Natasha's Law and the FSA's Ongoing Review: What May Change

Natasha's Law is not static. The Food Standards Agency continues to monitor its implementation, gather evidence from enforcement activity, and consult on whether the PPDS definition is functioning as intended. Food businesses should stay aware of potential changes.

The Definition Under Discussion

One area under ongoing review is the PPDS definition itself — specifically, whether it is being applied consistently and whether there are categories of food that fall in grey areas. The FSA has consulted on edge cases including:

• Food packaged in one location and transported to a separate selling location owned by the same business
• Food pre-packaged by a third party on behalf of a food business operator
• Multi-site businesses with central production kitchens

Digital Labelling Consultation

The FSA has been considering whether digital labelling — allergen information accessible via QR code or digital display — could eventually supplement or replace physical label requirements for certain product categories. No change has been implemented as of 2026, but consultation has been ongoing.

The Natasha Ednan-Laperouse Foundation's Position

The Natasha Ednan-Laperouse Foundation, established in memory of Natasha, advocates for rigorous enforcement and continued extension of allergen labelling requirements. The Foundation has pushed for allergen information to be standardised across non-prepacked food in the hospitality sector.

How to Stay Current

Subscribe to FSA newsletters, follow Food Safety News, and review updates from trade associations relevant to your sector. The legal minimum today may change, and staying ahead of changes reduces the risk of a compliance gap.

Why Grey Areas Create Real Risk for Small Food Businesses

For small and independent food businesses, the grey areas within the PPDS definition are not merely academic. When enforcement officers visit premises and find labelling arrangements that sit on the boundary of compliance, the consequences can include improvement notices, fines, and reputational damage even where the business operator believed they were acting lawfully. The challenge is that the FSA guidance, while detailed, cannot anticipate every operational configuration, and many businesses make labelling decisions without access to specialist legal or food safety advice.

The difficulty is compounded when a business scales. A baker who packages their own products in the same kitchen where they sell them may initially have a clear situation, but the moment they begin supplying products to a neighbouring café or fulfilling Shopify orders dispatched from a separate unit, the regulatory picture shifts. These transitions often happen incrementally, without a moment where the operator pauses to reassess whether their labelling arrangements still meet the current legal standard. The FSA's ongoing review is in part a response to this kind of operational drift.

For Shopify food merchants specifically, the practical implication is that your labelling obligations may depend on details of how and where your products are assembled, packed, and dispatched — not simply on what ingredients they contain. Keeping a documented record of your production process, and reviewing it whenever your operations change, is a basic but often overlooked form of compliance protection. If the FSA's review results in a tightened or clarified definition, businesses with good documentation will be far better positioned to adapt quickly.

What the FSA's Evidence Gathering Means in Practice

The FSA does not revise food labelling regulations in isolation. Its review process involves gathering evidence from local authority enforcement officers, from food businesses through consultation exercises, and increasingly from consumer groups and allergy charities. This means the direction of any regulatory change is shaped partly by the documented experiences of enforcement on the ground and partly by advocacy from organisations such as the Natasha Ednan-Laperouse Foundation. Understanding this process helps food businesses anticipate where tightening is most likely to occur.

In recent consultation rounds, enforcement officers have flagged inconsistency as a central problem. Two businesses operating under almost identical models may have received different guidance from their local authority, leading to different labelling practices with no clear regulatory basis for the divergence. The FSA's response to this evidence has generally been to push towards greater standardisation and clearer guidance rather than formal regulatory amendment, but the two approaches are not mutually exclusive and more prescriptive rules remain a live possibility.

Food businesses should treat each FSA consultation as a practical signal rather than a theoretical exercise. When the FSA publishes a call for evidence on a specific aspect of PPDS labelling, it is often a precursor to either updated guidance or a formal amendment proposal. Registering to receive FSA alerts, and taking the time to read consultation summaries even where you do not respond formally, will give you an earlier indication of where compliance expectations are heading. This is a low-cost habit that can meaningfully reduce the risk of being caught off-guard by a change in requirements.

The Hospitality and Online Retail Divide

One of the more consequential distinctions in current allergen labelling law is between food sold in physical hospitality settings and food sold as pre-packaged or PPDS products online. Hospitality businesses serving non-prepacked food must provide allergen information but are not required to label individual items in the same way. Online food retailers, including Shopify merchants selling packaged food directly to consumers, generally face stricter requirements because the product must carry its allergen information on or with the packaging at the point it is received by the customer.

This divide has attracted attention from allergy advocates who argue it creates an uneven level of protection depending on how and where a consumer purchases their food. The Natasha Ednan-Laperouse Foundation has been vocal about the risks faced by allergic consumers in hospitality settings, and there is ongoing policy discussion about whether the verbal or written disclosure model used in restaurants and cafés provides sufficient protection compared to the hard-label requirements that apply to packaged food. Any move to extend stricter labelling requirements into hospitality would also have implications for food businesses operating across both channels.

For Shopify merchants who also operate a physical presence — whether a market stall, a café counter, or a pop-up — this divide creates a compliance environment where different rules apply to the same product depending on how it is sold. Maintaining a clear operational distinction between your online and in-person channels, with documented labelling protocols for each, is both a compliance safeguard and a useful way to prepare for any future harmonisation of the rules. Tools like Allergen Matrix can help you manage the online dimension systematically so that your Shopify storefront remains accurate as your product range evolves.

Preparing Your Business for Regulatory Change

The most effective way to manage regulatory uncertainty is not to wait for confirmed changes before acting, but to build compliance practices that are adaptable by design. For food businesses operating on Shopify, this means maintaining an up-to-date and accurate allergen record for every product you sell, structured in a way that can be quickly updated when formulations change or when new regulatory requirements come into force. Businesses that rely on manually updated product descriptions or informal team knowledge are most exposed when the rules shift.

Training is another dimension of preparedness that is frequently underinvested. Staff who understand not just what the current rules require but why allergen labelling exists and what the consequences of errors can be are more likely to flag potential compliance problems before they become serious. This is particularly relevant for businesses where product formulations change seasonally or where ingredients are sourced from multiple suppliers. Regular allergen training, combined with a documented review process for product listings, creates a culture of compliance rather than a one-time tick-box exercise.

Finally, it is worth engaging with your trade association or sector body if one is relevant to your business. Many food sector associations have dedicated regulatory affairs functions that track FSA consultations and produce guidance tailored to their members' specific circumstances. Combining this sector-specific intelligence with your own operational review processes gives you the broadest possible coverage of emerging compliance requirements. The goal is not to predict exactly what will change, but to ensure that when change comes, your business is positioned to respond quickly and confidently without disruption to your customers or your trading relationships.

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