How to Write a PPDS Label That Meets Natasha's Law Requirements
A Natasha's Law compliant PPDS label must include the food name and a full ingredient list with allergens emphasised. Here's exactly how to write one.
A Natasha's Law compliant label for PPDS food has two mandatory elements: the name of the food, and a full ingredient list with allergens emphasised. Getting both right requires attention to detail. Here's how to write a compliant label from scratch.
The Food Name
The label must carry the name of the food. This must be a specific name (e.g. "Chicken and mushroom pie") rather than a generic description ("savoury pastry"). If the food is regulated — such as a product with a legally defined name like "mayonnaise" — the legal name must be used. Trade names or brand names alone are not sufficient.
The Ingredient List
Ingredients must be listed in descending order of weight (heaviest ingredient first, as a proportion of the finished product). Each ingredient must be listed by its common name. For compound ingredients (ingredients that are themselves made from multiple components), the sub-ingredients must be listed in brackets: "pastry (wheat flour, butter, water, salt)".
Emphasising Allergens
The 14 major UK allergens must be emphasised within the ingredient list wherever they appear. The legal requirement is that the allergen appears in a different typeface, style, or background colour — bold is the most common approach. Every occurrence of an allergen-containing ingredient must be emphasised: if wheat flour appears twice in the ingredient list (in the pastry and in the sauce), both instances must be emphasised.
Practical Formatting
Use a minimum font size of 1.2mm (measured by the x-height of lowercase letters) for the ingredient list. If the packaging is too small for a full ingredient list, the label must carry a web address where the full information can be found. Don't omit ingredients to save space — every ingredient must be listed.
Understanding the 14 UK Allergens
The 14 allergens covered by UK law are: celery, cereals containing gluten (wheat, rye, barley, oats and their hybridised strains), crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, pistachios, macadamia nuts and Brazil nuts), peanuts, sesame, soya, and sulphur dioxide or sulphites at concentrations above 10mg/kg. Each of these must be emphasised whenever they appear in your ingredient list, whether they are a primary ingredient or a minor component of a compound ingredient deep in the recipe.
It is worth noting that cereals containing gluten must be specified by their source grain. Writing "gluten" in bold is not sufficient — you must name the grain itself, such as "wheat flour" or "rye bread", with the grain name emphasised. Similarly, tree nuts must be identified by their specific variety wherever possible. Listing "nuts" without clarification is not acceptable under UK labelling regulations, and could leave your business exposed if a customer with a specific nut allergy relies on your label for safety information.
Sulphites and sulphur dioxide are commonly found in dried fruits, wine-based marinades, and some vinegars, and are easy to overlook when building an ingredient list. If you use a compound ingredient such as a pre-made dressing or marinade, check the specification sheet from your supplier carefully for sulphite content. Even trace levels approaching the 10mg/kg threshold warrant caution, and many food businesses choose to declare sulphites wherever there is any realistic possibility of presence rather than risk under-declaration.
Handling Compound Ingredients and Supplier Changes
Compound ingredients are one of the most common sources of labelling errors in PPDS food businesses. When you use a bought-in ingredient — a pastry case, a sauce base, a spice blend — that ingredient is itself made from multiple components, and those components must appear in your ingredient list. The correct format is to list the compound ingredient by name, followed immediately by its own ingredient list in brackets. If a spice blend contains celery salt, for example, the celery must be both listed and emphasised within the bracketed sub-list, not simply absorbed into a vague reference to "seasoning".
Supplier changes present a particular operational risk. If a supplier reformulates a product they sell to you — swapping one oil for another, adding a stabiliser, changing the grain source in a starch — your ingredient list and allergen declarations can become incorrect overnight without any visible change to the product itself. Building a process to review supplier specification sheets at regular intervals, and whenever you re-order a product after a gap, is a practical safeguard. Request up-to-date technical data sheets from suppliers at least annually, and keep copies on file alongside your recipe records.
The safest approach is to treat your ingredient list as a living document rather than something you write once and print indefinitely. Whenever a recipe changes, a supplier changes, or a new ingredient is introduced as a substitute, the label must be updated before production resumes. Many food businesses find it helpful to assign clear ownership of this process to one person, so that label accuracy does not fall through the gaps during busy periods or when staff changes occur. Allergen Matrix is designed to help Shopify-based food businesses manage exactly this kind of centralised, updatable allergen information.
