Natasha's Law for Food Importers: Does It Apply to Foreign-Made PPDS Products?
If you import food and package it in the UK for direct sale, Natasha's Law may apply. Here's what food importers need to understand about PPDS classification.
Food importers who bring products into the UK and then repackage or portion them for sale face questions about how Natasha's Law applies. The key factor is not where the food was made — it is where it is packaged.
When Importing Triggers PPDS Requirements
If you import food in bulk and package it on your UK premises for direct sale — slicing and wrapping imported charcuterie, portioning imported cheese, packaging imported pastries — that packaging process on your premises makes the food PPDS. Natasha's Law applies.
If you import food that was fully packaged at the point of manufacture in another country and sell it in that original packaging, it is fully prepacked food. Different labelling rules apply (also mandatory, but not Natasha's Law PPDS requirements).
The Repackaging Trigger
The act of packaging on the premises where the food is sold is the defining PPDS trigger. An importer who divides bulk imported goods into retail portions at their own warehouse and sells from that warehouse is packaging PPDS food on their selling premises.
Language Requirements
Labels on food sold in the UK must be in English. Imported products relabelled for UK sale must have English-language labels that comply with UK food information requirements, including allergen emphasis.
Allergen Data from Foreign Suppliers
Importers must obtain accurate ingredient and allergen data from their overseas suppliers. Difficulties in obtaining this information do not create an exemption from labelling requirements. If allergen data cannot be confirmed, the product cannot be accurately labelled.
Understanding the PPDS Definition in an Import Context
The definition of prepacked for direct sale food hinges on a specific relationship between packaging location and selling location, not on the country of origin. Many importers assume that because their product was manufactured and initially packaged overseas, it falls outside the scope of Natasha's Law. That assumption is incorrect the moment any repackaging, portioning, or wrapping occurs on the UK selling premises. The law looks at what happens to the food in the UK, not what happened to it abroad.
This distinction matters enormously for importers who operate as both importer and retailer from the same site. A business that receives pallets of imported olives, scoops them into branded pots, seals those pots on-site, and sells them directly to customers at that location is performing every step of the PPDS process on its own premises. The origin of the olives is legally irrelevant to that trigger. What matters is the act of packaging at the point of sale, and that act is happening in the UK under UK food law jurisdiction.
The same logic applies to importers who use market stalls, farm shops, or online fulfilment operations co-located with their storage facilities. If a customer could reasonably consider the place where packaging occurs and the place from which they are buying to be the same premises, the food is PPDS. Importers should map their physical operations carefully against this definition before concluding that their imported products fall outside Natasha's Law obligations.
Traceability Across International Supply Chains
Sourcing allergen data from overseas manufacturers is one of the most practically challenging aspects of compliance for importers. Many foreign producers supply ingredient information in formats that do not align with UK labelling requirements, either because their domestic regulations differ or because they have not previously needed to provide data at the level of detail UK law demands. That mismatch does not create any flexibility in what the UK importer is required to put on their labels. The obligation sits entirely with the business selling the food in the UK.
Importers should build formal allergen information requests into every supplier contract and purchasing agreement. Asking for a full ingredient list, a declaration of the fourteen regulated allergens, and information about cross-contamination risks at the manufacturing site should be standard practice before any product reaches UK shelves. Where suppliers are unable or unwilling to provide this data, the importer faces a straightforward choice: invest in independent laboratory testing to verify allergen status, or do not sell that product in the UK market.
Keeping records of the allergen data you have received from overseas suppliers is also important. If your labelling is ever questioned by an enforcement authority, being able to demonstrate that you requested, received, and acted on specific allergen declarations from your supplier is evidence of due diligence. A structured approach to managing this information across multiple product lines — particularly when you are importing from several countries simultaneously — is essential rather than optional. Tools like Allergen Matrix at saltai.app are designed to help food businesses organise exactly this kind of product-level allergen data.
Label Formatting for PPDS Imported Products
A PPDS label on an imported product must meet the same formatting requirements as any other PPDS label sold in the UK. That means the name of the food, a full ingredient list with the fourteen regulated allergens emphasised — typically in bold — and any other mandatory information required under the Food Information Regulations. The fact that your supplier has already printed ingredients on the original outer packaging in another language does not satisfy this requirement. You need a UK-compliant label applied to each individual PPDS unit.
The emphasis requirement is one area where importers sometimes make errors. It is not sufficient to list allergens separately in a "contains" statement, though that can appear in addition to the ingredient list. The allergens must be emphasised within the ingredient list itself, so that a consumer scanning the label can immediately identify them. Bolding is the most common method, but underlining or capitalisation can also be used as long as the emphasis is visually distinct from the surrounding text. This must appear on the label in English regardless of what language the original product packaging uses.
Importers who produce their own PPDS labels should also ensure they have a reliable process for updating labels when supplier formulations change. An overseas manufacturer may adjust a recipe for cost or availability reasons without notifying every distribution partner. Building a review process that checks ingredient declarations against supplier data at regular intervals — and certainly whenever a new batch arrives — reduces the risk of selling a mislabelled product because a reformulation went unnoticed.
When Imported Food Is Sold Through Multiple Channels
Many food importers do not sell exclusively from a single premises. They may sell wholesale to other retailers, supply food service customers, operate an e-commerce store, and maintain a trade counter or market presence simultaneously. Each of these channels can carry different labelling obligations, and the PPDS rules apply specifically to the channel where packaging and direct sale occur on the same premises.
Wholesale supply to another retailer who then repackages the food on their own premises transfers the PPDS obligation to that retailer. In that situation, the importer's obligation is to provide the downstream business with accurate and complete allergen and ingredient information, not to apply PPDS labels to the bulk goods themselves. However, if the importer is also selling pre-portioned units directly to end consumers — even informally, from the same warehouse — those units require PPDS labelling regardless of what else the business does with the same product.
E-commerce adds further complexity. Food sold online and dispatched to consumers from the seller's premises is subject to PPDS rules if it is packaged at the dispatch location, which is typically the same business premises for small and medium importers. Treating online sales as exempt from PPDS requirements because the customer is not physically present at the packaging location is a common misunderstanding. The rules apply based on the relationship between the packaging premises and the selling business, not on whether the customer was present when the food was wrapped.
Enforcement and Consequences for Non-Compliant Importers
Local authority environmental health officers are responsible for enforcing food labelling requirements in the UK, and they do conduct inspections of food businesses including importers. A business found to be selling PPDS food without compliant allergen labelling may receive an improvement notice requiring corrective action within a specified timeframe, or in more serious cases face prosecution. The reputational consequences of a labelling failure involving allergens can be severe, particularly if a consumer suffers an allergic reaction and the business cannot demonstrate that its labels were accurate and compliant.
For importers, the enforcement risk is compounded by the complexity of international supply chains. If a label is found to be incorrect because of inaccurate information provided by an overseas supplier, the UK business remains liable. Enforcement authorities assess the compliance of the food as it reaches the consumer, and the argument that a foreign supplier provided wrong data is not a defence, though evidence of due diligence may be considered in mitigation. This is another reason why having documented processes for obtaining and verifying allergen data is so important.
The practical steps for reducing enforcement risk are well established: obtain written allergen declarations from every supplier, review them when batches change, ensure every PPDS label meets UK formatting requirements, train staff who handle packaging and labelling, and keep records. Importers who treat allergen compliance as a documented, auditable process rather than an informal judgement call are in a significantly stronger position if questions are ever raised about their products.
Manage allergen data for imported and domestically produced food lines with Allergen Matrix at saltai.app.
Try Allergen Matrix free at saltai.app — no credit card required.
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.