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

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.

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.