What Does Natasha's Law Require? A Plain-English Guide
Natasha's Law requires every food business that sells pre-packed for direct sale (PPDS) food to attach a label showing the product name, a complete ingredients list in descending weight order, and all 14 major allergens emphasised within that list. This guide explains exactly what that means in practice — and what it does not require, which is often just as important.
The legal basis: Food Information (Amendment) Regulations 2019
Natasha's Law is the common name for amendments made to UK food labelling law through The Food Information (Amendment) (England) Regulations 2019, with equivalent instruments for Wales, Scotland and Northern Ireland. These regulations amended retained EU law — specifically Regulation (EU) No 1169/2011 on food information to consumers — to create a new labelling requirement for pre-packed for direct sale (PPDS) food.
The regulations came into force on 1 October 2021, following a two-year transition period that was announced after the inquest into the death of Natasha Ednan-Laperouse in 2018. Natasha died in 2016 after eating a Pret a Manger baguette containing sesame seeds that were not declared on the packaging. The inquest concluded that she had no way of knowing the product contained sesame, because the pre-2021 rules only required food businesses to list allergens on packaging if they were added as a distinct ingredient — not if they were embedded within a compound ingredient.
The 2021 law closed that gap completely. Every ingredient in a PPDS product must now be declared, and every one of the 14 major allergens must be emphasised within the ingredients list — regardless of how they arrive in the recipe or at what concentration they are present. There are no exemptions for small businesses, home bakers, market stall operators or cottage food producers.
For a comprehensive overview of who the law applies to and how it is enforced, see our complete Natasha's Law guide.
The three things every PPDS label must include
The law is precise. A compliant Natasha's Law label must contain exactly three elements. Nothing more is required, but nothing less is acceptable.
1. The name of the food
Every PPDS label must display the name of the food — a clear, accurate description of what the product is. This does not need to be a legal or technical name, but it must not mislead the consumer. "Lemon and almond tart" is an acceptable name. "Pastry" or "baked goods" for the same product would not be acceptable because they are not sufficiently descriptive.
If the product has a customary name that consumers would recognise — such as "Victoria sponge", "baklava" or "pain au chocolat" — that name is perfectly acceptable. If there is no established customary name, you should use a descriptive name that gives the buyer a clear idea of what they are purchasing.
Where the product name might suggest that an allergen is absent when it is in fact present, the FSA recommends making this clear. For example, a "coconut milk ice cream" labelled only with that name might mislead a dairy-allergic customer into assuming it is milk-free — if it happens to contain a milk-based emulsifier, the full ingredients list would reveal that, but a prominent allergen summary in the name or tagline would add clarity. This is a best-practice recommendation rather than a strict legal requirement, but it reflects the spirit of the legislation.
2. A full ingredients list
The PPDS label must carry a complete list of all ingredients, presented in descending order by weight as they were at the time of manufacture. The list must be preceded by the word "Ingredients:" (or an equivalent heading). No ingredient may be omitted, however small its contribution to the recipe — water, salt, a pinch of spice, a flavouring, a colouring, an emulsifier, a preservative. Everything goes in.
The weight used for ordering is the weight at manufacture — meaning the raw ingredient weight as it is added to the recipe, before cooking. This matters because ingredients change weight during cooking. Water evaporates, which would move it down the list significantly if the cooked weight were used instead. Fat renders out of meat. Eggs change in volume when beaten. The law requires you to use the weight at the point of addition, not the finished weight.
If two ingredients are present in the same quantity, they may be listed in any order relative to each other. Where an ingredient makes up less than 2% of the finished product, you may list those minor ingredients in any order after all the major ingredients — provided you clearly indicate that the remaining items are present in amounts below 2%.
3. Allergens emphasised within the ingredients list
Any of the 14 major allergens that appear in the recipe — directly or as a component of a compound ingredient — must be emphasised within the ingredients list so that they stand out clearly from the surrounding text. The emphasis must be applied within the list itself. A separate "Contains:" box at the bottom of the label does not satisfy this requirement.
