Natasha's Law: The Complete Guide for Small Food Businesses (2026)

What is Natasha's Law?

Natasha's Law is the informal name for amendments to the UK Food Information Regulations that require full ingredient and allergen labelling on all food that is pre-packed for direct sale (PPDS). It is named after Natasha Ednan-Laperouse, who died in 2016 after suffering an allergic reaction to a Pret a Manger baguette that contained sesame — an ingredient not listed on the packaging.

Before the law changed, PPDS food only needed to display the product name and a "may contain" allergen warning. Now, every PPDS product must carry a full ingredients list with allergens emphasised. The legislation came into force on 1 October 2021, giving businesses a transition period to adjust their labelling systems. There are no exemptions for small businesses, sole traders, home bakers or market stalls — if your product meets the definition of PPDS, the law applies to you without exception.

The law sits within the wider framework of Regulation (EU) No 1169/2011 on the provision of food information to consumers, which the UK retained and amended post-Brexit. The specific amendments are set out in The Food Information (Amendment) (England) Regulations 2019 and equivalent legislation for Wales and Scotland.

What is PPDS food?

Pre-packed for direct sale (PPDS) food is food that is:

• Packaged at the same place it is sold
• Offered for sale in that packaging
• Packed before the customer orders it

The "direct sale" element is important. The packaging is applied at the same business premises where the food will be sold to the end consumer — it is not transported to another site for sale elsewhere. A bakery that wraps its own cakes and sells them over the counter is PPDS. A bakery that supplies wrapped cakes to a coffee shop down the road would be producing pre-packed (not PPDS) food, which has a different and more extensive labelling requirement.

Common examples of PPDS food include:

• Sandwiches and wraps made and packaged in a café or deli
• Cakes and pastries wrapped and displayed in a bakery
• Salads and ready meals packaged in a farm shop or food hall
• Homemade products sold at a market stall, packaged in advance
• Meal prep boxes assembled and sealed before collection
• Cake shed or click-and-collect products packed before the customer arrives

Food that is not PPDS includes: food packed to order in front of the customer (e.g. a deli counter making a sandwich while you watch), food sold completely loose without packaging, and food produced and packed at one site for sale at a different site.

What does Natasha's Law require?

Every PPDS product must display the following information, on or attached to the packaging:

1. The name of the food — a clear, accurate description of what the product is (e.g. "Almond and raspberry tart", not just "Pastry")
2. A full ingredients list — all ingredients listed in descending order by weight as they were at the time of manufacture, preceded by the word "Ingredients:"
3. Allergens emphasised within the ingredients list — any of the 14 major allergens that appear in the recipe must be highlighted using a different typeface, font style (bold is most common), or colour, so they stand out clearly from the rest of the ingredients text

The emphasis must be applied within the ingredients list itself — you cannot satisfy the requirement by adding a separate "allergen box" or "contains:" statement alongside the list. The purpose of the legislation is that someone with an allergy can read through the ingredients and immediately identify every allergen present. A separate list at the bottom of the label does not achieve this because it is disconnected from the full ingredient context.

There is no minimum font size specified in law for PPDS labels, but the information must be legible. There is also no requirement for a nutritional declaration (calories, fat, protein etc.) on PPDS food — that requirement applies to pre-packed manufactured food, not PPDS.

The label must be permanently attached to or displayed on the packaging so it cannot be separated from the product before purchase. A loose sticker that can fall off, or a label placed underneath the product, does not meet the requirement in practice, even if it technically meets the letter of the law.

The 14 major allergens

UK food law requires the following 14 allergens to be declared and emphasised whenever they appear as an ingredient — including when they appear as sub-ingredients of a compound ingredient. You must emphasise them every time they appear, not just the first time. If an allergen appears in multiple ingredients (e.g. milk in both butter and cream), it should be emphasised in each instance.

A few notes on specific allergens that trip up small businesses. Cereals containing gluten means wheat, rye, barley, oats, spelt and kamut — not just wheat. You must specify which cereal is present (e.g. "wheat flour" not just "gluten"). Tree nuts must be specified by type — almonds, cashews, hazelnuts, walnuts, pecans, Brazil nuts, pistachios, macadamia nuts and Queensland nuts are all individually named allergens. Sulphur dioxide/sulphites only need to be declared when present at concentrations above 10mg/kg or 10mg/litre; below this threshold, declaration is not required. Lupin is found in some flour blends and is often overlooked by home bakers.

Who does Natasha's Law apply to?

