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Allergen Labelling & Law

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

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

Quick answer

Three food categories cause most of the confusion in UK allergen law: PPDS (prepacked for direct sale), fully prepacked, and loose food. The same business often handles all three, sometimes with the same product, and each one carries a different allergen duty. Get the category wrong and you either under-label, which is a legal and safety risk, or over-label, which wastes time and money. The categories were brought into sharper focus by Natasha's Law in October 2021, which created a labelling duty for PPDS food that had not existed before. This article compares the three side by side: what each one means, what allergen information you must provide for it, and how to decide which applies to a given item. The deciding factors are simple once you see them laid out, and they come down to when the food was packaged and where it was packaged.

  • The three categories are fully prepacked, PPDS, and loose, separated by when and where food is packaged
  • Fully prepacked food needs the fullest label: ingredients, allergens, business details, and a date mark
  • PPDS food needs the food name and a full ingredients list with the 14 allergens emphasised

Key takeaways

The three categories are fully prepacked, PPDS, and loose, separated by when and where food is packaged
Fully prepacked food needs the fullest label: ingredients, allergens, business details, and a date mark
PPDS food needs the food name and a full ingredients list with the 14 allergens emphasised
Loose food needs the 14 allergens made known, in writing or verbally with supporting records
The same product can fall into different categories depending on how it is sold in each situation

The Three Categories Defined

Fully prepacked food is packaged before it is offered for sale and packaged at a different premises from where it is sold. Think of a sandwich made in a factory or central kitchen and delivered to a shop, or food prepared in a home kitchen and taken to a market stall. PPDS food is also packaged before the customer selects it, but it is packaged at the same premises where it is sold. A sandwich wrapped in the shop's own kitchen and placed in that shop's chiller is PPDS. Loose food is not packaged when the customer chooses it. This covers a plate of food in a restaurant, a cake chosen from a display and boxed afterwards, a buffet dish, and any item made to order and then wrapped. The two questions that separate the categories are: was the food packaged before the customer chose it, and if so, was it packaged where it is sold? Those two answers place every item.
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The Different Allergen Duties

Each category carries its own allergen-information duty. Fully prepacked food needs the most: a full ingredients list with the 14 allergens emphasised, plus the business name and address, a date mark (use-by or best-before), storage instructions, and quantity information. PPDS food, since Natasha's Law, needs the name of the food and a full ingredients list with the 14 allergens emphasised within that list. It does not legally require the business name, address, or date mark that fully prepacked food does, though many businesses add a use-by date as good practice. Loose food has the lightest formal duty: the 14 allergens must be made known to the customer, but the information can be written (a menu, a chalkboard, an allergen matrix) or given verbally, provided staff are trained and there is documentation behind what they say. The pattern is that the further the food is from a face-to-face conversation, the more the information has to live on the packaging.

How to Decide and Why It Matters

Work through each product with the two questions. Was it in packaging when the customer chose it? If no, it is loose food and you provide allergen information through your menu, signage, or trained staff with records to support them. If yes, ask whether it was packaged at the same premises where it is sold. Same premises means PPDS and a full ingredients list with emphasised allergens. Different premises means fully prepacked and the longer label. Why does this matter beyond compliance? Because the wrong category creates real risk. Treat PPDS as loose and you skip a label the law requires, leaving a customer to rely on a conversation that may never happen at a self-service chiller. Treat fully prepacked food as PPDS and you may omit the date mark and business details that customers and regulators expect. The same loaf can be PPDS at the counter, fully prepacked when supplied to a cafe, and loose when sliced to order, so the test must be applied to the situation, not just the product.

What to do next

Map each product against the two deciding questions

Ask whether each item is packaged when the customer chooses it, and whether it is packaged on site. Use the answers to assign the correct category.

Match the label to the category

Give fully prepacked items the full label, PPDS items a name plus emphasised ingredients list, and loose items written or documented verbal allergen information.

Review products sold through more than one channel

Identify items you sell in different ways (counter, wholesale, made to order) and confirm each channel has the right allergen treatment for its category.

Common mistakes to avoid

Mistake
Treating PPDS food as loose because staff are on hand to answer questions
Instead
PPDS food needs a written ingredients label regardless of staff availability. A self-service chiller customer may never speak to anyone.
Mistake
Labelling fully prepacked food as if it were PPDS
Instead
Fully prepacked food needs more than the PPDS label: it also requires the business name and address, a date mark, and storage instructions.

Frequently asked questions

What is the difference between PPDS and fully prepacked food?

Both are packaged before the customer selects them, but PPDS food is packaged at the same premises where it is sold, while fully prepacked food is packaged at a different site and carries a fuller label including business details and a date mark.

Does loose food need a label?

No. Loose food does not need an individual ingredients label, but you must make the 14 allergens known through a menu, signage, or trained staff supported by written records.

Can one product be in more than one category?

Yes. A loaf wrapped and sold at the counter is PPDS, the same loaf supplied wrapped to a cafe is fully prepacked, and a loaf sliced to order is loose. The category depends on the situation, not just the product.

Which category needs the most information on the label?

Fully prepacked food. It needs a full ingredients list with allergens emphasised plus business name and address, a date mark, storage instructions, and quantity, more than PPDS or loose food require.

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Keep exploring

Related resources

Glossary

The 14 Allergens (UK Law)

Expert Answers

What Are the 14 Allergens in the UK?

UK Regulations

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

Free Tools

Allergen Matrix Builder

Paddl Features

Allergen Management

In-Depth Guides

PPDS Meaning: What PPDS Stands For and Which Foods It Covers

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