Natasha’s Law for small food businesses: what PPDS actually requires

“Natasha’s Law” is the name that stuck, but the rule itself is plainer than the name suggests, and it isn’t a bakery rule. It applies to any UK food business (a home baker, a butcher’s counter, a farm shop, a deli or café, a caterer, a jam or preserve maker) on identical terms. If you pack food before someone asks for it, this guide is about you.

Where the name comes from

The law is named after Natasha Ednan-Laperouse, who died in 2016 after an allergic reaction to a baguette bought at an airport that didn’t list its allergens on the packaging. The rule that followed came into force on 1 October 2021, and it’s formally called PPDS labelling: Prepacked for Direct Sale.

What “PPDS” actually means

Food is PPDS when it is packaged at the same place it’s offered or sold to the customer, and it’s already in that packaging before the customer orders or selects it. That covers more than it sounds like it should:

• Sandwiches or cakes boxed up before a customer asks for them
• Items on a display unit that a customer picks up themselves, already wrapped
• Trays at a butcher’s counter, pre-packed before the shop opens
• A farm shop’s own jam, wrapped and labelled on the same premises it’s sold from
• Takeaway containers filled and sealed before the order is placed

The test is timing and location, not what the food is. The same product can be PPDS or not depending on when it was packed relative to the sale: a tray of brownies boxed at 6am for a market stall is PPDS; the same brownie bagged after a customer points at it generally isn’t. If your situation sits anywhere near that line, it’s worth checking with your local Environmental Health team rather than guessing. See our guide on what an EHO wants to see for how that conversation tends to go.

This guide covers PPDS specifically. Food you buy in from someone else, already packaged, carries its own labelling obligations under separate rules; if you’re relabelling or repacking bought-in food, that’s worth a specific check rather than assuming PPDS covers it.

What has to be on the label

Two things, and only two things, but both matter:

1. The name of the food. Plain and accurate: “Victoria sponge”, not a marketing name that hides what it is.
2. A full ingredients list, with the 14 allergens emphasised every time they appear: typically bold, CAPITALS, underlined, or a contrasting colour, so they stand out from the surrounding text at a glance.

That’s it. No separate allergen box, no QR code, no “ask a member of staff” instead of the label itself: a PPDS label has to carry the actual information, on the pack. Our guide to the 14 allergens covers the full list and where declarations go wrong; our weight-order guide covers how to write the ingredients list itself, including compound ingredients like “bread” in a sandwich.

What emphasis actually looks like

The rule is that an allergen has to be visually distinct from the rest of the list, not that it follows one specific format. The FSA names four methods: bold type, capital letters, underlined text, or a contrasting colour — what matters is that a customer scanning the list can pick the allergens out without reading every word. Emphasis is required every single time an allergen ingredient appears, not just the first time.

What PPDS doesn’t require

It’s worth being clear about what this rule isn’t, because the gaps are as important as the requirements:

• It doesn’t require a “may contain” warning. Precautionary allergen labelling is a separate, voluntary decision based on your own risk assessment, covered in our guide to “may contain”.
• It doesn’t require nutrition information, in most cases. Nutrition labelling is mandatory for prepacked food generally, but food you make and supply directly, in small quantities, to the final consumer or a local retailer is exempt under Annex V, point 19 of Regulation (EU) 1169/2011 — exactly the shape of a home bakery or market stall’s own PPDS food. Worth checking the exemption still applies if you scale up or start supplying further afield.
• It doesn’t make the software, or anyone else, responsible for your label. The food business operator is legally responsible for what’s on the label, always (a point worth holding onto as you read the rest of this series).

Why this exists, and why it’s worth getting right

14 allergens cause the overwhelming majority of serious allergic reactions in the UK, and for someone with a genuine allergy, an inaccurate label isn’t an inconvenience; it’s the difference between a normal day and a hospital visit. Getting this right isn’t just about avoiding a fine; it’s the actual point of the rule.

It’s also more achievable than it sounds once the workflow is right. The hard part isn’t knowing the rule; it’s keeping every supplier declaration up to date every time you buy a pack, swap a brand, or tweak a recipe, by hand, forever. That’s the specific problem ProvenBatch is built to solve: a label derived from your data, with an audit trail, rebuilt from the actual supplier pack you used in a given batch, not from a recipe you typed once and never revisited. Allergens are detected for you from the pack’s own declaration, and you confirm each one: the app points, you decide, because the responsibility stays exactly where the law puts it: with you.

Sources

• GOV.UK: Introduction to allergen labelling for PPDS food
• Food Standards Agency: Labelling guidance for prepacked for direct sale (PPDS) food products
• GOV.UK: Nutrition labelling — exemptions under Annex V, Regulation (EU) 1169/2011