The law applies to any food business that sells PPDS food, regardless of size. There is no minimum turnover threshold, no exemption for sole traders, and no grace period for new businesses. This includes:

• Bakeries and patisseries
• Cafés, delis and sandwich shops
• Farm shops and food halls
• Market stalls and pop-ups
• Home bakers selling online or at events
• Meal prep and food subscription businesses
• Catering companies that pre-pack food
• Cake sheds, click-and-collect home bakeries and cottage food producers
• Schools, hospitals and care homes selling or providing PPDS food

It does not apply to food that is packed to order in front of the customer (e.g. a barista making a sandwich while you wait), or to food sold loose without packaging. However, loose food and food sold to order still triggers a separate allergen information requirement under Article 44 of the Food Information Regulations — you must be able to provide allergen information verbally or in writing on request, and you must have a clear process for doing so.

How to create a compliant PPDS label — step by step

Creating a compliant Natasha's Law label is straightforward once you understand the process. The steps below apply whether you are labelling a single product or managing a full product range. Follow them in order every time you introduce a new recipe or update an existing one.

1. List every ingredient in your recipe. Start with a complete, accurate list of everything that goes into the product — including water, salt, oil and every spice or flavouring, no matter how small the quantity. Nothing can be omitted. If an ingredient contributes flavour, texture, colour or any functional purpose, it must be declared.
2. Order all ingredients by weight at the time of manufacture. Weigh each ingredient as it is added before cooking — not after. The heaviest ingredient comes first in the list. If two or more ingredients are present in equal quantities, you may list them in any order relative to each other. Note that water evaporates during cooking, which changes the proportions; you must use the weight at manufacture, not the finished product weight.
3. Identify all compound ingredients. A compound ingredient is any ingredient that is itself made up of multiple components — a bought-in sauce, a spice blend, a pre-made pastry base, a flavoured oil or a seasoning mix. Every compound ingredient in your recipe needs to be treated as a bundle of sub-ingredients.
4. List the sub-ingredients of every compound ingredient. You have two options: either break down the compound ingredient into its individual sub-ingredients and slot them into the main list by weight, or name the compound ingredient and then list its sub-ingredients in parentheses immediately after. For example: Shortcrust pastry (wheat flour, Butter (milk), Salt). Check the packaging or specification sheet of every bought-in product for its full ingredient declaration.
5. Identify every one of the 14 allergens present. Go through your full ingredient list — including all sub-ingredients — and flag every allergen. Use the official list of 14. Do not rely on memory; use a checklist and cross-reference against each ingredient systematically.
6. Apply emphasis to allergens within the ingredients list. Bold text is the most widely used method and is strongly recommended for clarity. Ensure the bold is applied consistently to the allergen name within each ingredient entry. For example: "Flour (wheat), Sugar, Butter (milk), Eggs (egg), Ground almonds (almonds), Baking powder (wheat starch, Raising agents)". The emphasis must be visually distinct — bold is most reliable across different printers and label formats.
7. Add the product name to the label. The name should clearly and accurately describe the product. Avoid generic names that could cause confusion. "Victoria sponge" is fine; "cake" is too vague if you sell multiple types. If the product contains an allergen that would not otherwise be obvious from the name, the Food Standards Agency recommends making this prominent, though the formal requirement is that it appear in the ingredients list.
8. Include date marking if applicable. While not strictly a Natasha's Law requirement, most PPDS food also requires a "use by" date (for safety-critical perishable products) or a "best before" date. Use-by dates are mandatory for microbiologically perishable products. Best-before dates are advisory but should be included on most products. Omitting date marking is a separate food labelling offence from Natasha's Law non-compliance, but both are enforced by the same environmental health officers.
9. Check sub-ingredients of all manufactured components. Pre-made pastry, bought-in chocolate, flavoured creams, stock cubes, ready-made sauces and even butter from different brands can contain different allergens. Never assume — always read the label. If a supplier changes their recipe, your label must be updated too. Build supplier specification reviews into your purchasing process.
10. Review and update your label every time the recipe changes. A label is only valid for the exact recipe it describes. If you swap an ingredient, change a supplier, alter a quantity significantly, or add a new component, the label must be updated before the product goes on sale. This includes seasonal recipe variations. Many allergen incidents occur because a product was reformulated but the label was not updated in time. Establish a formal review process — ideally linking label generation directly to your recipe records.

PPDS label examples: compliant vs non-compliant

To understand what a compliant label looks like in practice, it helps to compare a non-compliant example with a compliant one. The differences are subtle but legally significant.

The distinction matters enormously for people with life-threatening allergies. The compliant label tells a milk-allergic customer not just that milk is present, but that it comes from butter — allowing them to judge whether a dairy-free spread would make the recipe safe for them, for example. The non-compliant label provides no such context. Natasha's Law was created precisely because the absence of this detail cost Natasha Ednan-Laperouse her life.

Note that the compliant example above also shows the sub-ingredients of the baking powder in brackets. This is a compound ingredient and its components must be declared. The wheat starch within the baking powder is emphasised, even though wheat is already declared elsewhere in the list. Allergen emphasis must be applied every time an allergen appears — not just on its first mention.

