Do I need a full ingredients label?

Is the food in packaging at the moment the customer takes it?

The FSA's technical guidance sets out two parts. First, where and when it was packed. Second, the packaging itself. The food must be "either fully or partly enclosed by the packaging; and cannot be altered without opening or changing the packaging; and is ready for sale to the final consumer" (paragraph 96).

The test is about timing, place and packaging, never about what the food is. The same item can be PPDS on one counter and not on another.

Worked examples

The food's name never decides this. Each example is one of the FSA's own edge cases, linked to the leaf it reaches.

• I pack at my unit and sell from a market stall "So if your business sells food from, for example, a market stall or van, and you package this food yourself at a different location, this is PPDS food."
• A wrapped item taken off the shelf The wrapped item on the shelf is PPDS.
• Bagged after someone points at it Food packed after the customer selects or orders it "is non-prepacked food and does not require a label".
• Made to order "Food made to order and food placed into packaging at the consumer's request is not PPDS."
• Boxed ahead of a rush The FSA gives "meals put in containers before they are ordered" and "packaged cartons of chips or chicken nuggets placed under a hot lamp ahead of an expected lunchtime rush".
• Served open, on a tray, or wrapped as handed over The FSA cites "pizza on display, with slices served on an open cardboard tray" and "chips or fries placed into packaging at the time of order".
• Wrapped deli counter goods Examples the FSA gives of PPDS food include wrapped deli counter goods such as cheese and meats.
• Free samples packaged on the premises Examples the FSA gives of PPDS food include free samples packaged on the premises.

Sources

• GOV.UK: Food allergen labelling and information requirements technical guidance

Guidance, not legal advice. Your local environmental health team has the final word.

Contains public sector information licensed under the Open Government Licence v3.0. Crown copyright. Source file last reviewed 23 Aug 2026.

This is general guidance, not legal advice, and it decides nothing about a specific product. The food business operator is legally responsible for what appears on the label, always. Software can derive a label from your data; it cannot take on that responsibility, and no tool can certify a product or a business.