Introduction
Natasha’s Law is a new way to manage allergy labelling in the UK. This new law came into effect on October 1, 2021. It came into effect following the death of 15-year-old Natasha Ednan-Laperouse. Natasha had a severe allergy to sesame seeds and sesame products.
There is no cure for a food allergy. So if a person suffers from a food allergy, even a trace of the allergen can cause severe anaphylaxis. Good communication is therefore vital.
So let’s break down what your business must do to meet Natasha’s Law food labelling requirements. Watch the video below, if you prefer to listen.
The Story Behind Natasha's Law - Food Allergen Labelling
You may be wondering why Natasha’s Law came about? In July 2016, Natasha purchased a pre-packaged baguette at Heathrow Airport from Pret-a-Manger. The packaging lacked allergen labelling. Natasha therefore believed the sandwich was safe to eat, despite having a severe sesame allergy. Tragically, the baguette contained sesame seeds baked into the dough. Natasha boarded a flight to Nice. During the flight she ate the baguette and suffered a fatal anaphylactic reaction. She died before the plane landed.
This tragic incident drew attention to a legal loophole in UK law. Food regulations allowed pre-packaged food to be sold without allergen labelling. Natasha’s Law was created to close this gap and prevent similar deaths.
Natasha's Law Food Allergen Labelling - What Legal Changes Are Required?
Natasha’s law amended the UK food labelling law. As a food business, you must now clearly label food classed as prepacked for direct sale (or PPDS). Are you wondering what PPDS food means? We discuss this in the next section.
Need A Quick Summary Of Natasha's Law?
Natasha’s Law Food Allergen Labelling - What is PPDS Food?
So what does PPDS food mean? It means food that is:
• Prepared and put into packaging. This could be either a bag, a box, a jar or a sealed cup or glass.
• Pre-packed ahead of time before being offered for sale to the consumer.
• Fully or partly enclosed by the packaging. The packaging cannot be altered without opening or changing the packaging.
• For ‘Direct Sale’ from the premises on which it is made.
Confused? Let’s go over a few examples to make things clearer for you.
Examples of PPDS Food under Natasha's Law
Let’s look at some examples of PPDS food. By going through these examples you may be able to identify PPDS food within your own business.
Some common examples include:
• Sandwiches/cakes placed into packaging by a food business before the customer selects or orders the food.
• Pre-packaged takeaway meals placed into sealed packaging before being ordered (e.g. a burger held in its packaging under a hot lamp).
• Foods that are pre-packaged on site ready for sale (e.g. pizza, salad pots, rotisserie chicken).
• Meat products prepared by a butcher which are prepacked to be sold on the same premises (e.g. burgers, sausages, spareribs).
• Samples of food that have been pre-packed on site (e.g. cookies) then given to customers for free (like a promotion).
• Foods pre-packed by a food business and then sold at a market stall or mobile unit.
Now let’s consider what is not PPDS food.
What types of food are not categorised as PPDS Food under Natasha's Law?
Food that does not come under the category of PPDS food under Natasha’s Law is listed below. Examples include:
• Food that is not packed at all – it is sold loose (e.g. food from a salad bar, or Deli Counter).
• Food that is prepared to order and served immediately (e.g. plated food).
• Food that is packaged after it is ordered and sold (e.g. takeaway food). Information must be available at the time the order is taken. And at delivery (e.g. takeaway food should display what allergens are in the food by use of a sticker).
• An open bag or box is not PPDS food (but twist the corners of a paper bag and it becomes PPDS). If the bag is open, allergen information must be available but full labelling is not required.
• A cardboard sleeve around a baguette that is open at both ends is not PPDS food. Neither is a hot dog served on a cardboard tray PPDS food.
• Food that is packed by Business A and sold to Business B is not PPDS food. This is pre-packaged food. However, if pre-packaged food (e.g. a tray of Baklava) is bought by Business A then re-packaged by Business B, this would be PPDS food.
• Food bought via Distance Selling is not PPDS food.
• Food that is sold from different premises by you (e.g. a stall or a mobile vehicle) is not PPDS food.
So lets’ be clear. Where food that is not classed as PPDS, full allergen labelling is not required. However, allergen information must still be communicated to the consumer (either orally or in writing).
