Natasha's Law in 2026: A PPDS Compliance Refresher

Why a refresher, five years on?

When the Food Information (Amendment) (England) Regulations 2019 — universally known as Natasha's Law — came into force on 1 October 2021, there was a flurry of activity. Businesses printed labels, bought guillotines and label rolls, and added an allergen column to a spreadsheet. Then, for many, the subject went quiet. The labels printed in that first month are, in some kitchens, still being reprinted from the same template today.

The problem is that a food business is not a static thing. Recipes get tweaked, a supplier changes a formulation, a cheaper flour comes in, a new flavour joins the range. Each of those small changes can quietly break a label that was perfectly compliant in 2021. Five years on, the most common compliance failures are no longer "we didn't know about the law" — they are "the label no longer matches what is in the box." This refresher is about closing that gap, and about being clear on the parts of the rules that are still widely misunderstood.

One thing to say up front: compliance is your business's legal responsibility, not a feature you can fully outsource. Tools like FoodCore can make the labelling itself faster and far harder to get wrong, but the duty to label accurately sits with you. Always check the current position against the Food Standards Agency allergen guidance, which is the authoritative source.

What is PPDS? A clear definition

Natasha's Law applies specifically to PPDS food — pre-packed for direct sale. PPDS is food that meets all of the following: it is packaged on the same premises from which it is sold, and it is put into that packaging before the customer orders or selects it. In plain terms, if the food is sitting in its packaging, ready to be picked up, before anyone asks for it — and you both made and packed it on site — it is almost certainly PPDS.

Examples of food that is PPDS:

• Sandwiches, wraps and salads boxed up in the morning and put on a chiller shelf for customers to grab
• Bakery items — cookies, brownies, loaves — bagged or boxed on site before a customer chooses one
• Deli items pre-weighed and wrapped before sale, such as a tub of olives or a pot of coleslaw made and packed in advance
• Meal-prep boxes assembled, sealed and labelled on site ready for collection

Examples of food that is not PPDS — and where different rules apply:

• Made to order at the counter. A sandwich assembled in front of the customer after they order it, or a coffee-shop toastie made to request, is not PPDS. You must still give accurate allergen information on request, and it is good practice to have it written down, but a PPDS ingredients label is not required.
• Loose, unwrapped food. Cakes on a stand sold by the slice, or bread in an open basket, are loose and not pre-packed. Allergen information must be available, but the food itself does not carry a PPDS label.
• Pre-packed for retail (not direct sale). Food you make and pack to be sold through another business — a wholesaler, a farm shop you supply, a supermarket — is not PPDS. It is "prepacked food" under the full Food Information Regulations 2014, which require a more extensive label including a name, ingredients, quantity, durability date, storage, business name and address, and more.
• Distance selling. Selling food online or by phone is treated differently again. Allergen information must be provided at two points: before the purchase is completed (for example on the website), and again at the moment of delivery (on the packaging or with the food). The detail of what is required depends on whether the item is PPDS, prepacked, or non-prepacked when it reaches the customer.

For a fuller treatment of the boundaries, see our complete guide to Natasha's Law and the more focused what Natasha's Law requires. The wider labelling framework is covered in our explainer on the Food Information Regulations 2014.

What Natasha's Law requires, exactly

For any product that is PPDS, the label must carry two things:

1. The name of the food. This is the name a customer would recognise — "Mature Cheddar & Pickle Sandwich", "Double Chocolate Brownie" — not an internal product code.
2. A full ingredients list, with every ingredient listed in descending order by weight as used in the recipe, including the sub-ingredients of any compound ingredient (so the mayonnaise in a sandwich filling brings its own egg, oil and mustard with it).

Within that ingredients list, all of the 14 major allergens must be emphasised wherever they appear, so they stand out from the surrounding text. Bold is the most common method and the one customers most readily recognise, but the law allows other forms of emphasis — a contrasting colour, capitals, underlining or a different font — provided the allergens are genuinely distinguished within the list. The 14 allergens are: celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soya, sulphur dioxide and sulphites, and tree nuts. For a deeper look at each one, see our guide to the 14 major allergens under UK law.

Is my product PPDS? A quick decision aid

The table below maps the common scenarios to whether the product is PPDS and what labelling applies. Use it as a starting point and confirm anything borderline against FSA guidance.

Common mistakes, five years on

The pattern of failures has shifted from "we didn't label" to "our labels have drifted." These are the five we see most often.

