Guide · Allergens
Natasha’s Law: what goes on a PPDS label — and what does not
Since 1 October 2021, a sandwich made and wrapped in the shop that sells it needs a full ingredients list on the pack. Three things have to be on the label, several things that people expect do not, and the four UK nations wrote four regulations that say the same thing. Here is what the text actually requires, quoted from legislation.gov.uk.
Why it is called Natasha’s Law
Natasha Ednan-Laperouse was fifteen when she died of anaphylaxis on 17 July 2016, after eating a baguette bought at an airport. She was allergic to sesame. In his report of 8 October 2018, the coroner recorded that the baguette “contained sesame to which she was allergic. There was no specific allergen information on the baguette packaging”. Food made and packed on the premises could at the time give its allergen information, as the FSA puts it, “by any means. This includes being informed verbally by staff.” The coroner named exactly that rule as his first matter of concern.
The four UK governments closed the gap with effect from 1 October 2021:
- England — Food Information Regulations 2014, reg. 5A and 6A (inserted by SI 2019/1218, restated by SI 2022/481)
- Wales — Food Information (Wales) Regulations 2014, reg. 5A and 6A (SI 2020/295 (W. 67))
- Scotland — Food Information (Scotland) Regulations 2014, reg. 5A and 6A (SSI 2021/70)
- Northern Ireland — Food Information Regulations (Northern Ireland) 2014, reg. 5A and 6A (SR 2020/80)
We compared regulation 5A in all four, word for word. The differences are drafting (“package” in England, “packaging” in Scotland) and one Scottish qualifier — the allergen part applies “where a food is a relevant food”, that is, where an allergen is in it, which is the only case in which there is anything to emphasise anyway. What has to be on the label is the same everywhere in the UK.
What counts as “prepacked for direct sale”
The regulations borrow the term from Article 2(2)(e) of Regulation (EU) No 1169/2011 as it applies in the UK, which defines prepacked food and then says that it “does not cover foods packed on the sales premises at the consumer’s request or prepacked for direct sale”. A definition of PPDS itself is not in the legislation. The Food Standards Agency’s reading is the one enforcement officers work from:
“Prepacked for direct sale or PPDS is food that is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected.”
Two conditions, then: packed where it is sold, and packed before the customer chooses it. The FSA’s own examples:
- sandwiches and bakery products packed on site before a customer selects or orders them;
- fast food packed before it is ordered, such as a burger under a hot lamp;
- pizzas, rotisserie chicken, salads and pasta pots prepackaged on site;
- burgers and sausages prepackaged by a butcher on the premises;
- free samples of cookies packed on site;
- food packed and then sold by the same business at its own market stall or van;
- PPDS food in schools, care homes and hospitals.
And what is not PPDS. Food packed after the customer orders it, or sold unpacked, is non-prepacked: allergen information is still owed, but “this can be done through other means, including orally”. Food packed by one business and sold by another is ordinary prepacked food and needs the full label. The line between the three:
- Prepacked — packed elsewhere, sold here: the full label, allergens emphasised in the ingredients list.
- PPDS — packed here, before the customer chooses: name and ingredients list on the pack, allergens emphasised.
- Non-prepacked — packed here after the customer orders, or not packed at all: allergen information by any means; if given orally, a written notice must say that staff can be asked.
The three things the label must show
Regulation 5A(1) of the English regulations, in the version in force since 30 September 2022:
“A food business operator who offers for sale a food to which this regulation applies must provide directly on the package or on a label attached to the package the particulars required by— (a) Article 9(1)(b) (list of ingredients) … (b) Article 9(1)(c) (labelling of certain substances or products causing allergies or intolerances), as read with Article 21(1) and Annex 2.”
Regulation 6A adds the name of the food, also “directly on the package or on a label attached to the package”. Together:
- The name of the food — its legal name, or failing that the customary name, or failing that a descriptive name (Article 17). “Egg mayonnaise sandwich” is a descriptive name; a brand or fancy name alone is not.
- The list of ingredients — under a heading that “consists of or includes the word ‘ingredients’”, in descending order of weight, with compound ingredients broken down (Article 18 and Annex VII). The usual source of mistakes is the bread, the mayonnaise, the pesto: each is itself made of several ingredients, and each has to be listed.
- The fourteen allergens, emphasised — every time they appear in the list (Article 21(1) and Annex II).
The presentation rules come with it: regulation 5A refers to Article 13(1) to (3), which sets a minimum x-height of 1.2 mm (0.9 mm if the largest surface of the pack is under 80 cm²), and to Article 15, which in the UK version reads: “mandatory food information shall appear in English.” Handwritten labels are allowed if they meet the same size, says the FSA.
An example
An egg mayonnaise sandwich made from 100 g bread, 60 g egg, 30 g bought-in mayonnaise, 3 g cress and a pinch of pepper. Bread and mayonnaise are compound ingredients, so their own ingredients follow in brackets — for the mayonnaise, as the supplier’s label lists them:
Egg mayonnaise sandwich
Ingredients: bread (wheat flour, water, yeast, salt, rapeseed oil), free range egg, mayonnaise (rapeseed oil, water, free range egg yolk, spirit vinegar, sugar, salt, mustard seed), cress, black pepper.
