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Natasha’s Law: What Every Food Business Must Know About Allergen Labelling

1 May 20255 min readCarren Amoli, BSc (Hons), RSPH Registered
Natasha’s Law: What Every Food Business Must Know About Allergen Labelling — Kitchen Tonic food safety blog

What Is Natasha’s Law?

Natasha’s Law, formally known as the Food Information (Amendment) (England) Regulations 2019, came into force on 1 October 2021. It was introduced following the tragic death of Natasha Ednan-Laperouse, who died from an allergic reaction after eating a baguette that did not have its allergens labelled. The law requires that all food that is prepacked for direct sale (PPDS) must carry a label with the food name and a full ingredients list, with the 14 declarable allergens clearly emphasised.

What Is PPDS?

Prepacked for direct sale (PPDS) refers to food that is packaged at the same premises from which it is sold, before the customer selects or orders it. Common examples include:

  • Sandwiches wrapped and placed in a display cabinet
  • Salads in sealed containers ready for customers to pick up
  • Cakes, pastries, or bread that are individually wrapped before display
  • Burgers, pizza slices, or other hot food that is packaged before the customer orders

PPDS does not include food made to order (such as a sandwich made after the customer requests it) or non-prepacked food sold loose (such as items served on a plate or from a buffet).

What the Law Requires

Every PPDS item must carry a label that includes:

  • The name of the food (e.g. "Chicken and Avocado Sandwich")
  • A full ingredients list with any of the 14 declarable allergens clearly emphasised (typically in bold, italics, or uppercase)

The 14 Declarable Allergens

The following allergens must always be declared and emphasised on labels:

  • Celery
  • Cereals containing gluten (wheat, rye, barley, oats)
  • Crustaceans (prawns, crab, lobster)
  • Eggs
  • Fish
  • Lupin
  • Milk
  • Molluscs (mussels, oysters, squid)
  • Mustard
  • Nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts)
  • Peanuts
  • Sesame
  • Soya
  • Sulphur dioxide and sulphites (at levels above 10mg/kg or 10mg/litre)

How to Create Compliant Labels

Creating compliant labels involves several steps:

  • List every ingredient in your recipe, including sub-ingredients (e.g. if you use mayonnaise, list its individual ingredients)
  • List ingredients in descending order of weight at the time of preparation
  • Emphasise allergens using bold, italics, underlining, or a contrasting colour
  • Include the food name on the label
  • Review labels whenever you change a recipe or supplier

Common Mistakes

  • Only listing "main" allergens and missing sub-ingredients (e.g. soya lecithin in chocolate)
  • Using "may contain" statements instead of proper allergen labelling (these do not satisfy Natasha’s Law requirements)
  • Failing to update labels when recipes or suppliers change
  • Not emphasising allergens clearly enough within the ingredients list

Non-Prepacked Food Requirements

For non-prepacked food (items sold loose or made to order), you must still provide allergen information. This can be done verbally, but you must have a system in place and direct customers to where they can find the information. Best practice is to display allergen information on menus, menu boards, or in a separate allergen folder. Staff must be trained to provide accurate allergen information upon request.

Enforcement

Natasha’s Law is enforced by local authority Environmental Health Officers. Non-compliance can result in improvement notices, fines, and prosecution. More importantly, incorrect allergen labelling puts customers’ lives at risk. Our food safety consulting service can help you establish robust allergen management systems. Download our free allergen management checklist to get started.

Frequently Asked Questions

Does Natasha’s Law apply to food made to order?

No. Natasha’s Law specifically applies to food that is prepacked for direct sale (PPDS). Food made to order or served loose is covered by separate allergen information requirements, which require you to provide allergen information upon request, either verbally or in writing.

Can I use a "may contain" warning instead of full labelling?

"May contain" warnings (precautionary allergen labelling) are not a substitute for the full ingredients list required by Natasha’s Law. You may use "may contain" in addition to the ingredients list where there is a genuine risk of cross-contamination, but only after taking all reasonable steps to prevent it.

Does the law apply in Scotland?

Scotland, Wales, and Northern Ireland have all introduced equivalent legislation. The requirements are essentially the same across the UK. Food Standards Scotland provides guidance specific to Scottish food businesses.

Written by Carren Amoli, BSc (Hons), RSPH Registered