Natasha's Law - Food Labelling

Natasha’s Law (PPDS) & FSA 2025 Allergen Guidance for the Out-of-Home Sector

💡 This blog belongs to the Infinitas Food Safety Help Centre – your go-to guide for turning complex food safety rules into simple, workable steps.

Natasha’s Law requires written allergen labelling on certain foods (called PPDS foods). Introduced in October 2021 after the tragic death of Natasha Ednan-Laperouse, it means food businesses must provide a full ingredients list—with allergens highlighted—on prepacked foods for direct sale.

In March 2025, the Food Standards Agency (FSA) updated its guidance, encouraging the out-of-home sector to provide written allergen information for foods that are not pre-packed (e.g. non-PPDS or loose foods).

These steps are vital to protect people with allergies and intolerances, as even tiny traces can trigger severe reactions. In this post, we break down what Natasha’s Law means, the latest FSA guidance, and what you need to do to stay compliant in 2025.

Table of Contents

What is Natasha's Law?

Why Was Natasha's Law Introduced?

In 2016 Natasha ate a baguette from Pret-a-Manger that contained undeclared sesame seeds and died.  Her death highlighted a legal loophole. Natasha’s Law was created to close that gap and prevent similar deaths.  By improving food labelling, Natasha’s law aims to allow people who sufferer from food allergies to make safer, informed food choices. 

Natasha's Law Requirements

Natasha’s law amended the UK food labelling requirements.  Now, caterers, retailers and schools must clearly label food classed as prepacked for direct sale (also know as PPDS).  

Schools face unique challenges in managing food allergies. If you work in a school, check out our post on managing allergies in schools for practical advice.

PPDS foods are explained below – but first let’s go over the new allergen guidance.

New FSA Allergen Guidance (released March 2025) for Non-PPDS Foods

In March 2025, the Food Standards Agency updated their allergen guidance to encourage the out-of-home sector to provide written allergen information for non-prepacked foods.  These are the foods that were not covered by Natasha’s Law.  The new guidance includes:
  • Provision of written, easy to find allergen information on menus, food labels, or allergen charts, so that customers can access it without having to ask. For example, businesses may display a QR code that links to the written allergen information online.
  • Conversations between staff and customers to clarify allergen risks and build trust.
  • Regular checks by businesses to update allergen information including allergen charts regularly.
  • Training for staff to understand the severity of food allergies and the importance of giving customers accurate allergen information.
  • Having a system in place to ensure that allergen requirements are passed on to the kitchen by servers and that allergen requests are acted upon.
Download the updated FSA allergen guidance for non-prepacked foods here.  It applies to food businesses in England, Wales, and Northern Ireland – but not Scotland.

New FSA Allergen Guidance & Owen's Law

In 2017, Owen Carey lost his life after suffering a severe allergic reaction to a chicken burger that contained buttermilk. Although Owen had made his allergies clear to staff, he wasn’t told about the dairy in his meal. The coroner found that this tragic incident was caused by human error and a lack of clear allergen information.

Following Owen’s death, his family have pushed for new laws requiring clearer written allergen details on menus and for staff to ask every customer about allergies. The new Food Standards Agency (FSA) guidance supports making allergen information more consistent for food that isn’t prepacked. This new guidance has been introduced while “Owen’s Law” is still under consideration.

What Does Out-Of-Home Sector Include?

The out-of-home sector includes retailers and caterers in the non-prepacked food sector, such as coffee shops, cafés, restaurants, fast food outlets, delis, butchers, bakeries and market stalls.  And any business that provides allergen information to consumers in person and digitally/online.  The new FSA allergen guidance is relevant to businesses of all sizes, including small and micro businesses.

What Does PPDS Food Mean?

Under Natasha’s Law, PPDS food means food that is prepacked for direct sale.   Specifically, this means food that is:

🔹 Prepared and put into packaging.  

🔹 Pre-packed ahead of time before being offered for sale to the consumer (customer or pupil).

🔹Fully or partly enclosed by the packaging, and the packaging cannot be altered without opening or changing the packaging.

🔹 For ‘Direct Sale’ from the premises on which it is made.

Let’s go over some examples to make things clearer.

What Are Common Examples of PPDS Food?

By going through some examples you may be able to identify PPDS foods within your own organisation.  PPDS foods include:

  • Sandwiches/cakes placed into packaging by a food business on the premises before it is selected or someone places their order.
  • Pre-cut cake wrapped in cling-film ready for selection or purchase.
  • Pre-packaged takeaway meals in sealed packaging before an order has been taken (e.g. burger kept hot under a hot lamp).
  • Foods pre-packaged for sale on site (e.g. pizza, salad pots, rotisserie chicken).
  • Meat products prepared by a butcher, and pre-packaged for sale on the same premises (e.g. burgers, sausages, spareribs) before putting on display.
  • Food samples pre-packed on site (e.g. cookies) given to customers for free (as a promotion).
  • Foods pre-packaged for an event and sold at a fete, market stall or mobile unit.

What Are Common Examples of Non-PPDS Food?

 Non-PPDS foods do not come under Natasha’s Law but they do come under the new allergen guidance for the out-of-home sector (restaurants, market stalls, delis, takeaways).

Foods that are non-PPDS include:

• Food that is not packed at all – it is sold loose (e.g. food from a salad bar, butcher’s counter, deli, takeaway or fishmonger).  Loose food will be put into a bag or a box at the point of sale.

• Food that is prepared to order and served immediately (e.g. plated food at a restaurant or cafe).

