Natasha's Law Two Years On: Has It Made Food Safer?

When Natasha Ednan-Laperouse died in 2016 after eating a Pret a Manger baguette containing sesame seeds that were not listed on the packaging, her death exposed a dangerous gap in UK food labelling law. Pre-packed for direct sale (PPDS) foods — items made and packaged on the same premises where they were sold — were entirely exempt from full ingredient labelling requirements. A sesame allergy sufferer had no way of knowing what was inside a sandwich wrapped and sold at the same counter. The result was a preventable tragedy that shook the food industry.

Natasha's Law, which came into force on 1 October 2021, closed that exemption by requiring PPDS foods to carry a full ingredients list with the 14 major allergens emphasised in bold. Two years on from that deadline, the question worth asking is whether the legislation has actually delivered the change it promised — and what it has meant in practice for the food businesses required to comply.

In this post, we examine what has changed since the law took effect, where compliance gaps still exist, how enforcement is playing out across England, Wales, Scotland, and Northern Ireland, and what food business owners selling through Shopify and other digital channels should be doing right now to make sure their labelling holds up under scrutiny.

What Natasha's Law Actually Requires — And What It Doesn't

It is worth being precise about the scope of the law, because many food operators still misunderstand which products fall within it. Pre-packed for direct sale describes food that is packaged at the same site where it will be sold directly to consumers — sandwiches wrapped in a café, salads portioned in a deli, freshly baked goods bagged in a bakery. These products now require a full ingredients list with all 14 major allergens — celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide and sulphites, and tree nuts — highlighted in bold, a contrasting colour, or an alternative typeface.

The law does not apply to pre-packed foods manufactured off-site and sold with sealed labels already applied — those were already covered by pre-existing regulations under the Food Information to Consumers Regulation. Nor does it govern loose foods sold without any packaging, which are subject to separate allergen information requirements that allow verbal communication as an alternative. Understanding this distinction matters enormously for businesses that operate across multiple formats, such as a producer who both sells loose at a market stall and ships pre-packed products through an online Shopify store.

What frequently catches operators out is the hybrid nature of many food businesses. A coffee shop that also sells its own branded granola through an e-commerce site, for example, may find that the granola destined for postal delivery falls under different labelling rules than the same granola pre-packaged and sold across the counter. Each sales channel and each packaging scenario needs to be assessed individually, and the consequences of getting it wrong — from council enforcement notices to reputational damage — are significant enough to demand careful attention.

The Evidence on Compliance Two Years After the Deadline

The early picture of compliance was, frankly, mixed. A 2022 survey conducted by the Food Standards Agency found that awareness of the new requirements was high among larger food businesses but considerably lower among smaller independent operators — exactly the cafés, delis, and artisan producers most likely to be selling PPDS products in volume. Many small operators reported that they had not received direct guidance from their local authority and had self-educated through trade publications or social media, with varying degrees of accuracy.

By late 2023, local authority enforcement bodies were beginning to report the results of their inspection programmes in more detail. Several councils in England published data showing that between 15 and 25 percent of PPDS food items inspected in independent food businesses lacked full compliant labelling, with the most common failure being allergens not properly emphasised. Contrast this with supermarket own-label PPDS lines, where compliance was near-universal — larger operations had the legal resource and operational infrastructure to adapt quickly.

The practical challenge for small and medium food businesses is not lack of willingness but lack of standardised process. A bakery producing thirty different products each week may be labelling accurately on a Monday and slipping into non-compliance by Friday simply because a recipe changed slightly, a supplier switched an ingredient, or a staff member printed last week's label on this week's batch. Building labelling into a repeatable operational system — not just a one-time compliance exercise — is the only sustainable approach.

Where the Gaps Still Are: High-Risk Categories and Scenarios

Allergen experts and trading standards officers have identified several categories of food business that remain disproportionately likely to have labelling gaps. Artisan and craft food producers selling at farmers' markets, independent retailers, and through their own Shopify stores often operate without dedicated food safety personnel, making it easy for labelling to fall behind operational reality. These businesses are also more likely to produce small-batch products where ingredients vary by season, increasing the risk that a label printed in spring is inaccurate by autumn.

Catering businesses that have pivoted to retail represent another high-risk group. During the pandemic, many restaurants and caterers launched direct-to-consumer product lines — hot sauces, condiments, ready meals, spice blends — to replace lost hospitality revenue. Some of these operations remained in place as successful side businesses, but their founders came from a food service background where verbal allergen disclosure was the norm. Translating that knowledge into compliant printed labelling for retail products is a different discipline, and not everyone made that transition cleanly.

Ghost kitchens and meal prep subscription services operating through Shopify also warrant specific attention. When a customer orders a prepared meal through an e-commerce interface and it arrives in a sealed container, that product almost certainly qualifies as PPDS — packed on the production premises and sold directly to the consumer. Yet many operators in this space continue to rely on website product descriptions as their primary allergen communication method, which is not a substitute for compliant on-pack labelling. The label must be on the packaging itself, not just somewhere on the website.

