Allergen Labelling & Law

Natasha's Law Explained: What UK Food Businesses Must Do

Natasha's Law: What UK Food Businesses Must Do

Natasha's Law came into force on 1 October 2021 following the death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction to sesame in a Pret a Manger baguette. The law requires food businesses to provide full ingredient lists with allergens emphasised on all prepacked for direct sale (PPDS) food. Before this change, PPDS food was exempt from individual labelling. Businesses could rely on verbal communication or signage. That exemption is gone. If you make food on your premises and package it before a customer selects or orders it, you must label it with a full ingredient list. The 14 major allergens must be emphasised within that list using bold, italics, underlining, or a contrasting colour. This article explains who the law applies to, what counts as PPDS, how to format compliant labels, and the consequences of getting it wrong.

Key takeaways

Natasha's Law requires full ingredient labelling with emphasised allergens on all PPDS food
PPDS means food packaged on the same premises before the customer selects it
Allergens must be emphasised within a full ingredients list, not listed separately
Enforcement is by EHOs and Trading Standards, with unlimited fines for serious breaches
Every recipe change requires an immediate label update

What PPDS Actually Means for Your Business

Prepacked for direct sale (PPDS) covers food that is packaged at the same premises where it is sold, before the customer orders or selects it. The critical test is whether the food is in packaging when the customer encounters it. Sandwiches wrapped in cling film and placed in a display cabinet are PPDS. A salad boxed up in a deli counter is PPDS. A pizza slice put into a box before the customer asks for it is PPDS. However, food packaged at the customer's request is not PPDS. If a customer points at a cake in a display case and you then box it up, that is loose food, not PPDS. Similarly, food packaged at a central kitchen and sent to a different branch for sale is fully prepacked, not PPDS, and falls under separate (stricter) labelling rules. The distinction matters because it determines exactly which labelling requirements apply. Getting the classification wrong is the first mistake many businesses make.

Labelling Requirements Under Natasha's Law

Every PPDS item needs a label showing the name of the food and a full ingredients list. Within that ingredients list, the 14 declarable allergens must be emphasised so they stand out clearly. The most common method is bold text, but you can use italics, underlining, capitalisation, or a different colour provided the allergen is obviously distinct from the surrounding text. The ingredient list must follow standard food labelling conventions: ingredients in descending order of weight, compound ingredients broken down, and allergens emphasised wherever they appear. You cannot simply list allergens separately. They must appear within the full ingredients list. A common non-compliant approach is printing "Contains: milk, wheat" at the bottom of a label without listing all ingredients. That does not satisfy the regulations. The label must also include the name of the food as it is commonly known, so the customer can identify what they are buying.

Who Enforces Natasha's Law and What Happens If You Fail

Local authority Environmental Health Officers (EHOs) and Trading Standards officers enforce food allergen labelling. During routine inspections, officers check whether PPDS food is correctly labelled. Failures can result in improvement notices requiring you to fix the problem within a set period, or in serious cases, prosecution. Under the Food Safety Act 1990, selling food that is not of the nature, substance, or quality demanded is a criminal offence with unlimited fines. If a customer suffers an allergic reaction due to incorrect or missing labelling, you could face prosecution for causing harm. Beyond legal action, allergen failures now routinely appear in the national media and on social platforms, causing damage that lasts far longer than any fine. Insurance may not cover claims where the business failed to meet basic labelling requirements.
Allergen Labelling & Law

Manage allergens digitally

Paddl tracks allergens across your entire menu, generates compliant labels for PPDS items, and gives staff instant access to allergen information. Built for Natasha's Law compliance.

Try the free Allergen Matrix Builder

Practical Steps to Get Compliant

Start by auditing every product you sell that could be classified as PPDS. Walk through your premises during a normal service and identify every item that is in packaging before a customer touches it. For each item, write a full recipe with every ingredient, including oils, seasonings, sauces, marinades, and garnishes. Cross-reference every ingredient against the 14 allergens. Create a label for each product using a template that includes the food name and a full ingredients list with allergens in bold. Print labels using a system you can update quickly when recipes change. Many businesses use dedicated label printers connected to recipe management software, but printed stickers from a standard printer are also acceptable if legible and durable. Train every team member who prepares or packages PPDS food. They must understand that any recipe change requires a label update, and that running out of labels means the product cannot be sold until new ones are printed.

What to do next

Audit all PPDS products

Walk through your premises during service and list every food item that is already in packaging when customers see it. Classify each as PPDS, fully prepacked, or loose.

Build a master recipe and allergen file

Document every recipe with a complete ingredient breakdown and map each ingredient to the 14 allergens. Keep this file updated whenever you change suppliers or recipes.

Set up a label printing workflow

Choose a label format (thermal printer, adhesive stickers, or pre-printed wraps), create templates for every PPDS product, and train staff on when and how to update labels.

Common mistakes to avoid

Mistake
Listing allergens separately instead of within the full ingredients list
Instead
The law requires a full ingredient list with allergens emphasised in context. A standalone "Contains" box does not comply on its own.
Mistake
Treating food packaged at a central kitchen as PPDS
Instead
Food packaged at a different site from where it is sold is fully prepacked and requires even more detailed labelling including business name, address, and use-by date.

Frequently asked questions

Does Natasha's Law apply to food made and sold on the same day?

Yes. If the food is in packaging before the customer selects it, it is PPDS regardless of when it was made. Same-day production does not exempt you from labelling.

Can I use a chalkboard instead of individual labels?

No. PPDS food must have an individual label on or attached to the packaging. A chalkboard or poster near the display is not sufficient for PPDS, though it may be used for loose food.

Do I need to label drinks as well as food?

Yes. Any drink that is PPDS (e.g. pre-made smoothies, bottled juices made on site) must carry a full ingredient label with allergens emphasised.

What if my supplier changes an ingredient?

You must update your labels immediately. Build a process where goods-in staff check ingredient lists on every delivery and flag any changes to the person responsible for labels.

Need expert help with your HACCP system?

Our hospitality consultants can review your HACCP plan, identify gaps, and help you build a system that satisfies EHO inspectors.

Talk to a consultant

Manage Allergen Management digitally

Paddl helps UK hospitality businesses automate allergen management compliance. AI-generated plans, digital records, and inspection-ready documentation.

Natasha's Law Explained: What UK Food Businesses Must Do | Allergen Management | Paddl | Paddl