Allergen Labelling & Law

Natasha's Law Explained: What It Is, Who It Applies To and How to Comply

Natasha's Law: The Complete Guide for UK Food Businesses

Natasha's Law is the name given to the allergen labelling rules that came into force across the UK on 1 October 2021. It requires any food that is prepacked for direct sale (PPDS) to carry a label with the name of the food and a full ingredients list, with the 14 regulated allergens emphasised within that list. Before the change, a sandwich made and wrapped in a cafe could be sold with no ingredient information at all, and a customer with an allergy had to ask and hope the answer was right. The law is named after Natasha Ednan-Laperouse, who was fifteen when she died in July 2016 after eating a Pret a Manger artichoke, olive and tapenade baguette bought at Heathrow. The baguette contained sesame baked into the dough, and because it was made and packaged on the premises it carried no allergen label. Her parents campaigned for the change and founded the Natasha Allergy Research Foundation. This guide covers the regulations the law consists of, the PPDS test that decides whether it applies to a product, what the label must show and how it must be formatted, the exemptions, who enforces it and what the penalties are, and a practical route to compliance. It also covers the two questions operators ask most: whether food packed to order needs a label, and whether a chalkboard is enough.

Key takeaways

Natasha's Law has required full ingredient labelling with the 14 allergens emphasised on all prepacked for direct sale food since 1 October 2021, across the whole UK
Food is PPDS when it is in packaging, was packaged before the customer chose it, and was packaged where it is sold; all three must be true
The label must show the name of the food and a full ingredients list in descending weight order, with every allergen emphasised each time it appears
Minimum text x-height is 1.2mm, or 0.9mm on packaging under 80 square centimetres
Food wrapped to order, food served loose, food packed elsewhere and food sold by delivery follow different rules
Enforcement is by improvement notice and prosecution under the Food Information Regulations 2014 and the Food Safety Act 1990, with unlimited fines

The regulations behind the name

Natasha's Law is not a single act. It is a set of amendments to the Food Information Regulations 2014, which implement the retained EU Food Information to Consumers Regulation (EU) 1169/2011, known as FIC. In England the amendment is the Food Information (Amendment) (England) Regulations 2019. Wales made the Food Information (Wales) (Amendment) (No. 2) Regulations 2020, Scotland the Food Information (Scotland) Amendment Regulations 2021, and Northern Ireland the Food Information (Amendment No. 2) Regulations (Northern Ireland) 2020. All four came into force on the same day, 1 October 2021, so the rules are the same wherever in the UK you trade. What the amendments did was remove an exemption. FIC had always required full ingredient labelling on prepacked food, but food prepacked for direct sale was treated like loose food and only had to have allergen information available on request. The amendments moved PPDS food into the category that needs a label. The 14 allergens themselves did not change; they are the same list that applies to every food business under FIC Annex II.

Who the law applies to

Any food business that packages food on the premises where it is sold, before the customer chooses it, is within scope. That includes cafes wrapping sandwiches for the chiller, bakeries bagging rolls and pastries before display, delis boxing salads and pasta pots, pubs and restaurants selling grab-and-go items, hotels putting packed breakfasts and lunch bags together, school and workplace canteens with a grab-and-go counter, farm shops, market stalls and mobile units that pre-wrap, and any kitchen that puts food into a container and puts a lid on it before the customer arrives. The size of the business makes no difference and neither does whether the food is sold that day. It also covers food packaged on the premises and sold from a temporary or mobile outlet run by the same business, such as a cafe that also sells from a stall at a weekend market. The test is whether the packaging happened at the same site or a site run by the same operator where the sale takes place, before the customer selected the item.

