e-commerce operation, the product pages are the first half of that duty and the packed order is the second. Recipee's product feed carries the ingredients list and allergen data from each recipe to the shop so both halves come from the same source.
Putting it into practice
Compliance is less about the label printer and more about the information behind it. A workable system has five parts.
1. A specification for every recipe
Each product needs a written recipe with every ingredient, its quantity, and the sub-recipes it uses. If the ingredients list on the label is generated from this record, it is right by construction. If it is typed separately, it drifts.
2. A specification for every bought-in ingredient
Keep the supplier's ingredients list and allergen statement for every product you buy, and link it to the ingredient in your recipes. A bought-in sauce is a compound ingredient on your label, and its allergens are your allergens.
3. Change control
When a supplier reformulates a product, or you swap one brand for another, every recipe that uses it changes. Check deliveries against the specification on file, and treat a changed ingredient as a trigger to re-check and reprint every affected label before the product goes on sale.
4. Label production
Print labels from the recipe record, not from memory. Make sure the printer and label stock can render the emphasis clearly at the required font size, and that the label for each product is checked against the recipe when it is first set up.
5. Staff training and records
Everyone who packs, labels or serves food needs to know what PPDS is, what the label must show, and what to do when a customer asks about allergens. Keep training records, specifications and label checks together so you can show your due diligence when an environmental health officer visits.
Enforcement and penalties
The rules are enforced by local authority environmental health and trading standards officers. An officer who finds non-compliant labelling can serve an improvement notice; failing to comply with that notice is a criminal offence, and the fines available to the courts in England and Wales are not capped. Where mislabelling leads to harm, prosecution under general food safety law is also possible. The reputational cost of a serious allergic reaction linked to your business is likely to be greater than any fine.
Automating the ingredient list
The hardest part of Natasha's Law is not understanding it but keeping the labels right on the two hundredth day, when a supplier has changed a mayonnaise and three sandwiches quietly changed with it. Recipe management software removes that problem by generating the ingredients list from the recipe itself. In Recipee, each ingredient carries its allergens, sub-recipes roll up into the parent product, the label builder emphasises the 14 allergens automatically and in the right order, and a change to one ingredient updates every product that contains it. The label builder prints to standard label printers, so the kitchen gets a compliant label without anyone retyping an ingredient.