Natasha's Law: What UK Food Producers Must Know About PPDS Labelling

What Natasha's Law changed

On 1 October 2021, new allergen labelling rules came into force for food sold in the UK. The change — which came to be known as Natasha's Law, named after Natasha Ednan-Laperouse who died in 2016 after an allergic reaction to undeclared sesame in a baguette — specifically targets pre-packed for direct sale (PPDS) food.

Before October 2021, PPDS food could legally be sold with allergen information provided verbally or on a separate notice, rather than on the packaging itself. The 2021 amendment to the Food Information Regulations 2014 changed that: PPDS food must now carry a label showing the product name, a full ingredients list, and the 14 allergens emphasised within that list.

For artisan food producers who pack their products on the same premises where they sell them — at a market stall, from a farm shop, at a bakery counter — this rule directly affects how you label your products.

What is PPDS food?

PPDS (pre-packed for direct sale) is food that is:

• Packaged by a food business before the customer orders or requests it
• Packaged on the same premises where it will be sold to the customer
• Sold directly to the final consumer from those same premises

The classic examples for artisan producers:

• Brownies individually wrapped before taking them to a market stall
• Granola bagged up in the kitchen and sold from a market table
• Jars of jam sealed and labelled at home and sold direct at a craft fair
• Bread or pastries packaged at a home kitchen and sold via a farm shop hatch

The common thread: you are the producer, the packager, and the seller on the same premises. The customer cannot inspect the unwrapped product before choosing it.

What PPDS is NOT:

• Pre-packed food (packaged before the point of sale for distribution to a different place — supermarkets, retailers, online delivery) — this was always subject to full labelling requirements
• Loose food (sold from open display, where the customer can ask a member of staff) — this is covered by separate "non-prepacked" allergen information rules, not the PPDS rules
• Food made to order at the point of sale (a sandwich made while the customer watches) — also non-prepacked

The line that matters for artisan producers: if you pack the product before the customer asks for it, on the same premises where you sell it, it is PPDS.

What a PPDS label must now include

Under the rules in force since 1 October 2021, every PPDS product must carry:

1. The name of the food — the common or legal name, not a brand name (e.g. "shortbread" not just "Maggie's Biscuits")
2. A full ingredients list — all ingredients in descending order by weight
3. The 14 allergens emphasised — wherever they appear in the ingredients list, highlighted using bold, italics, underlining, or contrasting colour so they stand out clearly

That's it. PPDS labels do not need to carry all the information required on pre-packed food sold in retail — no durability date is required on the label itself (though best-before and use-by dates are still required for food safety, they do not need to be on the PPDS label). The three elements above are the specific Natasha's Law requirements.

Example PPDS label for a honey and oat flapjack:

Honey and oat flapjack

Ingredients: oats (47%), golden syrup (22%), unsalted butter (milk) (18%), honey (9%), brown sugar (4%)

Allergens: gluten (oats), milk

The allergens oats (a cereal containing gluten) and butter / milk are bolded in the ingredients list. The "Allergens:" line beneath is a useful addition but not mandatory — the legal requirement is the emphasis within the list itself.

How this compares to what was required before

Before October 2021, artisan producers selling PPDS food had two compliant options:

1. A "contains" label listing allergens only (e.g. "Contains: oats, milk")
2. Providing allergen information verbally or via a separate notice at the point of sale

Both options are now closed for PPDS food. The "contains" label alone is not compliant — you need the full ingredients list with allergens highlighted within it. Verbal disclosure does not remove the requirement for physical labelling.

This is the most significant practical change for market stall producers and farm shop operators: allergen-only labelling was common and convenient, but it no longer meets the legal standard.

Do I need to re-label existing stock?

The rules have been in force since 1 October 2021. If you produce PPDS food, you should already be compliant. If you are not yet using full-ingredient labels on PPDS products, you are currently non-compliant with the 2021 requirements and should update your labels as quickly as possible.

The FSA's guidance on allergen labelling changes for PPDS food is the authoritative source on the current requirements, and includes worked examples and information to help businesses determine whether their products are PPDS.

What about cross-contamination (may contain warnings)?

Natasha's Law covers intentional ingredients — allergens that are present because you added them to the recipe. It does not directly mandate "may contain" warnings for cross-contamination.

That said: if you produce food in a space where allergens are also present (a home kitchen used for both nut-containing and nut-free products, for example), a "may contain" advisory on your labels is both good practice and increasingly expected by allergy-aware consumers. It is not legally required, but its absence can expose you to liability if a cross-contamination incident occurs.

The related guide on the 14 allergens UK food producers must declare covers the distinction between mandatory ingredient declarations and voluntary "may contain" advisories in more detail.

Practical steps for PPDS compliance

1. Identify your PPDS products. List every product you pack before the customer requests it, on the same premises where you sell it. Each of these is PPDS.

2. Build a full ingredients list for each. List all ingredients in descending order by weight. Include sub-ingredients (e.g. "butter (milk, salt)" not just "butter").

3. Tag each ingredient for allergen content. Work through your 14 allergens list and flag which ingredients carry which allergens.

4. Emphasise allergens in the list. Use bold, italics, or contrasting colour — whatever your label system supports. Ensure every occurrence is emphasised, not just the first.

5. Include the product name. Common name, not just a brand name.

6. Produce the label. Whether printed, typed, or handwritten: it must be legible and physically on the packaging. A label tied to a box lid counts; a sticker on a see-through bag counts. A card placed next to the product does not.

7. Retain your allergen records. Keep per-batch ingredient records so that if a customer reacts, you can identify which batch they bought from and what went into it. The guide on batch tracking for small UK food producers covers this.

The story behind the law

Natasha Ednan-Laperouse was 15 when she died on a flight from Heathrow in July 2016. She had bought a baguette from Pret A Manger at Heathrow, unaware it contained sesame seeds. Under the rules at the time, Pret was not required to list ingredients on food prepared and sold from the same premises — PPDS food. Sesame was not declared on the packaging.

The 2018 inquest found that she died as a result of the food business's failure to list the allergen. The inquest coroner made a Prevention of Future Deaths report, and the government responded with the amendment to the Food Information Regulations that came into force on 1 October 2021.

The law applies to every food producer making and selling PPDS food, regardless of scale. The obligation to label properly is not reduced because you sell at a small market or operate from home.

---

This guide covers PPDS labelling requirements under the Food Information Regulations 2014 as amended in 2021. It is general information for UK artisan food producers, not legal advice. For specific questions about your products, contact your local Environmental Health team or refer to the FSA's PPDS guidance directly.

Sources

• Food Information Regulations 2014 (SI 2014/1855), legislation.gov.uk
• Allergen labelling changes for PPDS food (Natasha's Law), Food Standards Agency
• Allergen guidance for food businesses, Food Standards Agency