The most common and recommended method of emphasis is bold text. Bold is visually clear, easy to reproduce on any printer, and unambiguous to consumers. However, the law also permits emphasis using a different font, a different colour, or capitalisation — provided the allergen text is clearly distinguishable from the non-allergen text. Italics alone are not recommended because they do not create sufficient visual contrast. Underlining is also accepted but less common.
The emphasis must be applied every time an allergen appears in the list — not just on its first mention. If milk appears in butter and again in cream within the same recipe, both instances must be emboldened. If wheat appears in flour and again as a component of the baking powder's starch, both appearances must be emphasised.
What counts as "emphasis" — FSA guidance
The Food Standards Agency has published detailed guidance on what constitutes adequate allergen emphasis. The key principle is that the allergen name must be visually distinct from the rest of the ingredients text. The guidance does not prescribe a single method; it allows businesses to choose an approach that suits their label format and printing capabilities, provided the result is clear to a consumer reading the label.
In practice, the FSA recommends bold text as the simplest and most reliable option. Bold is universally supported across label printing software, thermal printers and standard office printers. It creates a clear visual contrast without requiring colour printing, which many small businesses do not have access to.
If you choose to use colour, the allergen name must be a clearly different colour from the surrounding ingredient text — and that colour must be legible against the label background. Red allergen text on a red background label, or yellow allergen text on a white background, would not meet the legibility standard. The FSA guidance does not specify which colour to use, only that the contrast must be clear.
Capitalisation (ALL CAPS for allergen names) is permitted but creates legibility issues in long ingredients lists. If your ingredients list contains allergens that are long words — CRUSTACEANS, SULPHUR DIOXIDE — capitalisation can make the list harder to read overall, which could undermine the purpose of the emphasis. Bold is strongly preferred.
There is no minimum font size prescribed in law for PPDS labels, but the overall label must be legible. If a local authority officer determines that the text is too small to read in normal use, they can take enforcement action on legibility grounds. The FSA suggests that below 6pt for body text is generally considered unacceptably small, and that 8pt or above is a reasonable practical minimum for ingredient list text.
The ingredients list rules in detail
Descending weight order
All ingredients must be listed with the heaviest first and the lightest last, using their weight at the time of manufacture. This gives consumers a sense of proportions — they can see at a glance whether the product is mostly flour and sugar, or mostly almonds and butter. For PPDS products, you are responsible for knowing and recording the weight of each ingredient used in your recipe, which means accurate recipe records are essential.
Compound ingredients
A compound ingredient is any ingredient that is itself made up of multiple components. Bought-in pastry, stock cubes, spice blends, chocolate chips, cream cheese, flavoured yoghurt, salad dressings and pre-made sauces are all compound ingredients. You cannot simply list them by their commercial name without declaring their contents.
You have two options for handling compound ingredients. First, you can break down the compound ingredient into its individual sub-components and insert them into your main ingredients list by weight alongside all your other direct ingredients. Second — and more commonly — you can name the compound ingredient and then list its sub-components in parentheses immediately after. For example: "Shortcrust pastry (wheat flour, Butter (milk), Salt, Water)". All allergens within the sub-components must still be emphasised.
There is one exception to the compound ingredient rule: if a compound ingredient makes up less than 2% of the finished product and does not contain any of the 14 allergens, you may list it by name without declaring its components. However, if it contains an allergen — even at less than 2% of the total — you must still declare and emphasise that allergen.
Water and alcohol rules
Water added during manufacture must be included in the ingredients list and ordered by its weight at the time of addition. However, water that is lost during cooking — through evaporation — does not need to be included if the finished product contains less water than was added. If you reconstitute a dried ingredient with water (e.g. soaking dried fruit), only the water retained in the finished product needs to be counted.
Alcohol follows the same rules as any other ingredient: if ethanol or an alcoholic ingredient (wine, spirits, beer, rum) is added to a recipe, it must be declared and ordered by weight. There is no threshold below which alcohol can be omitted. This is particularly relevant for confectionery (rum truffles, brandy cakes), savoury items with wine or sherry in the recipe, and preserves made with alcohol.
