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Allergen Labelling & Law

Prepacked for Direct Sale (PPDS): Allergen Labelling Rules

PPDS Allergen Labelling: Rules, Examples & How to Comply

Quick answer

Prepacked for direct sale is a food classification that many businesses still struggle with. The concept was introduced into UK food law by the Food Information (Amendment) (England) Regulations 2019, commonly known as Natasha's Law. PPDS sits between fully prepacked food (labelled with full nutrition and allergen information, typically manufactured off-site) and loose food (where allergen information can be provided verbally or via signage). If your food falls into the PPDS category, you have specific labelling obligations that did not exist before October 2021. This article focuses on the practical detail: which products are PPDS, what your labels must contain, and how to handle the grey areas that cause the most confusion.

  • PPDS requires three conditions: packaged, at the same premises, before the customer selects it
  • Labels must include the food name and a full ingredient list with allergens emphasised
  • Food packaged at a different site from where it is sold is fully prepacked, not PPDS

Key takeaways

PPDS requires three conditions: packaged, at the same premises, before the customer selects it
Labels must include the food name and a full ingredient list with allergens emphasised
Food packaged at a different site from where it is sold is fully prepacked, not PPDS
Allergens must be emphasised every time they appear in the ingredients list

Defining PPDS: The Three-Part Test

A food item is PPDS if it meets three conditions. First, it must be packaged or fully wrapped. Partial wrapping or an open container does not count. Second, the packaging must happen at the same premises where the food is offered or sold to the consumer. Third, the food must be in its packaging before the customer selects or orders it. All three conditions must be met simultaneously. If any one fails, the food is not PPDS. A sandwich made and wrapped in your kitchen, then placed in your counter display, meets all three. A cake baked on-site, placed in a box, and sold from the same shop meets all three. But a cake baked at your central kitchen and sold at your market stall does not meet condition two, because the packaging and sale happen at different premises. That cake is fully prepacked, which carries its own labelling rules. Understanding this distinction prevents you from either under-labelling (a legal risk) or over-labelling (an unnecessary cost).
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What Your PPDS Label Must Include

The minimum legal requirement for a PPDS label is the name of the food and a full ingredients list with the 14 declarable allergens emphasised. The food name should be the common name that a customer would recognise. "Chicken Caesar wrap" is acceptable. An internal code like "CW-04" is not. The ingredients list must follow standard food labelling conventions: ingredients in descending order by weight, compound ingredients broken down into their sub-ingredients, and water included if it makes up more than 5% of the finished product. Allergens must be emphasised using bold, italics, underlining, capital letters, or a different colour. Bold is the most widely used and is recommended by the FSA for clarity. If an allergen appears multiple times in the list, it must be emphasised every time. For example, if your wrap contains both wheat flour and wheat starch, both instances of "wheat" must be in bold.

Grey Areas: Same-Day, Multi-Site, and Market Stalls

Several scenarios cause confusion. Market stalls and pop-ups: if you prepare and package food at home, then sell it at a market, the food is fully prepacked, not PPDS. You need full prepacked labelling including your business name and address. Multi-site businesses: a central kitchen packaging food for branch shops means the food is fully prepacked. Each branch selling food it packages on-site is PPDS. This means the same business can have both categories running simultaneously. Buffets and self-service: food placed in individual containers on a self-service counter is typically PPDS. Food in large serving dishes that customers portion themselves is loose. Food-to-go counters: pre-made sandwiches in sealed packaging are PPDS. A sandwich made to order and then wrapped is not PPDS because it was packaged after the customer ordered it. When in doubt, apply the three-part test and document your reasoning.

Label Design and Printing Practicalities

Your labels must be legible, durable, and attached to the packaging or clearly associated with the product. The minimum font size under EU-retained law is 1.2mm for the x-height (the height of a lowercase letter). In practice, aim for at least 8-point font for readability. White or light backgrounds with dark text work best. Avoid handwritten labels unless your handwriting is genuinely clear and consistent, as EHOs may question legibility. For printing, thermal label printers are the most popular choice in food businesses because they produce durable, smudge-resistant labels quickly. Brother, Dymo, and Zebra all make models suitable for food labelling. Many allergen management software platforms integrate directly with these printers. If you use printed stickers from a standard inkjet or laser printer, ensure the adhesive holds in chilled and ambient conditions and that the ink does not smear if the label gets damp.

What to do next

Apply the three-part test to every product

Review your full product range and classify each item as PPDS, fully prepacked, or loose food. Document the classification and your reasoning.

Create a label template library

Build a standard label template for each PPDS product. Include the food name and full ingredients list. Store digitally so any team member can print updated labels.

Set up a recipe change notification process

When any ingredient changes (new supplier, substitution, recipe update), trigger an automatic label review and reprint before the next batch is packaged.

Common mistakes to avoid

Mistake
Assuming food made to order and then wrapped is PPDS
Instead
If the customer orders first and you then package the food, it is loose food, not PPDS. The packaging must happen before the customer encounter.
Mistake
Using handwritten labels with inconsistent information
Instead
Handwritten labels are technically allowed but are prone to errors, omissions, and legibility issues. Use printed labels with standardised templates wherever possible.

Frequently asked questions

Is cling-wrapped food considered PPDS?

Yes, if the food is fully enclosed in cling film before the customer selects it and packaged on the same premises. Cling film counts as packaging under the regulations.

Do I need a use-by date on PPDS labels?

Natasha's Law does not mandate a use-by date on PPDS labels. However, separate food hygiene regulations require you to manage shelf life. Many businesses include a use-by date as good practice.

What about food sold through a hatch or counter?

If the food is already in packaging when the customer orders it, it is PPDS. If you package it after the order, it is loose food. The timing of packaging relative to the customer interaction is what determines the classification.

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Related resources

How-To Guides

How to Manage Allergens in a Commercial Kitchen

Glossary

The 14 Allergens (UK Law)

UK Regulations

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

Paddl Features

Allergen Management

Free Templates

Allergen Matrix Template

Compliance Risks

Anaphylaxis From Undeclared Allergen

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