What Counts as PPDS Food
Prepacked for direct sale (PPDS) food is food that is packaged at the same premises from which it is sold, before a customer orders or selects it, and is sold in that packaging. A sandwich made in the morning and placed in a sealed wrapper on a shelf for customers to pick up is PPDS. A wrap assembled to order in front of a customer and then wrapped is not PPDS — it is non-prepacked, and subject to different allergen information requirements. Understanding which category your products fall into is the foundation of getting your labelling obligations right.
The distinction matters because some food businesses operate across both categories simultaneously. A bakery might sell loose bread over the counter (non-prepacked), pre-sliced loaves in sealed bags (PPDS), and mail-order cakes shipped to customers (prepacked, subject to full prepacked food labelling law). Each category carries different legal requirements, and applying the wrong standard to a product is a compliance failure even if the intent was good. If you sell food through a Shopify store for local collection or delivery, the PPDS rules are very likely to apply to at least part of your range.
Online food businesses face a specific question about PPDS status when orders are placed online but fulfilled from the same premises. The Food Standards Agency guidance confirms that food packed before the order is placed — for instance, a batch of brownies portioned and wrapped each morning regardless of orders received — is PPDS if sold from the same site. Food portioned and packed only after an online order is received may be treated differently, but the safest course for most small operators is to apply full PPDS labelling to anything that arrives at a customer's door in sealed packaging, and to seek formal guidance from your local authority environmental health team if you are uncertain.
Common Mistakes to Avoid
One of the most frequent errors on PPDS labels is the use of "may contain" statements as a substitute for allergen emphasis within the ingredient list. "May contain" statements refer to unintentional cross-contamination risk — they are a voluntary addition and are not a legal requirement — but they do not replace the obligation to emphasise allergens that are deliberately present as ingredients. A label that lists "wheat flour" without emphasis, but carries a "may contain gluten" footer, is non-compliant. The emphasis must appear within the ingredient list itself, at the point where the allergen-containing ingredient is named.
Another common mistake is abbreviating or simplifying the ingredient list to fit small packaging. The law does not permit omission of ingredients on grounds of space. If your packaging genuinely cannot accommodate a full ingredient list at the required minimum font size, the correct solution is to use a QR code or web address that links to the full information — but this is a last resort, not a default approach. The linked page must be permanently accessible, must contain the complete ingredient list with allergen emphasis, and must reflect the current recipe at all times. A broken link or an outdated page creates both a legal and a safety risk.
Finally, many businesses forget to update labels after seasonal recipe adjustments. Swapping fresh herbs for a dried blend, using a different brand of stock, or adding a new garnish are all changes that can introduce new allergens or alter the order of ingredients by weight. Building a formal review trigger into your recipe management process — so that any change, however minor it seems, prompts a label check before the updated product goes on sale — is one of the most practical steps you can take to maintain ongoing compliance without relying on memory alone.
Keeping Records to Demonstrate Compliance
Maintaining good records is not a strict legal requirement under Natasha's Law in the same way that label content is, but it is an essential part of demonstrating due diligence if a complaint, incident, or inspection occurs. Your records should include the recipe and ingredient specification for each PPDS product, the supplier specification sheets for all bought-in ingredients, the date each label version was created or updated, and a record of who approved each label before it went into use. These documents form the evidence base that shows your labelling process is systematic rather than ad hoc.
If you sell through a Shopify store, keeping allergen records digitally and linking them directly to your product listings creates an auditable trail that paper records cannot easily match. When a customer contacts you with an allergen query, being able to retrieve accurate, current information immediately is both a customer service advantage and a risk management tool. For businesses managing multiple PPDS products with overlapping ingredients, a centralised system that propagates allergen data consistently across all products is far more reliable than maintaining separate label documents for each item.
Good record-keeping also supports the process of training staff. When recipes, allergen declarations, and label versions are documented clearly, new team members can be brought up to speed accurately, and the risk of a well-meaning but incorrect verbal update bypassing the formal label process is reduced. Treat your allergen records with the same rigour you apply to your financial records — they represent the evidence that your business took its legal and moral obligations seriously.
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SaltAI Team
SaltAI builds focused Shopify apps for food merchants and general merchants. Every app is tested in production at a real food store — including Vanda's Kitchen — before it ships.