What a PPDS label does not need
Regulation 5A refers to Article 9(1)(b) and (c), regulation 6A to (a). It does not refer to the other points of Article 9(1). And Article 44(1) of the UK version of Regulation 1169/2011, which covers everything that is not prepacked, “or prepacked for direct sale”, says:
“(a) the provision of the particulars specified in point (c) of Article 9(1) is mandatory; … (c) the provision of the other particulars specified in Articles 9(1) and 10 is not mandatory …”
So Natasha’s Law itself does not require:
- a nutrition table. If you add one voluntarily, Article 30(5) allows it to be limited to energy, or to energy plus fat, saturates, sugars and salt — and it has to follow the usual format rules;
- percentages of named ingredients (QUID), with one exception: in England, regulation 7 of the Food Information Regulations 2014 requires the percentage of meat for PPDS food that “contains meat and any other ingredient”;
- a best-before date, net quantity or business address — not under these regulations. Food safety rules and good practice may still make a date sensible.
Two exemptions are written into the text. Distance selling is excluded from regulation 5A (“otherwise than by means of distance communication”); the allergen information then has to be available before the purchase and again at delivery. And through Article 16(2), on a pack whose largest surface is smaller than 10 cm² the ingredients list “shall be provided through other means or shall be made available at the request of the consumer” — the name and the allergens stay on the pack.
How to emphasise the allergens
The legal text is Article 21(1)(b), identical in the UK and EU versions: the allergen “shall be emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour”. The two agencies read it slightly differently:
| Agency | Names as examples |
|---|---|
| Food Standards Agency (England, Wales, Northern Ireland) | “bold type, capital letters, contrasting colours or through underlining” |
| Food Standards Scotland | “using a different text colour”, “writing the allergens in bold or underlining” |
Capital letters appear on one list and not the other. Bold is on both. If your products cross a border inside the UK, bold is the choice that needs no second thought. What is emphasised is the Annex II name — “milk”, “wheat”, “mustard” — not necessarily the whole word around it. The full list is in our guide to the 14 allergens; note one UK difference for mustard, explained in UK food labelling regulations.
Enforcement: Scotland is stricter
Local authorities enforce the rules. What differs is which breach is a criminal offence:
| Nation | Criminal offence under regulation 10 |
|---|---|
| England, Wales, Northern Ireland | the allergen part only, reg. 5A(1)(b) |
| Scotland | all of reg. 5A(1), and reg. 6A(1) and (3) — the ingredients list and the name as well |
In England, the rest of regulations 5A and 6A is enforced by improvement notice (regulation 12). The penalty for an offence is the same text in all four: “a fine not exceeding level 5 on the standard scale”. In England and Wales, level 5 has had no upper limit for offences committed since 12 March 2015.
Making the same product with different weights each time? The weights decide the order of the list, so keep the recipe, not just the label. Our free nutrition calculator and allergen checker work without an account.
Frequently asked questions
What is Natasha's Law?
The name used for the rules that took effect across the UK on 1 October 2021: food that is prepacked for direct sale (PPDS) must carry the name of the food and a full list of ingredients on the package or on a label attached to it, with the fourteen allergens emphasised. In England the rules are regulations 5A and 6A of the Food Information Regulations 2014; Wales, Scotland and Northern Ireland have their own, equivalent regulations.
Does a PPDS label need a nutrition table?
No. The PPDS regulations require the name of the food, the list of ingredients and the allergens. They do not refer to the nutrition declaration, and Article 44 of the UK version of Regulation 1169/2011 makes only the allergen information mandatory for food that is not prepacked. A nutrition table may be added voluntarily; it then has to follow the normal rules.
Can I emphasise allergens in capital letters?
The Food Standards Agency, which covers England, Wales and Northern Ireland, names bold type, capital letters, contrasting colours or underlining. Food Standards Scotland names a different text colour, bold or underlining, and does not mention capitals. Bold type is named by both, which makes it the safe choice for a business selling in more than one nation.
Does Natasha's Law apply to food sold online?
Not in the same way. The PPDS rules expressly exclude sales by distance communication. Food sold online or by phone still needs its allergen information available before the purchase is completed and again at delivery.
This article is general information and does not replace legal advice. Quoted from legislation.gov.uk: the Food Information Regulations 2014 (S.I. 2014/1855), revised version in force from 30 September 2022, and the equivalent regulations for Wales, Scotland and Northern Ireland; Regulation (EU) No 1169/2011 as it applies in Great Britain, revised version in force from 27 February 2025. In Northern Ireland the EU version of Regulation 1169/2011 applies. The definition of PPDS, the examples and the emphasis options are the interpretation of the Food Standards Agency and Food Standards Scotland, not the text of the law.