Natasha's Law by business type

Natasha's Law applies broadly, but the practical questions vary significantly by business type. Here is a breakdown of how it applies to the most common types of small food business in the UK.

Home bakers

If you bake at home and sell your products — whether through Instagram, Etsy, a market stall, a cake shed, or word of mouth — Natasha's Law almost certainly applies to you. The trigger is pre-packing: if you wrap your products before the customer collects or receives them, those products are PPDS. This includes postal cake sales, click-and-collect orders that are packed before the customer arrives, and any product you bag up or box in advance of a market or event. Many home bakers are unaware of this obligation or assume that small-scale operation creates an exemption — it does not. You must attach a compliant Natasha's Law label to every pre-packed product you sell.

Cake sheds

The cake shed model — where customers collect pre-made cakes and bakes from a shed, garage or outbuilding at your home — is a growing trend in the UK, but it is firmly within the scope of Natasha's Law. Every product placed in the shed for sale must carry a compliant PPDS label before it is offered for sale. The FSA has confirmed that informal selling arrangements do not create any exemption from food labelling law. If you operate a cake shed and are not labelling your products, you are non-compliant and at risk of enforcement action.

Market stalls

Whether Natasha's Law applies at a market stall depends on how the products are presented. If you arrive at the market with products already packaged — cakes in cello bags, jars of jam, boxed brownies — those products are PPDS and must carry compliant labels. If you prepare and pack food to order at the stall (e.g. filling sandwiches to order, or wrapping a slice of cake that the customer selects from a display), those products are not PPDS. However, even for loose or made-to-order food, you must still have allergen information available on request. Having a printed allergen matrix on your stall covering all your products is good practice and helps customers with allergies make safe choices quickly.

Bakeries

For most small bakeries, the majority of products will be PPDS — breads in bags, pastries in cello wrappers, cakes in boxes. The key question for each product line is: was it packaged before the customer ordered it? If yes, it needs a Natasha's Law label. Bakeries with a wide product range face the most significant labelling burden, because every SKU needs its own label reflecting its specific recipe. The risk of label-recipe mismatch is highest in bakeries where recipes evolve seasonally or where multiple staff are involved in production. A software system that links labels directly to recipes is strongly recommended.

Caterers

Caterers typically serve food at events, which usually involves either plated meals or buffet-style service — neither of which is PPDS. However, caterers who pre-pack individual portions for delivery, who provide boxed lunches prepared in advance, or who supply wrapped items to clients' offices or events do need to comply with Natasha's Law for those specific products. If you are a caterer who delivers pre-packed individual meals, each box needs a compliant label. For catered events where food is served loose or plated, the Article 44 allergen information duty applies instead — you must be able to provide allergen information on request.

Meal prep businesses

Meal prep businesses — which prepare, portion and seal individual meals for collection or delivery — are squarely within the scope of Natasha's Law. Every sealed meal is PPDS. Each individual container must carry a label with the product name, full ingredients list (ordered by weight at manufacture) and all allergens emphasised in bold. Given that meal prep businesses typically produce a rotating menu of multiple dishes, the administrative burden of maintaining accurate labels can be significant. Automating label generation from recipe data is not just convenient — for businesses producing multiple changing dishes each week, it is practically essential for maintaining consistent compliance.

How to manage Natasha's Law compliance without specialist staff

Most small food businesses do not have a dedicated food safety or compliance manager. Compliance is typically handled by the owner, often alongside every other aspect of running the business. There are three broad approaches to managing Natasha's Law labelling, each with very different risk profiles.

Manual approach: spreadsheets and Word documents

The most common approach among small businesses is to maintain a spreadsheet of recipes and allergens, and to produce labels using Word, Google Docs or similar tools. This approach has a very low setup cost and works reasonably well for businesses with a small, stable product range. The risks, however, are significant. Labels and recipes exist as separate documents, which means they can fall out of sync when a recipe changes. A new supplier, a substituted ingredient or a seasonal variation can invalidate a label without anyone noticing. There is no automated alert when a recipe change affects an allergen. Human error in the original allergen identification — a missed sub-ingredient, an incorrectly transcribed allergen — propagates to every product produced until someone catches the mistake. For businesses producing high volumes or rotating menus, manual management is genuinely high-risk.

Design tools: Canva and similar platforms

Some businesses use Canva, Adobe Express or similar design tools to create and print labels. These tools produce professional-looking labels but have no understanding of food law, allergens or recipe logic. They are no more than a visual design tool: if you enter incorrect information, the label will look polished but will still be non-compliant. Design tools also do not link to recipe data, so every recipe change requires a manual update to the label template. The visual emphasis of allergens in bold must be applied manually, and it is easy to miss an allergen in a long ingredients list. Using Canva for label design is not inherently wrong, but it offers no compliance assurance and should be combined with a rigorous manual review process.

