Natasha's Law: what UK food businesses must do for PPDS items

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title: "Natasha's Law: what UK food businesses must do for PPDS items" description: "Natasha's Law (since October 2021) requires a full ingredient list and clear allergen labelling on any food packed for direct sale. Here's what counts as PPDS, what the label has to say, and how EHOs check it." date: "2026-05-08" keyword: "natasha's law ppds requirements" author: "LogFather"

Since 1 October 2021, any food that's packed on the same premises it's sold from — sandwiches behind the counter, salad pots in the chiller, cakes wrapped in cellophane — must carry a full ingredients list with the 14 UK allergens emphasised. That's Natasha's Law, formally the Food Information (Amendment) (England) Regulations 2019 (with parallel regulations in Wales, Scotland and Northern Ireland).

It applies to PPDS — Prepacked for Direct Sale. If you're a cafe, bakery, takeaway or deli, this almost certainly applies to you.

What counts as PPDS

PPDS is food that is:

1. Packed (in any container — film, bag, box, cup with lid) before the customer orders it, and
2. Sold from the same premises it was packed on.

Examples that ARE PPDS:

• Pre-made sandwiches, baguettes, wraps in your chiller
• Salad pots, pasta pots, soup containers prepped that morning
• Cakes, traybakes, brownies wrapped in cellophane on the counter
• Sushi, sliced quiche, pre-sliced pizza in clamshells
• Coffee shop "grab and go" anything

Examples that are NOT PPDS (different rules apply):

• Food made to order at the till — a sandwich you build for the customer (loose food rules)
• Pre-packaged food made by a supplier off-site (full FIC labelling rules — supplier's job)
• Food eaten in (loose food rules — verbal allergen info still required)

What the PPDS label must include

Every PPDS item needs, on the pack itself or on a label firmly attached:

1. The name of the food (clear, not just "sandwich")
2. A full ingredients list in descending order of weight
3. The 14 UK allergens emphasised within that list — bold, capitals, contrasting colour, or underlined. Pick one style and stick to it.

The 14 allergens you must declare:

| | Allergen | |---|---| | 1 | Celery | | 2 | Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut) | | 3 | Crustaceans | | 4 | Eggs | | 5 | Fish | | 6 | Lupin | | 7 | Milk | | 8 | Molluscs | | 9 | Mustard | | 10 | Nuts (tree nuts: almonds, hazelnuts, walnuts, cashews, pecans, brazil, pistachio, macadamia) | | 11 | Peanuts | | 12 | Sesame | | 13 | Soybeans | | 14 | Sulphur dioxide / sulphites (if >10 mg/kg or 10 mg/litre) |

If you use compound ingredients (e.g. mayo, which contains egg + mustard), you must declare each allergen within those — "mayonnaise (egg, mustard)".

What EHOs actually check

During an inspection involving PPDS items, the EHO will usually:

1. Pick a random packed item from the chiller or counter and read the label.
2. Cross-reference the ingredients list against your allergen matrix (a master document mapping every menu item to its allergens). Inconsistencies between label and matrix = points off.
3. Ask staff who made the item, when, and how they know what's in the recipe (recipe cards, written specs, manager check).
4. Ask what your process is when a recipe changes — does the label get updated the same day, or does the old printed batch run out first?

The point that gets the most cafes is item 4. Recipe drift — swapping margarine for butter on a Wednesday because a delivery didn't show up — must be reflected on labels printed Thursday onwards.

How to build the underlying allergen matrix

Before you print a single PPDS label, you need a master matrix listing every menu item against the 14 allergens. Use our free allergen matrix generator to build one in your browser, or build it in a spreadsheet — the format matters less than the discipline of keeping it current.

Two rules that catch most people out:

• "May contain" is not a get-out clause. It's only legitimate where genuine cross-contamination risk exists despite reasonable precautions. Scattering "may contain nuts" across every menu item to cover yourself is misleading and EHOs will challenge it.
• Update the matrix when the recipe changes, not when you remember at the end of the month. The matrix is meant to reflect what's actually in the food today.

Common PPDS labelling failures

• Allergens listed but not emphasised (just typed in normal weight inside the ingredients list)
• A label saying "contains: gluten, milk, egg" with no full ingredients list — the contains line is in addition to the ingredients list, not a replacement
• Old label still on the chiller after the recipe changed
• "Mayonnaise" in the ingredients list with no breakdown of its sub-ingredients
• Sulphites in a wine reduction not declared because nobody thought of it
• Sesame seeds on the bun not transferred to the burger label

Verbal allergen info: still required for loose food

Natasha's Law specifically covers PPDS, but the parallel rule for loose food (anything sold unpackaged or made to order) is that you must be able to give accurate allergen info verbally and direct customers to a written reference if they ask. Most cafes use the same allergen matrix to power both.

Checklist: Natasha's Law-compliant PPDS

• A current allergen matrix covering every menu item
• Every PPDS pack labelled with: name, full ingredients list, 14 allergens emphasised
• A consistent emphasis style across every label (don't mix bold and underline)
• Compound ingredients broken down to their allergens
• Process for updating labels when recipes change — same day, not next week
• Staff trained to know that "I think it's safe" is never the right answer to an allergen question

One thing to do today

Walk to your chiller and pick up the first PPDS item your hand lands on. Read the label out loud. If you can't see the 14 allergens emphasised in the ingredients list — or if the ingredients list is missing entirely — you've got a Natasha's Law issue to fix before your next inspection. The allergen matrix tool builds the master document you need; the labels themselves still have to be printed and stuck on, but a good matrix means you're never guessing.