Natasha's Law Explained: Is Your Food Labelling Compliant?
A simple guide to allergen labelling, PPDS food and the mistakes food businesses need to avoid.
Estimated reading time: 3 minutes
Allergen labelling is one of those areas where food businesses can easily get caught out. Whether you're running a café, bakery, deli, takeaway or restaurant, the rules depend on how your food is prepared, packaged and sold.
One of the biggest areas of confusion is Prepacked for Direct Sale (PPDS) food, commonly associated with Natasha's Law.
So, what does your business actually need to do?
The three types of food labelling
Food generally falls into three categories, each with different allergen information requirements.
1. Pre-packed food
Food packaged before being offered for sale, such as a supermarket sandwich produced by a separate manufacturer.
These products generally require a full ingredients list, with any of the 14 regulated allergens clearly emphasised, usually in bold.
2. Non-prepacked food
Food served in restaurants, cafés and takeaways, or packaged after a customer orders it.
You must still provide accurate information about the 14 regulated allergens, but this can be communicated through menus, an allergen matrix or verbally by knowledgeable staff.
If providing information verbally, customers must be clearly directed to where they can obtain it.
3. Prepacked for Direct Sale (PPDS)
Food packaged by a business before a customer selects or orders it, and sold from the same premises or site, or under certain other qualifying arrangements.
Common examples include:
Sandwiches prepared, wrapped and displayed in a café.
Cookies baked, bagged and placed on a counter.
Sausages packaged by a butcher for sale.
Cakes sliced, boxed and displayed for customers.
If your food is PPDS, it must have a compliant label.
What is Natasha's Law?
Natasha's Law was introduced in England on 1 October 2021, following the death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction after eating a baguette containing sesame.
Previously, PPDS food did not have to display a full ingredients list on its packaging, although allergen information still had to be available.
The law changed to give consumers clearer information about what they're eating.
Today, PPDS food must display:
The name of the food
A full ingredients list
Any of the 14 regulated allergens emphasised within that list, for example in bold
It's not enough to list only the allergens. Ingredients within compound products, such as mayonnaise, sauces and fillings, must also be accounted for, subject to applicable exemptions.
Is your food PPDS?
Ask yourself three questions:
Is the food packaged before the customer selects or orders it?
Is the food presented to the customer in packaging?
Is it packaged and sold under arrangements that meet the PPDS definition, typically at the same premises or site?
If the answer to all three is yes, your food is likely PPDS.
Remember: Food packaged after a customer orders it is generally not PPDS, but allergen information must still be provided.
Market stalls, mobile businesses and businesses operating across multiple locations may have different arrangements, so it's important to check the specific circumstances.
Five common allergen labelling mistakes
Even well-run food businesses can make mistakes.
1. Missing ingredients
Listing 'mayonnaise' without accounting for its constituent ingredients, where required, can result in an incomplete label.
2. Outdated labels
Your supplier changes a recipe, but your labels don't change with it. Always check ingredient specifications when products or suppliers change.
3. Incorrect allergen identification
Allergens must be correctly identified and emphasised within the ingredients list.
4. Relying on 'may contain'
A precautionary allergen warning isn't a substitute for proper allergen controls. It should only be used where a genuine cross-contact risk remains following an appropriate risk assessment.
5. Assuming small businesses are exempt
Natasha's Law applies to qualifying PPDS food regardless of whether you're a small independent café or a large food business.
What should your business do?
Start by reviewing the food you prepare, package and sell.
Identify which products are PPDS, check your ingredient information against current supplier specifications and make sure your labels accurately reflect the food being sold.
Staff should also understand the difference between PPDS and non-prepacked food, and know how to provide reliable allergen information to customers.
Getting allergen labelling right isn't just about compliance. It's about protecting your customers and building trust in your business.
Not sure whether your labels comply?
At The Compliant Chef, we help cafés, bakeries, restaurants and other food businesses understand their legal responsibilities and identify food safety issues before they become bigger problems.
From allergen management and food labelling reviews to comprehensive pre-EHO inspections, we provide practical, straightforward advice tailored to your business.
Get in touch today to arrange a food safety audit or allergen labelling review.
This article provides general guidance on food labelling requirements in England. Individual business arrangements may affect the applicable requirements. For further information, refer to the Food Standards Agency's official PPDS guidance.
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