Natasha’s Law labels: what a PPDS label must show

This is general guidance, not legal advice. Your local authority’s food safety team can tell you what applies to your own products.

What is Natasha’s Law?

The law is named after Natasha Ednan-Laperouse, who died in 2016 after an allergic reaction to sesame in a baguette. It had been packed in the shop where it was bought, and at the time food packed that way did not have to carry an ingredients list.

Before 1 October 2021, allergen information for this kind of food could be given in any way, including by staff speaking to customers. Since then, the ingredient and allergen information has had to be on the label. The FSA’s guidance covers England, Wales and Northern Ireland; Food Standards Scotland publishes its own PPDS guidance for Scotland.

Is your food PPDS?

The FSA describes PPDS food as food that is packaged at the same place it is offered or sold to consumers, and packaged before it is ordered or selected. Its examples include:

sandwiches and bakery products packed on site before a customer chooses them
pizzas, salads and pasta pots packed on site
burgers and sausages packed by a butcher on the premises
free samples, such as cookies, packed on site
food you pack and then sell yourself somewhere else, such as at a market stall or from a van

Food that is unwrapped, or packed after the customer orders it, is loose food: it needs no label, but you must still give allergen information, which can be done by talking to the customer. Food packed by one business and sold by another needs full prepacked labelling. For online and phone sales, the FSA says allergen information must be available before the purchase is completed and again at delivery. Unsure which applies? The FSA has an online labelling decision tool, linked in the sources below.

What must a PPDS label show?

The FSA says the label must show the name of the food and a full ingredients list, with the allergenic ingredients emphasised within the list. Both must follow the existing rules for naming food and listing ingredients. From GOV.UK’s guidance on ingredients lists:

A heading. Use “Ingredients”, or a heading that includes the word ingredients.
Weight order. List the ingredients in order of weight, with the main ingredient first.
Every allergen, every time. Emphasise each of the 14 allergens wherever it appears in the list, not just the first time.
Ingredients inside ingredients. The allergens in anything you buy in, such as chocolate or a stock cube, still have to be declared. Copying its ingredients from the supplier’s pack, in brackets after its name, makes sure nothing is missed.

The 14 allergens are celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide and sulphites (above 10 parts per million), and tree nuts.

The FSA’s technical guidance adds two naming rules. Name the cereal, such as wheat, barley or oats, so spelt needs “(wheat)” after it. Name the nut too, such as almonds or walnuts, rather than just “nuts”.

How should allergens be emphasised?

You choose how. The technical guidance gives bold, capitals, contrasting colours and underlining as examples, and allows a short note that explains the method, such as “Allergy advice: for allergens, see ingredients in bold”.

It does not allow a separate “Contains: wheat, egg and milk” box repeating the allergens when there is an ingredients list. Here is a brownie’s list with bold emphasis:

Ingredients: Dark chocolate (cocoa mass, sugar, cocoa butter, emulsifier: soya lecithin), unsalted butter (milk), caster sugar, free range eggs, wheat flour (wheat flour, calcium carbonate, iron, niacin, thiamin), walnuts, cocoa powder, salt.

How big does the text need to be?

The same minimum text size applies as for other packaged food. In England, regulation 5A of the Food Information Regulations 2014 applies Article 13 of the assimilated food information regulation to PPDS food: an x-height (the height of a lower case x) of at least 1.2 mm, or 0.9 mm when the largest surface of the pack is under 80 cm².

Point sizes do not map neatly onto x-height, because typefaces differ, so measure a printed test label. On a narrow 58 mm thermal label, a long list may need a longer label rather than smaller text.

When should you add a may contain warning?

A “may contain” line is voluntary. GOV.UK’s guidance on precautionary allergen labelling says to use one only when you have identified a risk of cross contamination that you cannot control, and to name the allergen, as in “may contain milk”. Avoid general wording such as “may contain allergens”, never pair it with a free from claim for the same allergen, and do not use it in place of good hygiene. Pass on a supplier’s may contain warning unless your risk assessment shows otherwise.

A practical way to make your labels

Write down each recipe by weight, as you actually make it.
Keep the label or specification sheet for every bought ingredient, and check it for allergens and may contain warnings.
Build the ingredients list, including what is inside bought ingredients, and emphasise every allergen.
Print one test label and check the text size and every allergen against the recipe.
Check again whenever a recipe, supplier or brand changes. Swapping an ingredient when stock runs low is an easy way for a label to become wrong.

Questions people ask

Do cakes I sell at a market stall need a PPDS label?

If you pack them yourself before customers choose them, and sell them yourself, the FSA counts them as PPDS food, so yes. Cakes sold unwrapped, or wrapped after the customer picks them, are loose food, but you must still give allergen information.

Can I write “Contains: milk, eggs” instead of using bold?

No. The FSA’s technical guidance says allergens must be emphasised within the ingredients list, and it does not allow a separate contains statement that repeats them when there is an ingredients list.

What happens if my labels are wrong?

Local authorities enforce the rules. The FSA says they can issue an improvement notice, and prosecution is possible in some cases. The bigger risk is to a customer with an allergy.

Where Allergen Label Maker helps, and where it does not

Allergen Label Maker is our Android app for PPDS labels, out now on Google Play. Add your ingredients heaviest first and it suggests allergens from their names, such as milk for butter, for you to confirm or reject. Allergens are bold every time, text never goes below the legal x-height, and labels print on a Bluetooth thermal printer or A4 sticker sheets. It works offline with no account. Every label feature is free for up to 5 products; Pro, yearly or lifetime, adds unlimited products, your logo and more.

What it is good for: clear, consistent labels for home bakers, market stalls, food vans and small cafés.

What it will not do: it is our own app, not made or endorsed by the Food Standards Agency. It cannot see your recipes or your kitchen, and its suggestions are only a prompt that can miss an allergen. You stay responsible for the accuracy of every label, so check each one against your recipe and your suppliers’ labels.

Questions or bugs: Email us.

Sources

Introduction to allergen labelling for PPDS foodFood Standards Agency gov.uk
Allergen guidance for food businessesFood Standards Agency gov.uk
Food allergen labelling and information requirements: technical guidanceFood Standards Agency gov.uk
Allergen and ingredients food labelling decision toolFood Standards Agency submit.forms.service.gov.uk
Food labelling and packaging: ingredients listGOV.UK gov.uk
Food labelling and packaging: precautionary allergen labellingGOV.UK gov.uk
The Food Information Regulations 2014, regulation 5Alegislation.gov.uk legislation.gov.uk
Regulation (EU) No 1169/2011, Article 13: presentation of mandatory particularslegislation.gov.uk legislation.gov.uk
PPDS guidance (May 2023)Food Standards Scotland foodstandards.gov.scot