Natasha’s Law and Food Allergen Labels
Natasha’s Law is the common name for UK rules on food prepacked for direct sale (PPDS). For a caterer, the crucial question is whether food is put into packaging before the customer orders or selects it and is packed at the same place it is offered for sale. If it is PPDS, the package needs the food’s name and a full ingredients list, with any of the 14 regulated allergens emphasised where they appear. A printed label is only as safe as the recipe information and working practices behind it.
Which foods are PPDS?
Think of sandwiches wrapped in a café kitchen and placed in a display fridge before customers choose them. A cake boxed on the same premises before it is offered may also qualify. Food packaged only after a customer orders is generally non-prepacked food instead; it still has allergen information duties, but the PPDS full-ingredients label rule is not automatically the same. Prepacked products made elsewhere have their own labelling rules. Check the FSA’s sector guidance if the sales route is unusual, including mobile or temporary premises.
Do not decide solely by whether a container is clear, whether the customer can open it or whether the item is made that morning. Timing and place of packaging, and whether the food is already packaged when the customer chooses it, are central to the PPDS definition.
What must the label show?
The PPDS label must show the name of the food, an ingredients list and any of the 14 regulated allergens emphasised in that list when present. Allergens can be highlighted in bold, capital letters, contrasting type or underlining, provided the information is clear. The 14 categories include milk, eggs, peanuts, sesame, fish and cereals containing gluten, among others. The same allergen may appear in more than one ingredient, so check every occurrence.
A label saying only “contains milk” is not a substitute for the required full ingredients list. Nor is an old label safe when a supplier changes a sauce or a baker substitutes a topping. Keep current supplier specifications, recipes and label templates linked. When an ingredient changes, stop using the old label until the updated version has been checked.
Build a reliable label process
Assign one person to approve the master recipe and another step to verify the printed label against it. Include sub-ingredients from bought-in products, such as a dressing or bread, rather than listing only the main ingredients. Set a rule for substitutions: no unrecorded swap is allowed, even during a busy lunch rush. Check that labels are attached to the right product, particularly when several sandwiches look alike.
Teach staff to recognise allergen cross-contact as a separate issue. A correctly labelled egg-free salad could still become unsafe if prepared with an unclean utensil used for egg mayonnaise. Separate work where possible, clean effectively and assess any unavoidable risk. Precautionary “may contain” wording should follow a genuine risk assessment; it is not a replacement for good controls.
Customer questions still need a careful answer
Customers may ask about ingredients even when a label is present. Train staff to pause, consult accurate written information and involve a responsible colleague if uncertain. Never infer that a dish is safe because an allergen is not obvious by sight. If the business cannot establish whether a product is suitable for a particular customer, it should say so clearly rather than guess.
Food handlers need role-specific instruction in allergens, labels and cross-contact. Our Food Hygiene for Catering Level 2 course can support general kitchen hygiene learning; managers should add detailed instruction for the exact products and labels they use. The FSA offers PPDS guidance and labelling instructions for checking the rules.
Make changes visible before sale
Review labels whenever recipes, suppliers, package sizes or preparation locations change. Keep a dated copy of approved information and remove obsolete stock of labels. During a handover, tell the next shift about any product held back because its ingredient details are uncertain. This prevents an accurate label system from failing at the final step: the moment the wrong pack reaches a customer.
Catering Food Hygiene training online
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Check special cases before printing labels
A food business may sell the same product in several ways. A sandwich wrapped before it goes on the counter can be PPDS, while one assembled and packed only after a customer orders it is treated differently. A product made at one location and sold at another may instead fall under the wider prepacked-food rules. Because the classification changes what information must appear on the pack, map each sales route before choosing a label template. If you are unsure, use the FSA’s decision support and seek advice from your local authority rather than relying on a label copied from a similar business.
Keep packaging and recipe decisions together: label checks should happen before a new product is launched, not after the first customer asks what is inside.
When staff make labels by hand, introduce a final check before packs enter the display. Compare the product name, ingredient list and highlighted allergens with the approved recipe. Remove any label with unclear printing or missing information instead of trying to explain it verbally at the till.