What counts as prepacked for direct sale

The Food Standards Agency uses a three-part test. The food is PPDS if it is presented to the customer in packaging, it was packaged before the customer selected or ordered it, and it was packaged at the same place it is sold or offered for sale. All three must be true. A sandwich wrapped and placed in a display cabinet at 8am is PPDS. A boxed salad on a deli counter is PPDS. A slice of cake in a clamshell on the counter is PPDS. A pre-wrapped burger kept hot under a lamp in a takeaway is PPDS. The same items become something else if one part of the test fails. If the customer points at a sandwich in an open display and staff then wrap it, the food was packaged after selection, so it is not PPDS; it is loose food and only needs allergen information to be available, for example on a menu or from staff. If the sandwich was made and wrapped at a central kitchen and sent to a different shop for sale, it fails the same-place part, so it is fully prepacked food and needs the full FIC label including business name and address, quantity, date marking and the rest. If the sandwich is ordered online and delivered, it is distance selling and different rules apply: the allergen information must be available before purchase and again at delivery, but a PPDS-style label is not required.
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What the label must show

The label on a PPDS item must show two things: the name of the food and a full list of ingredients. The name is the customary or descriptive name the customer would recognise, so "chicken and bacon mayonnaise sandwich" rather than a brand name alone. The ingredients list must include every ingredient, in descending order of weight as used at the time of preparation, with compound ingredients such as bread, mayonnaise or pesto broken down into their own ingredients unless they make up less than two per cent of the product and their own allergens are declared. Within the ingredients list, every one of the 14 allergens must be emphasised so it stands out from the rest of the text. Bold is the convention; italics, underlining, capitals or a contrasting colour are also acceptable. The allergen must be emphasised each time it appears, so a sandwich with milk in the butter and in the cheese shows milk in bold twice. The name of the allergen must be clear: "whey (milk)" or "semolina (wheat)" where the ingredient name does not make the allergen obvious. A separate "contains" statement may be added but does not replace the emphasised ingredients list, and a "may contain" statement is voluntary and should only be used after a genuine cross-contact risk assessment. Other mandatory information that applies to fully prepacked food, such as date marks, net quantity, storage instructions and the business address, is not required on a PPDS label, though many businesses add a use-by date for stock control.

Format and legibility

FIC sets a minimum text size for mandatory information, and it applies to PPDS labels. The x-height of the lettering, the height of a lower-case x, must be at least 1.2mm. Where the largest surface of the packaging is under 80 square centimetres, it may drop to 0.9mm. On a thermal label from a desktop printer that is roughly a 7 to 8 point font. The label must be on the packaging or on a label attached to it, legible, indelible and not hidden by other material. It must be in English, and may also be in Welsh or another language. Handwritten labels are permitted if they meet those standards, but they rarely survive a busy service without smudging, and the ingredients list for even a simple sandwich runs to twenty items. Most businesses print labels from a recipe database so that a change to one ingredient updates every product that uses it. The PPDS label generator produces a correctly formatted label from a recipe for free, and the allergen matrix builder gives you the underlying allergen data for every dish.

The 14 allergens that must be emphasised

The allergens are set by FIC Annex II and are the same across all food law: celery, cereals containing gluten (wheat, rye, barley, oats and their hybrids), crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide and sulphites above 10mg per kg or litre, and tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamias). Where a cereal or a nut is present, the specific type must be named, so "wheat" rather than "gluten" and "almonds" rather than "nuts". Sesame, the allergen that killed Natasha, is on the list in its own right and is common in seeded breads, hummus, tahini, dressings and spice mixes, which is why supplier specifications matter as much as your own recipes.

Exemptions and grey areas

Food that is not in packaging when the customer selects it is not PPDS and does not need a label. Food packaged at the customer's request after they have chosen it is not PPDS. Food packaged at a different premises from the one selling it is fully prepacked and follows the stricter FIC rules rather than Natasha's Law. Food sold by distance selling, including delivery apps, follows the distance selling rules. Food served on a plate, in a bowl or in a glass in a restaurant or bar is loose food. The grey areas come from packaging that is used for hygiene or handling rather than sale. A cake under a cloche on the counter is loose. A cake wrapped in film on the counter that is sold whole is PPDS. Soup in a lidded cup filled to order is loose; the same cup filled and lidded before service starts is PPDS. A takeaway that pre-wraps burgers during a rush and holds them under a lamp has created PPDS food even though it would be loose if wrapped to order. When in doubt, the FSA's advice is to label, because a label on loose food does no harm and a missing label on PPDS food is an offence.

