Phoenix Journal · Kitchens
Natasha's Law turns every ready-wrapped item you sell into a labelling duty - and the difference between made-to-order and prepacked for direct sale is where good kitchens get caught out.
Case postmortem
A busy counter deli was packing sandwiches, wraps and salad pots into clamshells every morning before service - and one routine visit from an environmental health officer stopped the whole operation in its tracks.
On paper, the kitchen looked tidy. Chilled displays were stocked by nine, allergen matrices were pinned by the pass, and staff could reel off which fillings contained nuts. But the pre-packed pots sitting in the grab-and-go fridge carried only a small sticker with the product name and a price. No ingredients list. No emphasised allergens. Nothing a customer could read before they picked one up and walked out.
Because those pots were packed on-site, before the customer chose them, they were prepacked for direct sale - PPDS - and they fell squarely under Natasha's Law. The officer issued an improvement notice, the grab-and-go fridge was emptied that afternoon, and a week of lost lunchtime sales followed while labelling was put right. Nobody had been harmed, and that was pure luck. The point of the law is that luck should never be the safeguard standing between a customer and a life-threatening reaction.
Natasha's Law is named after Natasha Ednan-Laperouse, who died of anaphylaxis in July 2016 after eating a baguette that contained sesame baked into the dough. There was no allergen information on the packaging and nothing on the display cabinet to warn her. Her parents campaigned for change, the legislation was passed in 2019, and it came into force across the UK on 1 October 2021.
The rule is deceptively simple. Any food that is packaged at the same place it is offered or sold, and is already in that packaging before the customer orders or selects it, is PPDS. That covers the salad pots in a self-service fridge, sandwiches wrapped and stacked behind the counter, and boxed items sold from a mobile or temporary pitch. If a customer picks it up ready-wrapped rather than asking you to make it to order, it almost certainly needs a full label.
Every PPDS item must carry the name of the food and a full ingredients list, with any of the 14 regulated allergens emphasised within that list. Emphasis means the allergen genuinely stands out - bold type, capital letters, a contrasting colour or underlining - and it applies right through the list, including inside compound ingredients. Under Article 9 of the Food Information to Consumers Regulation, the presence of those 14 allergens must be declared wherever they are used. The deli's price-and-name sticker met none of that.
The 14 are celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, tree nuts, and sulphur dioxide and sulphites where these exceed ten parts per million. That last one is worth remembering because sulphites hide in dried fruit, wine vinegars and some processed potato - SO₂ is easy to miss when you are writing a label from memory rather than from the recipe.
The failure here was not ignorance of allergens - the staff knew their menu. It was a gap between two different duties that people routinely muddle. When you make a sandwich to order and hand it straight over, you can give allergen information verbally or by signposting to a written source. That is the loose-food rule, and the deli had it covered. The moment the same sandwich is wrapped and put on a shelf to be chosen later, the duty changes entirely and a full written label is legally required on the pack.
Three things stacked up:
There is a deeper risk sitting underneath all of this, and it is one a label can never fix on its own. A label only tells the truth about what is genuinely in the food. If an allergen gets into a dish it was never meant to contain - a shared prep surface, a blade used on nuts and then on a nut-free pot, residue carried through poorly cleaned equipment or extraction that recirculates grease and debris - then even a perfect label is wrong. Cross-contact turns an accurate label into a false promise.
Putting this right is methodical rather than difficult. The deli worked through it in the order below, and it is a sound sequence for any food business selling ready-wrapped food.
Enforcement, for context, tends to be proportionate. Local authorities usually reach for improvement notices, cautions and warnings before penalties, but the law allows fines of up to £5,000 per offence, and a serious allergen incident can escalate far beyond that. The reputational cost of a customer reaction is heavier still.
It is easy to think of allergen compliance as a paperwork exercise and cleaning as a separate chore. In practice they are two halves of the same duty of care. The label states what should be in the food; the kitchen environment determines what actually ends up there. Grease-laden extraction, contaminated ductwork and surfaces that never get a deep clean are exactly how a stray allergen travels from one dish into another that was labelled free of it. Getting both right - accurate labels and a demonstrably clean kitchen - is what real allergen management looks like. If you want the wider picture of how the labelling regime fits together, our overview of Natasha's Law for busy food businesses sets out the duties in full.
Questions
Food made to order is prepared and handed to the customer after they ask for it, so you can give allergen information verbally or point them to a written source. PPDS food is packaged on the same premises before the customer chooses it - for example a wrapped sandwich on a shelf or a salad pot in a self-service fridge. PPDS food must carry a full written label with the name of the food and a complete ingredients list with the 14 allergens emphasised.
All 14 regulated allergens must be emphasised within the ingredients list wherever they appear: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, tree nuts, and sulphur dioxide and sulphites above ten parts per million. Emphasis can be bold type, capital letters, a contrasting colour or underlining, and it applies throughout the list, including inside compound ingredients.
No. A label only tells the truth about what is deliberately in the food. If an allergen gets in by accident - through a shared blade, an uncleaned surface or grease-laden extraction carrying residue - the label becomes a false promise. Controlling cross-contact through separated preparation and a properly deep-cleaned kitchen is an essential part of allergen management, working alongside the label rather than instead of it.
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