Guide · Food safety · UK
If you wrap it before the customer picks it up, it needs a label. What Natasha's Law asks of your kitchen.
If your kitchen wraps a sandwich, bags a salad or boxes a cake before a customer picks it up, you are almost certainly making prepacked for direct sale food - and it has to carry a label. This is the change most people know as Natasha's Law, and it has been a legal requirement across the UK since 1 October 2021. The rule sounds simple, but the two things operators most often get wrong are deciding which of their products actually count, and keeping the labels accurate as recipes drift.
The law is named after Natasha Ednan-Laperouse, who died in 2016 after eating a baguette whose packaging gave no hint of the sesame baked into it. At the time, food packed on the same premises it was sold from fell in a gap: unlike factory-sealed products it needed no ingredient label, and unlike made-to-order food there was no one to ask. PPDS labelling closed that gap by requiring the packaging itself to carry the information an allergic customer needs before they buy.
The first question
PPDS is food that is packaged at the same place it is offered or sold, and is in that packaging before the customer orders or selects it. Get this classification right and the labelling follows; get it wrong and you either over-label harmlessly or under-label dangerously.
The dividing line is whether the food was in its packaging before the customer chose it. A sandwich you wrap after they order is non-prepacked; the identical sandwich sitting pre-wrapped in a display unit is PPDS. It applies to food behind the counter and to some food sold at mobile or temporary outlets too, and to PPDS provided in settings such as schools, care homes and hospitals. The FSA and NCASS both publish flow charts and checker tools to settle borderline cases.
What goes on the label
A PPDS label must show the name of the food and a full ingredients list, with any of the 14 regulated allergens emphasised within that list - typically in bold, so they stand out at a glance. Emphasis is the point: it is not enough for sesame to appear somewhere in the ingredients; it has to be visible as an allergen. The 14 are celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soya, sulphur dioxide and sulphites, and tree nuts. Labels should be clear and legible; handwritten labels are legally acceptable if legible and properly emphasised, though the FSA prefers printed labels because they carry less risk of error, and a QR code cannot replace the physical label.
Precautionary "may contain" statements are voluntary and separate: only use them after a genuine cross-contact risk assessment shows a real risk you cannot manage out, and never as a blanket disclaimer. The same clear thinking about the 14 allergens that a label demands is what should already be running through your kitchen, which is why PPDS sits so close to communicating the 14 allergens clearly and to day-to-day allergen management that works in a real kitchen.
Where it goes wrong
The most dangerous PPDS error is not a missing label; it is an out-of-date one. A label is only accurate for as long as the recipe behind it. Switch flour brands, change a sauce, take a supplier substitution during a shortage - and if the label does not change with it, you now have a confident, printed, wrong label in front of an allergic customer, which is worse than no label at all. Build a routine that reviews labels whenever a recipe or supplier changes, and treat that review as part of your food safety system rather than an afterthought.
Two boundaries are worth remembering. Distance selling - phone or internet orders - is not changed by the PPDS rules; those already require allergen information at the point of sale and on delivery. And separately, since March 2025 the FSA has encouraged the out-of-home sector to provide written allergen information for non-prepacked food too, so the direction of travel is toward more written information, not less. PPDS is the strict, packaged end of a wider allergen duty that includes Natasha's Law explained for busy food businesses.
Questions
Prepacked for direct sale food is packaged at the same place it is offered or sold to consumers, and is in that packaging before the customer orders or selects it - for example a pre-wrapped sandwich on a shelf or a bagged salad in a chiller. Food made or packed to order, or sold loose, is non-prepacked.
The name of the food and a full ingredients list, with any of the 14 regulated allergens emphasised within the list, typically in bold. The label must be clear and legible. This has been a legal requirement across the UK since 1 October 2021 under what is known as Natasha's Law.
Celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soya, sulphur dioxide and sulphites, and tree nuts. Any of these appearing in a PPDS product must be emphasised within the ingredients list.
They are legally acceptable if they are legible and the allergens are properly emphasised, but the FSA prefers printed labels because they carry less risk of error. A QR code cannot replace the physical label - the information must be on the packaging.
An out-of-date label. A label is only accurate as long as the recipe behind it, so a changed ingredient, sauce or supplier substitution must trigger a label update. A confidently printed but wrong label in front of an allergic customer is more dangerous than no label. Review labels whenever a recipe or supplier changes.
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