Allergen Labelling Procedures
The UK legal requirements for labelling allergens on pre-packed, pre-packed for direct sale (PPDS), and non-prepacked food under the Food Information Regulations 2014 and Natasha's Law.
Allergen labelling is a legal requirement for all UK food businesses. The Food Information Regulations 2014 (FIR), which implement EU Regulation 1169/2011 in UK law, require that the presence of any of the 14 declarable allergens is clearly communicated to consumers. The requirements differ depending on whether food is pre-packed, pre-packed for direct sale (PPDS), or sold loose (non-prepacked). Natasha's Law, which came into force on 1 October 2021, introduced specific labelling requirements for PPDS food following the death of Natasha Ednan-Laperouse from an allergic reaction to a sandwich containing undeclared sesame. Non-compliance with allergen labelling requirements is a serious offence. Penalties can include fines of up to 5,000 pounds per offence in the Magistrates Court, or unlimited fines and up to 2 years imprisonment in the Crown Court.
Key Points
- UK law requires declaration of 14 specific allergens under the Food Information Regulations 2014
- Natasha's Law (October 2021) requires full ingredient labelling with allergens emphasised on PPDS food
- Penalties for non-compliance include fines up to 5,000 pounds per offence or unlimited fines in Crown Court
- "May contain" statements must be supported by a documented risk assessment, not used as blanket disclaimers
- Non-prepacked food businesses must display a notice directing customers to ask about allergens
- Allergen information must be updated immediately when recipes, suppliers, or menus change
The 14 Declarable Allergens
UK law requires food businesses to declare the presence of 14 specific allergens. These are: celery, cereals containing gluten (wheat, rye, barley, oats), crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts (almonds, hazelnuts, walnuts, cashews, pecans, brazils, pistachios, macadamias), peanuts, sesame, soybeans, and sulphur dioxide/sulphites (at concentrations above 10 mg/kg or 10 mg/litre). These 14 allergens account for approximately 90% of food allergic reactions. Any food containing these allergens, whether as an ingredient, processing aid, or through cross-contact, must be declared to the consumer.
Labelling Requirements by Food Type
Pre-packed food (manufactured and sealed before sale, such as supermarket products) must have allergens emphasised in the ingredients list, typically in bold, underline, or contrasting text. PPDS food (prepared and packed on the same premises from which it is sold, such as sandwiches made and wrapped in a cafe) must, under Natasha's Law, carry a label listing the food name and a full ingredients list with the 14 allergens emphasised. Non-prepacked food (sold loose, such as meals served in a restaurant) does not require a physical label, but the business must be able to provide allergen information to the customer. This can be done verbally, but a written notice must direct customers to ask. The FSA strongly recommends written allergen information for all non-prepacked food.
Implementing Allergen Procedures
Every food business needs documented allergen procedures covering ingredient tracking, recipe management, and communication with customers. Maintain up-to-date ingredient records from suppliers, including specifications confirming allergen content. When recipes change or new suppliers are used, allergen information must be reviewed immediately. Staff must be trained in allergen awareness and understand how to communicate allergen information accurately. Cross-contamination controls during preparation and cooking are essential: separate utensils, work surfaces, and cooking oil for allergen-free preparation where possible. Your allergen matrix (a chart showing which allergens are present in each menu item) should be reviewed whenever the menu changes.
Precautionary Allergen Labelling
Precautionary allergen labelling (PAL) statements such as "may contain" should only be used after a thorough risk assessment has identified a genuine and unavoidable risk of cross-contact. The FSA has published guidance stating that PAL should not be used as a blanket disclaimer to cover all products. Overuse of PAL unnecessarily restricts food choices for allergic consumers and can lead to "label fatigue" where warnings are ignored. Each "may contain" statement must be backed by a documented risk assessment showing that despite all reasonable precautions, cross-contact remains a possibility. This is an area where EHO inspectors and Trading Standards officers are increasingly focused.
Frequently Asked Questions
What is Natasha's Law?
Natasha's Law (the UK Food Information Amendment) came into force on 1 October 2021. It requires food that is pre-packed for direct sale (PPDS), such as sandwiches made and wrapped on the premises, to carry a label showing the food name and a full ingredients list with the 14 declarable allergens emphasised. It was introduced following the death of Natasha Ednan-Laperouse from an allergic reaction to undeclared sesame in a Pret A Manger baguette in 2016.
Do restaurants need allergen labels on their menu?
Restaurants serving non-prepacked food are not required to label every dish, but they must provide allergen information to customers upon request. A written notice (such as a sign on the menu or at the counter) must direct customers to ask staff about allergens. The FSA strongly recommends having written allergen information available, such as an allergen matrix showing which of the 14 allergens are present in each dish.
What is the difference between pre-packed and PPDS food?
Pre-packed food is manufactured and sealed before being offered for sale, typically in a factory or central kitchen, and sold at a different location. PPDS (pre-packed for direct sale) food is prepared, packed, and sold at the same premises, or from a mobile unit or market stall belonging to the same business. Examples of PPDS include sandwiches wrapped in a cafe or salads boxed in a deli. Both require ingredient labels with allergens emphasised, but the rules were only extended to PPDS by Natasha's Law in 2021.
Can you give allergen information verbally?
For non-prepacked food (served loose), allergen information can be provided verbally, but you must have a clear sign directing customers to ask. The member of staff providing the information must be trained and able to give accurate details. Many food safety professionals and local authorities recommend having written allergen information as a backup, because verbal communication relies on staff knowledge and can lead to errors.
Ready to simplify your compliance?
Start your free 14-day trial and see how Paddl makes food safety management effortless.