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Allergen Labelling & Law

Do I Need PPDS Labels? Exemptions and Who the Rules Apply To

Do I Need PPDS Labels? Who Must Comply and What Is Exempt

Quick answer

The honest answer to "do I need PPDS labels?" is: it depends on how you package and sell each item, not on what type of business you run. Natasha's Law, which came into force on 1 October 2021, applies to any food business that packages food on its own premises and puts it out for sale before the customer selects it. That captures cafes, bakeries, delis, sandwich shops, school kitchens, hospitals, market stalls run from the selling site, butchers, farm shops, and plenty of others. The law does not care whether you are a one-person bakery or a national chain. What matters is the food. Some of what you sell will be PPDS and will need a full ingredients label with allergens emphasised. Some will be loose or made to order and will not. This article sets out who the rules apply to, what is genuinely exempt, and how to work through your own range so you label what needs labelling and avoid the cost of labelling what does not.

  • PPDS labelling applies to any business that packages food on site and sells it pre-packaged, regardless of size
  • School, hospital, care home, and workplace caterers are covered if they pre-pack food for self-service
  • Loose food and made-to-order food are exempt from PPDS labels but still need allergen information available

Key takeaways

PPDS labelling applies to any business that packages food on site and sells it pre-packaged, regardless of size
School, hospital, care home, and workplace caterers are covered if they pre-pack food for self-service
Loose food and made-to-order food are exempt from PPDS labels but still need allergen information available
Fully prepacked food (packaged at another premises) is not PPDS but carries its own detailed label rules
There is no exemption for small producers, same-day food, or food given away as part of the business

Who the Rules Apply To

PPDS labelling applies to any food business operator that prepares and packages food on the premises and offers it for sale at those same premises, where the food is already packaged before the customer chooses it. There is no exemption based on the size of the business or the volume of food. A village cafe wrapping its own flapjacks faces the same duty as a supermarket bakery section. The duty also applies regardless of whether the food is sold for profit, so school caterers, hospital kitchens, care homes, and workplace canteens that pre-pack food for self-service are included. Charities and community groups packaging food on site for sale are covered too. If you only ever serve food on a plate, or you only wrap food after a customer orders it, you will have little or no PPDS food. But most businesses that have a grab-and-go fridge, a counter of pre-wrapped items, or a self-service chiller will have at least some PPDS products, and those products need labels.
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What Is Exempt from PPDS Labelling

Several types of food sit outside the PPDS labelling requirement. Food sold loose, where the customer chooses it before it is packaged or it is never packaged at all, is not PPDS, though you still must make allergen information available. Food made to a customer's order, then wrapped, is loose food and exempt from the PPDS label, again with the allergen-information duty still applying. Food that is fully prepacked, meaning packaged at a different premises from where it is sold, is not PPDS either, but it carries its own, more detailed labelling rules rather than being exempt from labelling altogether. Drinks and food consumed on the premises after being ordered are treated as loose. There is no blanket exemption for small producers, same-day food, or food given away free as part of a business activity. If an item is packaged in advance on the premises and sold from there, the PPDS label is required even if you made it that morning.

A Simple Test to Decide

Use this two-step check on each product. Step one: is the food in its packaging at the moment the customer chooses it? If the customer picks an unwrapped item, or orders something that you then wrap, the answer is no and you do not need a PPDS label (you do still need allergen information available). If the food is already wrapped when the customer reaches for it, go to step two. Step two: was it packaged at the same premises where it is being sold? If yes, it is PPDS and needs a full ingredients list with the 14 allergens emphasised. If it was packaged elsewhere, it is fully prepacked and needs the separate full-label treatment. Run every product through these two questions. Keep a written note of the outcome for each item, because an Environmental Health Officer may ask how you decided. The note also protects you when staff change, so the reasoning does not walk out the door.

What to do next

Run the two-step test on your full range

Check each product: is it packaged when the customer chooses it, and was it packaged on site? Use the answers to confirm which items need PPDS labels.

Record your exemption decisions

Write down which items you treat as loose or made to order and why. Keep this with your allergen records so you can show an inspector your reasoning.

Check your self-service and grab-and-go areas first

Pre-wrapped chillers, counter displays, and grab-and-go fridges are where PPDS items hide. Audit these before anything else.

Common mistakes to avoid

Mistake
Assuming small or same-day producers are exempt
Instead
There is no exemption for business size or same-day production. If the food is packaged on site before the customer selects it, it needs a PPDS label.
Mistake
Thinking exempt food needs no allergen information at all
Instead
Loose and made-to-order food is exempt from the PPDS label, but you must still make the 14 allergens known through written or documented verbal information.

Frequently asked questions

Do small cafes need PPDS labels?

Yes, if they package any food on site before the customer selects it. There is no exemption based on the size of the business. A small cafe with a pre-wrapped cake display needs PPDS labels on those cakes.

Are restaurants exempt from PPDS labelling?

Restaurants that plate food to order are mostly serving loose food, which is exempt from PPDS labels. But if a restaurant pre-packs items for a grab-and-go fridge or counter, those items are PPDS and need labels.

Is food made fresh that morning exempt?

No. Same-day production does not create an exemption. If the food is packaged before the customer chooses it and sold from the premises where it was packed, it needs a PPDS label.

Do school and hospital caterers need PPDS labels?

Yes, where they pre-pack food on site for self-service, such as wrapped sandwiches in a chiller. The PPDS rules apply regardless of whether food is sold for profit.

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Related resources

Glossary

The 14 Allergens (UK Law)

UK Regulations

Natashas Law (Food Information Amendment 2019)Food Information Regulations 2014

Free Tools

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Paddl Features

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PPDS vs Non-Prepacked vs Loose: Which Allergen Rule Applies

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