What Natasha's Law does NOT require
There is significant confusion among food businesses about what Natasha's Law actually demands. Many businesses over-comply — adding information that is not required — or assume that certain standard label elements are mandatory when they are not. Here are the most common misconceptions.
Nutritional table
Natasha's Law does not require a nutritional declaration on a PPDS label. There is no legal obligation to include calories, fat, saturated fat, carbohydrates, sugars, protein or salt per 100g or per portion. A nutritional table is required on pre-packed food produced by manufacturers for supply to retailers — but PPDS food is specifically exempt from this requirement. Some businesses include nutritional information voluntarily, which is perfectly acceptable, but it is not compulsory.
Calorie count
Similarly, there is no requirement to display a calorie count on PPDS food. Although the UK government introduced mandatory calorie labelling for large restaurants and cafés (those with 250 or more employees) in April 2022, this applies to food sold for immediate consumption — not to PPDS food in the Natasha's Law sense.
Country of origin
Country of origin labelling for PPDS food is not required by Natasha's Law or by the general PPDS labelling framework. Country of origin is required for certain pre-packed products (beef, pork, lamb, certain honey and olive oil categories), but these are separate product-specific rules that apply to pre-packed manufactured food. For most PPDS products from small food businesses — cakes, sandwiches, ready meals — country of origin labelling is voluntary.
Lot number or batch code
Lot numbers and batch codes are required on pre-packed food for traceability in the event of a recall. For PPDS food, formal lot number labelling is not a legal requirement, though many businesses use batch references for their own quality management purposes, which is good practice. You should be able to trace any ingredient back to its supplier, but this information does not need to appear on the consumer label.
The 14 allergens you must declare
The following table lists all 14 major allergens covered by UK food law, the most common foods in which each is found, and the key distinction between an ingredient that contains an allergen (which must be declared) and a may contain advisory (which addresses cross-contamination risk and is voluntary).
The key distinction between "contains" and "may contain" is this: "contains" refers to an allergen that is actually in the recipe as a deliberate ingredient. "May contain" is a voluntary advisory statement used to warn customers of the risk of unintentional cross-contamination during production. You are legally required to declare all "contains" allergens. "May contain" statements are voluntary — there is no legal obligation to use them, but if you choose to, they must be accurate and should not be used as a catch-all substitute for proper cross-contamination controls. See our allergen management guide for more on cross-contamination controls.
Special cases
Homemade products
There is no exemption for homemade food. If you make food at home and sell it pre-packed — at markets, online, to friends, via social media — Natasha's Law applies to you in exactly the same way as it applies to a commercial bakery. The law does not recognise "homemade" as a category with reduced obligations. If your product is packaged before the customer receives it, it needs a compliant label. See the FSA's guidance on home food businesses for more detail on your obligations as a home food producer.
Bulk orders and catering supplies
If you produce PPDS food for direct sale to end consumers in bulk — for example, a meal prep business that delivers sealed individual portions — each individual portion must carry a compliant label. If you are supplying food to another food business (not to the end consumer directly), different business-to-business food information rules may apply instead of the PPDS rules. However, if the end consumer is the person buying directly from you, PPDS rules apply regardless of the quantity ordered.
Multiple-serving packs
For products sold as a multiple-serving pack — a box of four brownies, a tray of pastries — the label must appear on the outer packaging. If individual items within the pack are separately wrapped, those individual wrappers do not need to carry the full label provided the outer packaging does. However, if the individual items are sold or distributed separately at any point, each individual item must carry its own compliant label.
What the FSA and local authorities check for
Environmental health officers (EHOs) from your local authority are responsible for enforcing food labelling law. They may visit your premises for a scheduled inspection or in response to a complaint. When checking for Natasha's Law compliance, they typically look for:
- Whether allergens are emphasised within the ingredients list rather than in a separate declaration
- Whether the ingredients list is complete — including sub-ingredients of compound ingredients
- Whether the ingredient order is genuinely descending by weight
- Whether labels are current — i.e., matching the actual recipes being used
- Whether there is a documented system for updating labels when recipes change
- Whether staff understand the allergen management process
EHOs are not just looking at the label on the product — they are looking at your overall allergen management system. A compliant label on the wrong product (because the recipe changed and the label was not updated) is as serious a breach as having no label at all. The FSA also emphasises that businesses should be able to demonstrate a documented, systematic approach to allergen management, not just show that the current labels look correct.