1. Outdated labels after a recipe change

This is now the single most common issue. A recipe is adjusted — a little more sugar, a new garnish, a different filling — but the printed label is never updated. The label that was accurate at launch is now wrong, and if the change added or removed an allergen, it is dangerously wrong. The same happens when a supplier reformulates a product: your "plain" ingredient might quietly gain a "may contain" change or a new sub-ingredient without you noticing.

2. Missing or inconsistent emphasis

Allergens are bolded on some labels and not others, or only the obvious ones (milk, nuts) are emphasised while the less obvious ones (mustard in a dressing, sulphites in dried fruit, soya in a lecithin) are missed. Every one of the 14 must be emphasised, every time it appears, on every PPDS label.

3. Illegible labels or the wrong ingredient order

Text printed too small to read on a tiny label, faded thermal printing, or ingredients listed alphabetically or in a "nice looking" order rather than in descending weight order. The legal requirement is descending order by weight as the ingredients went into the recipe — not whatever reads best.

4. Treating "may contain" as a substitute

A precautionary "may contain nuts" statement is about cross-contamination risk; it is voluntary and is not a substitute for the mandatory ingredients list with emphasised allergens. Some businesses lean on "may contain" and skip the full ingredients list — that is non-compliant.

5. No process for ingredient or supplier changes

Underlying all of the above is the absence of a defined process. If nobody owns the question "when this recipe or supplier changes, who updates the label and how?", labels will drift out of date by default. A reliable process — ideally one that regenerates labels automatically from a single source of recipe data — is what keeps a business compliant between inspections.

What an EHO checks for PPDS compliance

It is worth understanding that an environmental health officer is not just glancing at a single label. They are assessing whether your whole labelling system produces accurate labels reliably. On a typical inspection, expect them to look at:

• Label accuracy against the recipe. They will compare the printed label to the actual recipe and the ingredients in use. Does the ingredients list match? Is it in descending weight order? Are all 14 allergens emphasised correctly within the list?
• Allergen records. Do you hold supplier specifications and product information that back up the allergen data on your labels? Can you show where the allergen information for each ingredient came from?
• Staff training. Do the people making and packing food understand allergens, cross-contamination and how the labelling works? Allergen awareness training records are commonly requested.
• Traceability. Can you trace ingredients back to suppliers and forward to finished products, so that a problem ingredient can be tracked through your range?
• The labelling process — not just one label. Crucially, they want to see that you have a repeatable process for keeping labels accurate when recipes or suppliers change. One correct label proves little; a system that keeps every label correct is what demonstrates due diligence.

This is why an audit trail matters. Being able to show that your labels are generated from current recipe data, and that changes are logged, is strong evidence of a controlled process. Our pieces on allergen management software and the allergen matrix go further on building that system.

Keeping labels in sync when recipes change

The practical heart of staying compliant is making sure a change to a recipe cannot leave a stale label in circulation. There are broadly two ways to achieve that.

The manual way: maintain a master document for every recipe, with a strict rule that any change triggers an immediate label reprint, the old labels are destroyed, and a date-stamped record is kept. This works, but it relies entirely on discipline and a single point of human memory. When the kitchen is busy, it is exactly the step that gets skipped.

The connected way: tie your labels to one source of truth — the recipe itself — so that the label is always a direct output of the current recipe data. Change the recipe, and the label is regenerated; there is no separate document to forget to update. This is the model FoodCore uses: ingredients and allergen data live with the recipe, the label is generated from them with allergens emphasised and ingredients in weight order, and when the recipe changes the label updates so it cannot fall out of step. The audit trail then gives you the evidence an EHO is looking for.

Whichever route you choose, the principle is the same: there should be no way for a recipe to change without the label changing with it.

A short worked example

Imagine a café that boxes a "Chicken Caesar Salad" each morning for the grab-and-go fridge. That salad is PPDS. The label needs the name and a full ingredients list — including the sub-ingredients of the Caesar dressing (which typically brings egg, mustard and anchovy/fish, plus milk in the parmesan). All of those allergens must be emphasised within the list. Now the café switches to a different dressing that uses soya instead of egg. If the label is generated from recipe data, swapping the dressing ingredient updates the allergen emphasis automatically and the new label is correct on the next print. If the label is a static template, somebody has to remember to find it, edit it, reprint it and bin the old roll — and that is precisely where compliance breaks down.

Further resources

• Natasha's Law: the complete guide
• What does Natasha's Law require?
• The 14 major allergens under UK law
• The Food Information Regulations 2014 explained
• Allergen management software for UK food businesses
• Natasha's Law labelling software
• Allergen matrix software
• FSA allergen guidance for food businesses

Frequently asked questions