Natasha’s Law Food Allergen Labelling & Distance Selling
Food sold through the internet or phone (e.g. from a menu or flyer) does not need to be fully labelled. But allergen information must still be communicated to the consumer. This must take place at the start of the transaction. And at the point of delivery of the food.
Natasha’s Law - How to Determine Which Foods Require PPDS Labelling?
PPDS food can be a bit confusing at first.
To make things a bit easier, the Food Standards Agency (FSA) have created a Flow Chart. Take a look at the flow chart below. Use it to decide which foods in your business are PPDS foods. These foods will require full ingredient labelling under Natasha’s Law.
Geographical Areas That Must Comply With Natasha’s Law
So which areas must comply with Natasha’s Law? Well, it applies throughout the whole of the UK. This means England, Scotland, Wales, and Northern Ireland.
How Many People Are Severely Allergic/Intolerant To Food Allergens?
A new study from the Food Standards Agency (FSA) found that approximately 6% of the UK population (2.4 million people) might have a clinically confirmed allergy to some food ingredients. Cooperation is therefore key. Your business must cooperate with allergy intolerant customers. And those customers must cooperate with you. This is critical if we are to keep allergy sufferers safe.
14 Major Allergens To Be Declared On PPDS Food Labelling
If any of the following 14 allergens are present in any PPDS food you sell, your business must declare them on the food label:
• Celery
• Cereals containing gluten
• Crustaceans
• Eggs
• Fish
• Lupin
• Milk
• Molluscs
• Mustard
• Nuts
• Peanuts
• Sesame seeds
• Soya
• Sulphur dioxide (sulphites)
It is important to remember that customers may be intolerant to foods not included on the list. Examples include strawberries, or tomatoes. You still need to keep those customers safe, even if the allergen is not on the declared list.
What Information Must Be Included On PPDS Food Labelling?
Under Natasha’s Law, PPDS food labels must include:
• The legal name of the food, or a recognised customary name in the absence of a legal name.
• The full ingredients list in descending order by weight.
• The 14 listed allergens emphasised in the ingredients list.
• The word ‘ingredients’ as a title before the ingredients list.
How Must Allergens Be Emphasised On PPDS Food Labelling?
If any of the 14 allergens are contained within the food, you must follow this rule. Allergens must be clearly emphasised within the ingredients label. Use either bold font, CAPITAL LETTERS, a contrasting colour or underline the allergen.
"May Contain" Warnings on PPSD Food Labelling
Precautionary allergen labelling (PAL) such as “may contain” statements remain voluntary. They are not a legal requirement. However ‘may contain’ statements:
• Should only be used when there’s a genuine risk of cross-contamination.
• Can be labelled like this, either as “may contain [XXX]”. Or you could use “not suitable for consumers with [XXX] allergy”.
• Must not be used as a blanket protection, without proper risk assessment. It may be considered misleading.
Natasha’s Law Food Allergen Labelling - Compliance Checklist
To ensure your business meets the requirements of Natasha’s Law, use a simple checklist to:
1. Identify which of your products fall under the PPDS category
2. Establish a system to track accurate ingredient information
3. Create compliant food labels to identify ingredients and food allergens
4. Train staff on allergen awareness and the new labelling requirements
5. Implement cross-contamination controls in food preparation areas
6. Regularly audit your ingredients and suppliers to maintain accuracy
Natasha's Law Food Allergen Labelling - Penalties for Non-Compliance
Failing to comply with Natasha’s Law can result in:
• Fines and legal action from local authorities.
• Serious damage to your business’s reputation.
• Loss of customer trust.
• Potential business closure for severe violations.
• Serious risk to the health and safety of your customers.
Natasha’s Law Food Allergen Labelling - Resources For Compliance
Several resources are available to help your business meet the requirements of Natasha’s Law:
• The Food Standards Agency offers free food allergy/intolerance training. The course is online with a certificate upon completion.
• Natasha’s Foundation provides guidance and support.
• Local authorities can provide assistance and inspections.
• Food safety consultants can audit your processes and offer tailored advice and training.
Conclusion
Natasha’s Law is responsible for the new food allergen labelling requirements. It represents a vital step in protecting people with food allergies and food intolerance. Compliance is not just a legal obligation. Your business has a moral responsibility to comply. By complying with Natasha’s Law, your business is demonstrating its commitment to customer safety.
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