Prepacked for Direct Sale (PPDS): Allergen Labelling Rules

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).

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.