How to create a compliant label: manual vs software
There are two fundamentally different approaches to generating Natasha's Law compliant labels: doing it manually using documents and spreadsheets, or using purpose-built software that automates the process from your recipe data.
The manual approach involves maintaining a spreadsheet of recipes with all ingredients and their weights, separately identifying allergens using a checklist, and then producing a label using a word processor or design tool such as Word, Google Docs or Canva. This works for a small, stable product range, but it has a critical structural weakness: the label and the recipe exist as separate documents. Any time you change a recipe, you must also remember to update the label — and that manual link can fail.
Purpose-built software such as FoodCore's Natasha's Law labelling tool generates labels directly from recipe data. When you build or update a recipe in the system, the allergen information is calculated automatically from the ingredient records, the ingredients list is generated in the correct weight order, allergens are emphasised in bold throughout the list, and a print-ready label is produced. The label is always a live reflection of the current recipe — there is no separate document to maintain and no risk of version mismatch.
For businesses managing more than a handful of products, or with any recipe rotation or seasonal variation, the software approach is strongly recommended. The food labelling software and allergen matrix tool together give you a complete allergen management system rather than a collection of static documents.
Frequently asked questions
Does Natasha's Law require a nutritional table?
No. Natasha's Law does not require a nutritional declaration on a PPDS label. You only need the product name and a full ingredients list with allergens emphasised in bold. Nutritional labelling is required on pre-packed manufactured food, but PPDS food sold direct to consumers at the same premises is exempt from the nutrition declaration requirement under current UK regulations. You may include nutritional information voluntarily, but it is not legally required.
What font size must allergens be on a Natasha's Law label?
There is no minimum font size specified in law for PPDS labels. However, the label must be legible. The FSA recommends that allergens are clearly distinguishable from the rest of the text using bold, colour or a different typeface. In practice, anything smaller than 6pt becomes very difficult to read and risks being considered non-compliant on legibility grounds. Most businesses use 8–10pt for the ingredients list text, which is readable on a standard label size.
Does Natasha's Law apply to food sold online?
Yes, in many cases. If you prepare food, pack it before the customer orders or collects it, and sell it online for click-and-collect or delivery from the same premises where it is made, those products are PPDS and must carry compliant Natasha's Law labels. If you are a manufacturer dispatching pre-packed food from a separate production facility for sale to retailers or consumers via a third-party platform, a fuller set of pre-packed food labelling rules applies instead.
What if I accidentally miss an allergen on a label?
Accidentally missing an allergen is a breach of the Food Information Regulations and can result in enforcement action from your local authority, including an improvement notice, a fine or prosecution. If a customer suffers an allergic reaction due to an undeclared allergen, you may also face civil liability. The best protection is a system that automatically derives allergen information from your recipe data rather than relying on manual checks — such as FoodCore's label tool.
Does Natasha's Law apply to Northern Ireland?
Yes. Natasha's Law applies across England, Wales, Scotland and Northern Ireland. In Northern Ireland the legislation is The Food Information (Amendment) Regulations (Northern Ireland) 2020, which came into force on the same date — 1 October 2021 — and sets out identical requirements to the England, Wales and Scotland regulations. All PPDS food businesses in Northern Ireland must comply in exactly the same way.
Can I use a sticker to add the label to packaging?
Yes, a sticker label is acceptable provided it is permanently attached to or on the packaging so it cannot become separated from the product before the customer purchases it. A sticker that can easily fall off, or that is placed under the product inside a bag, may be considered non-compliant in practice even if it technically contains the right information. Thermal-transfer or direct-print labels affixed directly to packaging are the most secure approach and are standard in commercial food production.
Further reading
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