Phoenix Journal · Food Safety & Compliance
The law is short and specific. Once you know which of your products count as prepacked for direct sale, complying is mostly routine - here is what it actually requires.
Natasha's Law sounds like a labelling technicality until you see what sits behind it: a teenager who died from an allergen that was never declared. For a busy food business the law is actually short and specific, and once you know which of your products it touches, complying is mostly a matter of routine rather than upheaval.
Since 1 October 2021 it has been a legal requirement across the whole UK - England, Scotland, Wales and Northern Ireland - for food that is prepacked for direct sale to carry a label showing the name of the food and a full list of ingredients, with the 14 regulated allergens emphasised within that list. The emphasis is the point that trips people up: the allergens must stand out inside the full ingredients list, not sit in a separate line that says "contains milk, wheat". A box listing allergens without the full ingredients does not comply. The law is named after Natasha Ednan-Laperouse, who died in 2016 after eating a baguette whose packaging, legally at the time, carried nothing to warn her.
The whole law turns on one category: prepacked for direct sale, usually shortened to PPDS. Food is PPDS when it is packed on the same premises it is sold from, and it is in that packaging before the customer orders or selects it. A sandwich made in the morning and put out on a chiller shelf is PPDS. So is a salad pot, a pasta tub, a wrapped cake or a burger packed ahead of service, including items customers pick up themselves and products kept behind a counter. What is not PPDS is just as important: food made or packed to order after the customer asks for it is not PPDS, and neither is food packed by a different business and supplied to you - though that already has to be fully labelled anyway. Some operators respond by moving products out of the PPDS category, selling them loose instead, which is legal but simply swaps one duty for another.
PPDS also reaches into settings people do not always think of. Food packed on site and then sold by the same business from a market stall, van or temporary pitch is still PPDS, and so is prepacked food provided in schools, care homes and hospitals. If you are unsure, the FSA publishes a decision tool that walks you through whether a given product is caught. Working through your own range against it once, and marking which lines are PPDS, is usually the fastest way to turn the whole question into a settled checklist rather than a recurring worry.
A compliant label is not complicated, but the details are checked. The ingredients list must be complete and accurate, with each of the 14 allergens emphasised every time it appears - typically in bold - so it can be seen at a glance. Labels must be legible, which is why the guidance sets a minimum text size, and while handwritten labels are legally acceptable if they are clear and accurate, they carry a higher risk of error and are not the FSA's preferred route. A QR code or a website cannot replace the physical label; the information has to be on the pack. Precautionary "may contain" wording is voluntary and should only be used where a genuine cross-contamination risk has been identified through a risk assessment, not scattered across everything as a blanket disclaimer. And because the label is only as accurate as the recipe behind it, allergen information has to be updated the moment an ingredient or supplier changes. Keeping that under control is part of the wider food hygiene paper trail that demonstrates a business is in control of what it serves.
The label is the legal minimum, not the whole job. In March 2025 the FSA updated its guidance to encourage the out-of-home sector to provide written allergen information for foods that are not prepacked too - loose and made-to-order items - reflecting a clear direction of travel toward written information everywhere. Underneath the paperwork sits the thing that actually keeps people safe: whole-team knowledge. Allergen management collapses if it depends on one trained person who might be on holiday or off sick; every member of staff who handles food needs to know the 14 allergens, know which are in which products, and know what to do when a customer asks. With around 2.4 million people in the UK living with a diagnosed food allergy, that competence is also what an environmental health officer expects to see, and it is worth knowing what a first EHO visit tends to probe. Natasha's Law made the label a legal duty; the culture around it is what makes the label true.
Questions
No. Food packed to order after the customer asks for it, and food sold loose, is not prepacked for direct sale, so it does not need a Natasha's Law label. You must still make allergen information available for it, and since March 2025 the FSA encourages providing that in writing.
Yes, handwritten labels are legally acceptable if they are legible and the allergens are properly emphasised. However, they carry a higher risk of error and are not the FSA's preferred method - most businesses find a printed system more reliable, especially when recipes change.
Yes. Natasha's Law applies to every food business that produces PPDS food regardless of size - a single-person market stall has the same duty as a supermarket chain. There is no small-business exemption.
No. The 14 allergens must be emphasised within a full ingredients list. A separate 'contains' statement without the complete list of ingredients does not meet the requirement of Natasha's Law.
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