Natasha's Law and Private Label Food: Who Is Responsible?
When a food business sells products under its own brand but made by a contract manufacturer, Natasha's Law responsibility sits with the brand owner. Here's why.
Private label food — products made by a contract manufacturer but sold under your brand — raises an important question for Natasha's Law compliance: who is responsible for accurate allergen labelling?
The Brand Owner Bears Responsibility
Under UK food law, the food business operator (FBO) placing the food on the market is responsible for the accuracy of its labelling. If you sell a product under your brand, you are the FBO — even if someone else made it. This means you are responsible for ensuring the label on your product is accurate, including allergen information.
Why This Matters for PPDS Products
If a contract manufacturer makes your sandwiches or prepared meals and you package them under your label on your premises, Natasha's Law applies and you are responsible for the label. If the manufacturer packages them at their premises and you collect and sell them, the classification (PPDS or fully prepacked) depends on where packaging occurs.
What to Demand from Contract Manufacturers
When working with a contract manufacturer, your supply agreement should specify:
- Full ingredient lists provided for every product
- Immediate written notification of any formulation change
- Allergen matrix documentation reviewed at least annually
- Samples retained for testing if allergen incidents arise
Shared Facility Risks
If your contract manufacturer also produces products containing allergens on shared equipment, you need to understand and document the cross-contamination risk. This affects both your labelling and any precautionary allergen statements.
Understanding Where Legal Liability Sits in Practice
Many private label brand owners assume that because a contract manufacturer physically produced the food, some portion of the legal responsibility for allergen accuracy sits with them. This assumption is dangerous and legally incorrect. Under the Food Information for Consumers Regulation and the subsequent amendments introduced by Natasha's Law, the FBO placing the product on the market carries full responsibility. If a customer suffers an allergic reaction and your label was inaccurate, enforcement action — including prosecution — will follow the brand, not the factory.
This distinction becomes especially important when formulations change mid-contract. A manufacturer may substitute an ingredient for operational or supply chain reasons without fully appreciating that this change must be communicated to you immediately. If they switch from a sunflower oil to a blend that includes a sesame derivative and your label still reads the original formulation, you are the party in breach — even though you had no direct knowledge of the change. Your supply agreement must close this gap explicitly and in writing.
The practical consequence is that you cannot rely on your manufacturer's own labelling or internal allergen documentation as your sole compliance record. You need to obtain, store, and periodically re-verify that documentation yourself. Any allergen incident investigation by a local authority trading standards team or the Food Standards Agency will look at what due diligence you exercised as the brand owner. Having a robust paper trail demonstrating that you actively managed allergen information from your supply chain is your primary defence.
Building a Contractual Framework That Protects You
A well-drafted supply agreement with your contract manufacturer is one of the most important compliance tools available to a private label brand owner. The agreement should go beyond commercial terms and include specific allergen-related obligations that are legally enforceable. At minimum, this means requiring your manufacturer to provide a full, verified ingredient list and allergen matrix for each product before it enters your inventory, and to reissue that documentation any time a formulation or ingredient source changes, regardless of how minor the change appears to them.
Your contract should also specify notification timelines. A change communicated three weeks after a reformulation has already occurred is a compliance failure waiting to happen. Requiring written notification within 24 to 48 hours of any ingredient or process change, with your written sign-off required before the reformulated product ships to you, creates a clear procedural checkpoint. If your manufacturer cannot commit to this operationally, that is important information about whether they are the right partner for a brand with Natasha's Law obligations.
Consider including audit rights in the agreement. The ability to visit your manufacturer's facility, review their allergen cleaning and segregation procedures, and inspect their incoming ingredient documentation gives you a level of oversight that cannot be replicated through paperwork alone. Even if you exercise that right only once a year, the fact that it exists changes the dynamic of the relationship and signals to your manufacturer that you take allergen compliance seriously. Pair this with a clear indemnity clause covering any losses arising from inaccurate allergen information provided by the manufacturer.
Managing Recipe and Formulation Changes Over Time
Private label products are rarely static. Ingredients get substituted, suppliers change, recipes are adjusted seasonally, and portion formats evolve. Each of these changes carries allergen labelling implications that must be assessed before the updated product reaches your customer. The challenge is that the change often feels routine to your manufacturer while being legally significant for you. Establishing a formal change management process — even a simple one — is essential for maintaining continuous compliance across a growing product range.
A practical approach is to create a formulation register for each product in your range, documenting the approved ingredient list, allergen status, and the date that version was verified. When a change notification arrives from your manufacturer, the register is updated only after you have reviewed the new allergen matrix, assessed whether the change affects any of the 14 major allergens, and confirmed that any label update required has been made. This creates a version-controlled record that demonstrates your due diligence at every point in the product's history.
Digital tools make this process significantly more manageable. Rather than maintaining spreadsheets that can fall out of date or become inconsistent across products, using a dedicated allergen management tool means your allergen data and your customer-facing product information stay in sync. When you update a formulation record, the corresponding allergen information visible to customers on your Shopify store should reflect that change immediately. Tools like Allergen Matrix are built specifically for this workflow, allowing Shopify merchants to manage allergen data product by product without the risk of manual errors accumulating over time.
What Happens When Things Go Wrong
Despite best efforts, allergen incidents do occur. A customer reports a reaction, a complaint is filed, or a local authority initiates an investigation. In these situations, your ability to demonstrate that you operated a robust allergen management system from the moment a product entered your range is the difference between a serious enforcement outcome and a proportionate response. Trading standards officers and FSA investigators are trained to assess whether a food business exercised due diligence — and the evidence they look for is systematic, documented, and contemporaneous.
The first practical step when an incident is reported is to preserve all documentation relating to the affected product batch: the ingredient list and allergen matrix version in use at the time of production, any change notifications received or sent in the preceding period, and any communications with your contract manufacturer about that specific product or batch. If you cannot produce this documentation quickly, the investigation becomes significantly harder to manage. Businesses that have made allergen management an ongoing operational discipline rather than a one-off compliance exercise tend to navigate these situations far more effectively.
There is also a customer communication dimension to allergen incidents that brand owners sometimes underestimate. If a mislabelling issue affects more than a single customer, a product recall or withdrawal may be necessary. The FSA publishes allergen-related recalls regularly, and the reputational damage of a public recall can be substantial for a private label brand. Having clear internal escalation procedures, a communication plan, and a relationship with your local environmental health team before an incident occurs puts you in a far stronger position to respond proportionately and protect both your customers and your brand.
Keeping Your Online Store Compliant
For private label brands selling through Shopify, the online product page is often the first and only place a customer will look for allergen information before purchasing. This makes the accuracy of your digital product listings just as important as the physical label — and in some cases, more so, because customers browsing online cannot pick up the product and read the back. Your Shopify store must reflect the current, verified allergen status of every product in your range, updated every time a formulation changes.
Managing this manually across a growing catalogue is error-prone. A product that has been reformulated by your manufacturer may have its allergen information updated on the physical label but remain outdated on the product page for weeks if there is no system linking the two. This creates a compliance gap that exposes your business to the same legal risk as an inaccurate physical label, particularly if a customer relies on the online listing to make a purchasing decision.
Using a structured allergen management tool integrated with your Shopify store removes this gap. When your allergen data is centralised and directly connected to your product listings, updates propagate automatically rather than depending on a manual process that can be missed during busy trading periods. This is precisely the workflow that Allergen Matrix is designed to support — giving private label brand owners a single, reliable source of allergen truth that keeps both their back-office records and their customer-facing store accurate and current.
Ensure accurate allergen labelling on your Shopify product pages with Allergen Matrix — free to get started at saltai.app.
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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.