• 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 under Natasha’s Law 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 become PPDS food.

• Food that is sold from different premises by you (e.g. a stall or a mobile vehicle) is not classed as PPDS food.

There is another important type of food that does not come under Natasha’s Law and that’s distance selling.

Natasha’s Law & Distance Selling

Distance selling includes internet and telephone orders.  So food sold through the internet or phone (e.g. through a menu or flyer) does not need to be fully labelled under Natasha’s Law. Because it does not come under the definition of PPDS food.  But it is included in the new FSA allergen information guidance (released March 2025). One way of achieving compliance with the guidance is by directing customers to your website where the allergen chart can be found online.  This is something that we always advised our clients to do. 

Allergen information must still be communicated to the consumer.  It must take place:

  • at the start of the transaction (when the order is take over the phone), and
  • at the point of delivery of the food. 

Which Foods Require PPDS Labelling Under Natasha's Law?

Deciding which foods require PPDS labelling can seem confusing.  To make things easier you could use the Food Standards Agency (FSA) Flow Chart.  It will help you identify which foods are PPDS, and which foods are not.

Remember – once you have identified which foods are PPDS foods, these will require full ingredient labelling under Natasha’s Law.

Flow Chart - How To Determine Which Foods Require PPDS Labelling

Where Is Natasha’s Law Applicable?

Natasha’s Law applies to food business operators throughout the whole of the UK. This means England, Scotland, Wales, and Northern Ireland.

How Many People Suffer From Food Allergens?

A new study from the Food Standards Agency (FSA) estimates that approximately  6% of the UK population (2.4 million people) might have a clinically confirmed allergy to some food ingredients.  

Cooperation is key.  Organisations selling or serving food must give allergy sufferers enough information to make informed choices about food they buy or eat.  And people with a food allergy must cooperate with you.  This dual responsibility is critical if we are to keep allergy sufferers safe.

What Are The Main 14 Allergens?

If any of the following 14 allergens are present in any PPDS food you sell or serve, your organisation must declare them on the food label.

It is important to remember that there are other known allergens, not included on the list. Examples include strawberries, or tomatoes.  You still need to communicate with people about allergens in food, even if you don’t need to comply with the PPDS labelling requirement.

What Must PPDS Labels Include?

Under Natasha’s Law, PPDS food labels must include:

🔹 The legal name of the food, or a recognised customary 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 To Emphasise Allergens On PPDS Food Labelling?

If any of the 14 allergens are contained in food you sell or serve, the allergens must be clearly emphasised within the ingredients label.  The guidance recommends you either use bold font, CAPITAL LETTERS, a contrasting colour or underline the allergen.

The use of contrasting colours may not be helpful to people who suffer from colour blindness, so keep that it mind.

What Needs To Be on PPDS Label

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 is 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 a risk assessment. 

Natasha’s Law Checklist

 To ensure your business or organisation complies with the requirements of Natasha’s Law, a simple checklist will help you to:

1️⃣ Identify which products fall under the PPDS category

2️⃣ Establish a system to track accurate ingredient information

3️⃣ Create compliant food labels to highlight ingredients and food allergens

4️⃣ Train staff on allergen awareness and the new labelling requirements

5️⃣ Implement cross-contamination controls in food preparation areas

6️⃣ Regularly audit your ingredients and suppliers to maintain accuracy

Natasha's Law - Penalties for Non-Compliance

Failing to comply with Natasha’s Law can result in:

➜ Serious risk to the health and safety of any person who suffers from a food allergy (even a tiny amount of an allergen could cause death).

➜ Fines and legal action from your local authority, and/or civil action.

➜ A low food hygiene rating.

➜ Serious damage to your business’s reputation.

➜ Loss of customer trust/ loss of business.

➜ Potential business closure for severe violations.

Benedict's Law - Protecting School Children

🛑 In July 2025, Labour MP Chris Bloore introduced the Schools (Allergy Safety) Bill—also known as Benedict’s Law. It requires schools to have an allergy management policy, keep spare adrenaline auto-injectors, and train staff in allergy awareness. Although education is devolved and the Bill applies primarily to England, it highlights the wider expectation that all organisations handling food—including schools—must strengthen their allergy safeguards.

Schools face unique food safety challenges.  Yet, a recent poll found that almost 70% of teachers have never received any training in managing food allergies — a gap that Natasha’s Law and Benedict’s Law aim to close.

For practical advice and common pitfalls to avoid in schools, read our Food Hygiene in Schools (Hidden Failurespost and our recently released safety article on Managing Food Allergies in UK Schools.

Natasha’s Law FREE Resources

Several 💡 resources are available to help you meet the requirements of Natasha’s Law:

➜ The Food Standards Agency provides free online food allergy/intolerance training for food businesses. 

➜ There are free resources to explore on our Food Safety Help Centre and the Resources Page on our website.  We also provide a free Food Safety Helpline, where you can ask questions about how to implement a food allergen policy.  

➜ Natasha’s Foundation provides Allergy School offering free resources for all nurseries, primary schools and out-of-school clubs, supported by the Kings Foundation. 

➜ Want practical tips on food allergy management from the perspective of a food safety consultancy? Read our post on Managing Food Allergies in Schools.

Conclusion

Compliance with Natasha’s Law is not optional — it protects lives.  Whilst compliance with the new FSA allergen guidance is encouraged it is not yet law.  

By complying with the guidance it can help you meet your legal responsibilities in delivering allergen information to consumers. 

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