Purpose-built software: the case for automation

Purpose-built food business software eliminates the structural risks of the manual and design-tool approaches by linking label generation directly to recipe data. When you build or update a recipe in the software, the system automatically identifies all 14 allergens, generates the ingredients list in correct descending-weight order, applies bold emphasis to allergens throughout the list, and produces a print-ready label. When you change a recipe, the label updates immediately. There is no separate document to maintain, no risk of version mismatch, and no manual allergen identification step where a mistake can go unnoticed for weeks.

The table below compares the three approaches across the factors that matter most for compliance:

Common mistakes to avoid

The following mistakes are the most commonly identified by environmental health officers and food safety advisers during inspections of small food businesses. Many of them are easy to make, especially when you are managing labelling alongside all other aspects of a busy kitchen.

• Listing allergens separately rather than within the ingredients list. A "Contains: milk, eggs, wheat, nuts" line at the bottom of the label does not comply. Allergens must be emphasised within the full ingredients list.
• Using "may contain" as a substitute for declaring actual allergens. "May contain traces of nuts" is a cross-contamination warning, not an allergen declaration. It cannot replace the mandatory ingredients list with allergens emphasised.
• Not updating labels when recipes change. If you swap a supplier, substitute an ingredient, or alter a recipe in any way, your labels must be updated before the new recipe goes on sale. This is the single most common cause of label-allergen mismatch in small businesses.
• Forgetting compound ingredient sub-declarations. If you use a bought-in pastry, sauce, spice blend or flavouring, you must list its sub-ingredients too. Check every compound ingredient against its product specification sheet.
• Applying bold to the allergen name only, not to its appearance within ingredient names. The allergen must be emphasised in the specific context where it appears. "Ground almonds" is correct; "Ground almonds" with a separate bold "almonds" elsewhere is not.
• Missing less obvious allergens. Lupin flour in gluten-free blends, sesame in hummus or dressings, sulphites in dried fruit and wine-based sauces, and mustard in spice mixes are frequently overlooked. Cross-reference every ingredient against all 14 allergens systematically.
• Illegible or incomplete handwritten labels. Labels must be legible. Handwritten labels that are hard to read, that fade, or that do not include all required information are non-compliant. Printed labels are strongly preferred.
• Failing to review labels after changing suppliers. A supplier change can silently introduce a new allergen if the replacement product has a different formulation. Treat every supplier change as a trigger for a full recipe and label review.

Penalties for non-compliance

Local authority environmental health officers enforce Natasha's Law. They can visit your premises unannounced, inspect your labelling practices, and request to see your allergen management procedures. Penalties for non-compliance can include:

• Improvement notices — a formal notice requiring you to fix specific labelling issues within a set timeframe (typically 14 days). Failure to comply with an improvement notice is a criminal offence.
• Prosecution — under the Food Safety Act 1990 and the Food Information Regulations, prosecution can result in unlimited fines. Serious cases involving injury or death can result in custodial sentences.
• Prohibition orders — preventing you from selling specific products or operating your food business altogether until compliance is achieved.
• Emergency prohibition orders — immediate closure in cases where there is an imminent risk to public health.

Beyond legal penalties, the reputational damage from an allergen incident can be devastating for a small business. A serious allergic reaction linked to a product you sold — even if the outcome is not fatal — will attract media attention and can permanently destroy customer trust. The financial and emotional cost of a serious incident far outweighs the cost of proper compliance systems.

It is also worth noting that food business insurance policies may not cover incidents caused by non-compliance with food labelling law. If you are operating without compliant labels and a customer suffers a reaction, you may face personal liability that your insurance will not indemnify.

How FoodCore helps with Natasha's Law compliance

FoodCore is built specifically for small UK food businesses that need to manage allergen labelling without a dedicated compliance team. The system is designed around the reality of running a small food business — where the owner is also the baker, the packer, the delivery driver and the accountant — and where compliance needs to be fast, reliable and low-effort.

When you build a recipe in FoodCore, the system automatically:

• Tracks all 14 allergens across every ingredient and sub-ingredient
• Generates a full ingredients list in descending order by weight
• Highlights allergens in bold within the ingredients list, wherever they appear
• Updates labels instantly when you change a recipe
• Produces print-ready labels you can attach to packaging — formatted to standard label sizes
• Maintains an allergen matrix across your full product range, so you always know which products contain which allergens

This means you never have a separate "label file" that can fall out of sync with your recipe. The label is always a direct reflection of the current recipe. If you change a supplier and update the ingredient record, every affected recipe and label updates automatically.

Natasha's Law: frequently asked questions

Further resources

• Food Standards Agency — Natasha's Law guidance
• FSA allergen guidance for food businesses
• What is PPDS food? Full explanation with examples
• Does Natasha's Law apply to home bakers?
• Allergen management checklist for small food businesses
• How to comply with Natasha's Law in 2026