Natasha’s Law: what your food labels need

What Natasha’s Law is

Natasha’s Law is the everyday name for the food labelling change that came into force on 1 October 2021 across the UK. It closed a gap: food packed on the premises where it was sold used to be exempt from carrying an ingredients list, which meant a customer with an allergy had no written information to read.

The law itself is short. Food that is prepacked for direct sale — PPDS — must carry the name of the food and a full ingredients list, with allergens emphasised inside that list.

Whether it applies to you

It applies to the food, not the business. A café can have three products that need labels and two that do not, on the same counter, on the same day. The test the FSA uses:

Two conditions, both of which have to be true:

• It is in packaging — wrapped, boxed, bagged, or in a lidded pot. Food on an open tray or under a dome is not packaged.
• It was packed before the customer chose it — the sandwiches made at 8am for the lunch rush, not the one built while the customer waits.

The FSA’s own examples of food that is PPDS include sandwiches and bakery items packed on site, boxed pizzas, rotisserie chicken, salad boxes, butcher’s products, and food served in schools, care homes and hospitals. Food that is not PPDS includes hot drinks made to order, unpackaged cakes in a glass display, pizza slices served on an open tray, and chips put into packaging at the moment of ordering.

Packing somewhere else and selling at a stall still counts. The FSA’s guidance for mobile sellers and market traders covers businesses that “package food yourself at a different location” — which is most home bakers who sell at markets.

Not sure about a specific product? Work through the decision path.

What must be on the label

Three things. That is all PPDS itself requires.

The label also has to be legible and visible. The FSA puts it plainly: a customer “should not need to open the packaging to access this information”.

Emphasising allergens

The guidance permits four methods: bold type, capital letters, contrasting colours or underlining. Any one of them satisfies the requirement.

In practice, bold capitals is the safest choice. It survives a monochrome thermal printer, a photocopy, a smudge, and a customer reading in poor light. Colour alone fails all four, and fails anyone who cannot easily distinguish it.

More detail: how to emphasise allergens on a food label.

A worked example

A chocolate brownie. Four allergens, one of them inside a compound ingredient, one of them in an ingredient whose name does not mention it at all.

Three things are happening there worth copying:

• Butter is written as “Butter (MILK)”. The ingredient still has to be named — you cannot replace “butter” with “milk” — so the allergen is added to it.
• The chocolate is broken open. Its own ingredients appear in brackets, and the soya inside it is emphasised there.
• “Wheat flour” becomes “WHEAT flour”. Here the allergen is written in the name, so it is emphasised where it stands.

Four more worked examples, including a sandwich, which is almost entirely compound ingredients.

What it doesn’t require

A lot of confusion comes from mixing PPDS up with the rules for prepacked food — the sandwich in a supermarket chiller. Those need a net quantity, a date mark, and the food business operator’s name and address. PPDS does not require those.

Plenty of businesses add a date anyway, because it is useful for rotation, and some add their name because it is good practice and good marketing. That is a choice, not the law. And other rules can apply to a particular product regardless — so treat the three requirements as a floor, not a ceiling.

Five common mistakes

1. Listing allergens instead of ingredients. “Contains: milk, wheat, egg” is not an ingredients list. The allergens have to be emphasised inside the full list.
2. Flattening a compound ingredient. Writing “chocolate” and stopping. If the chocolate has its own ingredients, they belong in brackets after it.
3. Emphasising only the first mention. Every occurrence.
4. Copying an old label without re-checking. Suppliers reformulate quietly. A label is only as current as the last time somebody read the tub.
5. Using a brand name. A customer cannot look up what is in your supplier’s product. Copy the declaration from the pack.

A checklist

Before a label goes on food:

• The name of the food is one a customer would recognise
• Every ingredient is listed, including the small ones
• They run heaviest first
• Compound ingredients show their own ingredients in brackets
• Every one of the 14 allergens present is emphasised, everywhere it appears
• The text is legible on the finished pack without opening it
• The supplier declarations behind it have been read within living memory

Questions