How Enforcement Is Evolving — And What Penalties Look Like

The enforcement landscape has evolved from the initial light-touch approach taken by most local authorities in the immediate post-October 2021 period. In the first year, the predominant approach was advisory — officers visiting premises, identifying labelling issues, and issuing improvement notices rather than pursuing formal action. That grace period has largely ended. By 2023, several food businesses had received formal improvement notices requiring corrective action within defined timeframes, and businesses that failed to comply faced the prospect of prohibition notices preventing them from selling non-compliant products.

The financial consequences of enforcement action extend beyond any direct financial penalty. A prohibition notice preventing the sale of a product line can devastate cash flow for a small food business, particularly one that has invested in stock and packaging. Beyond enforcement, the reputational damage from a publicised allergen incident or a Food Standards Agency enforcement action can be terminal for a brand built on trust. The allergen-allergic consumer community is highly networked, and news of labelling failures spreads quickly through social media channels.

Civil liability is the dimension that keeps food business solicitors busy. If a customer suffers an allergic reaction because allergen information was incorrect or absent, the business faces potential claims under consumer protection legislation in addition to any regulatory action. Anaphylaxis cases resulting in hospitalisation have led to settlements and judgments running to tens of thousands of pounds. Natasha's Law was partly designed to create a clear, enforceable standard precisely so that liability could be assessed objectively — but that cuts both ways for operators who fail to meet it.

Using Digital Tools to Manage Allergen Information Reliably

Managing allergen information manually — through spreadsheets, handwritten notes, or Word documents — is the single most common source of errors in small food businesses. Ingredient changes, supplier substitutions, and recipe iterations need to be captured centrally and reflected immediately in labelling output. A tool like Allergen Matrix allows Shopify-based food businesses to maintain a centralised allergen database that links directly to their product catalogue, making it straightforward to identify which products are affected when an ingredient changes.

The practical benefit of a digital allergen management system is not just accuracy — it is auditability. If a local authority officer or a solicitor asks you to demonstrate that your allergen information was correct on a specific date, a well-maintained digital system provides that evidence trail in a way that a manually updated spreadsheet simply cannot. This audit capability has become an increasingly important consideration as enforcement activity increases and the standard of expected record-keeping rises accordingly.

For Shopify merchants selling food products, the intersection of online product listings and physical packaging creates a specific compliance challenge. Both must be accurate, both must be consistent with each other, and both must reflect the current version of each recipe. Building a workflow that updates physical label templates and online product descriptions simultaneously — triggered by any change to the underlying ingredient or allergen data — is the operational standard that regulators and legal advisers increasingly expect from food businesses of any scale.

Practical Steps Every Food Business Should Take Now

If you have not conducted a formal review of your PPDS labelling since October 2021, the most important first step is a complete product audit. List every product you sell, identify which ones qualify as PPDS, and check each label against the current regulatory requirements — full ingredients list, allergens emphasised, and accurate reflection of the current recipe. This sounds straightforward but in practice it often surfaces discrepancies that have accumulated over time as recipes evolved without label updates following. Treat the audit as a diagnostic exercise, not a box-ticking one.

Second, establish a change control process for recipes and ingredients. Every time a supplier changes a formulation, or you substitute an ingredient, or you adjust a recipe, that change should trigger an automatic labelling review before the product is made or sold again. This process needs to be documented, assigned to a named person, and followed consistently — not left to informal communication. A two-step check, where a second person verifies the label before production runs, significantly reduces the risk of errors reaching the consumer.

Third, invest in staff training that is specific to your product range rather than generic allergen awareness. Your team needs to understand not just the 14 allergens but specifically where they appear in your own products and what to do if a customer asks a question that the label does not answer. Refresh this training at least annually, and whenever your product range changes materially. Document that training in a format you could present to an enforcement officer — sign-off sheets, training records, and assessment results all contribute to demonstrating the due diligence defence that is available to food businesses under UK food safety law.

Conclusion

Natasha's Law has unquestionably moved the dial on food labelling safety in the UK — it closed a genuine gap in the regulatory framework and has driven widespread improvement in allergen communication across the food industry. But two years on, compliance is not yet universal, enforcement is tightening, and the operational challenge of keeping labelling accurate in dynamic food businesses remains significant. The businesses most at risk are those that achieved initial compliance in October 2021 but have not maintained the discipline to keep labelling current as their products and suppliers evolve.

The key takeaways are simple: audit your current labelling, build a change control process, train your team specifically, and use digital tools to make allergen management systematic rather than manual. The law is clear, the regulator is watching, and the cost of getting it wrong — to your customers and to your business — is too high to leave to chance.

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