Enforcement and penalties

Natasha's Law is enforced by local authority Environmental Health and Trading Standards officers as part of routine food hygiene inspections and in response to complaints. An officer who finds unlabelled or wrongly labelled PPDS food can serve an improvement notice under the Food Information Regulations 2014 requiring the failure to be corrected within a set time, and failing to comply with the notice is a criminal offence. Selling food that is not of the nature, substance or quality demanded, or falsely describing it, is an offence under the Food Safety Act 1990 with an unlimited fine in England and Wales since 2015. Where a customer is harmed, prosecutions for food safety offences have brought fines in the tens of thousands of pounds against small businesses and, in the most serious cases involving a death, prison sentences for owners. Beyond the courts, a labelling failure appears on the inspection report, drags the confidence in management score down and with it the food hygiene rating, and will usually invalidate any public liability claim from a customer who reacted to the product because the policy conditions require legal compliance. The Natasha's Law penalties article sets out the enforcement route in detail.

How to comply, step by step

Start by walking the premises during service and listing every item that is in packaging before a customer touches it. Classify each as PPDS, fully prepacked, loose or distance sold. For each PPDS item, write a full recipe down to the oils, seasonings, garnishes and sauces, and collect the specification or label for every bought-in ingredient so the compound ingredients can be broken down and the allergens identified. Build the allergen matrix for the whole menu from those recipes; it is the same data the loose-food menu needs. Generate a label for each PPDS product with the name and the full emphasised ingredients list, check it against the minimum text size, and print it in a format that survives a chiller. Then make it a process rather than a project. Goods-in staff check every delivery against the specification and flag substitutions, because a supplier swapping a mayonnaise brand can add mustard or egg without warning. Any recipe change triggers a label update before the product goes on sale. Staff who prepare or wrap PPDS food are trained on what the label is for and told that a product with no label cannot be sold. The training is recorded, and the allergen matrix is reviewed at the same time as the SFBB 4-weekly review. Paddl holds the recipes, the allergen matrix and the labels in one place so that a change to an ingredient updates every dish and every label that uses it.

What to do next

Audit all PPDS products

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

Build a master recipe and allergen file

Document every recipe with a complete ingredient breakdown and map each ingredient to the 14 allergens. Collect supplier specifications for every bought-in ingredient and keep the file updated whenever a supplier or recipe changes.

Set up a label printing workflow

Generate a label for every PPDS product from the recipe data, check the text size, and train staff that a recipe change means a label change and a missing label means the product is not for sale.

Common mistakes to avoid

Mistake
Listing allergens separately instead of within the full ingredients list
Instead
The law requires a full ingredients 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 needs the full FIC label including business name, address, quantity and date marking.
Mistake
Relying on a chalkboard or a poster near the display
Instead
Signage is acceptable for loose food. PPDS food needs a label on or attached to each item.
Mistake
Not checking deliveries for ingredient substitutions
Instead
A supplier changing a bread, a sauce or a dressing changes the allergens in every product that uses it. Goods-in checks against the specification are part of compliance.

Frequently asked questions

What is Natasha's Law in simple terms?

Any food you package on your premises before a customer chooses it must carry a label with the name of the food and a full ingredients list, with the 14 allergens shown in bold or otherwise emphasised. It has applied across the UK since 1 October 2021.

Does food packed to order need a Natasha's Law label?

No. Food wrapped or boxed after the customer has chosen it is loose food, not PPDS. You must still be able to give allergen information, for example on the menu or from staff, but a label is not required.

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, such as a smoothie or juice made and bottled on site before sale, must carry a full ingredients label with allergens emphasised.

Does Natasha's Law apply in Scotland, Wales and Northern Ireland?

Yes. Each nation made its own amending regulations and all four came into force on 1 October 2021, so the requirements are identical across the UK.

What if my supplier changes an ingredient?

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

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