Pre-Packed Food Labelling: Natasha's Law Compliance Checklist

Natasha's Law changed the labelling requirements for pre-packed for direct sale (PPDS) food in England, Wales, and Northern Ireland from 1 October 2021. If your food business makes, packages, and sells food on the same premises — whether you are a bakery, deli, café, meal prep company, or catering operation — this law requires full ingredient labelling with allergen emphasis on every PPDS item.

Use this checklist to assess and achieve compliance.

Step 1: Identify Your PPDS Products

PPDS food is food that is:

Packaged in full or in part before a customer orders it
Packaged on the same premises where it is offered for sale
In the packaging when offered for sale

Examples include:

Pre-wrapped sandwiches, wraps, or rolls
Pre-packaged salads or prepared meals
Pre-wrapped cakes, pastries, biscuits
Pre-packed meal prep portions
Homemade items packaged before selling at a market or event

Not PPDS (different rules apply):

Items packaged in front of the customer on request (non-prepacked)
Items manufactured and packed at a different site (fully pre-packed under standard FIC rules)

Step 2: Document Your Recipes Completely

For each PPDS product:

List every ingredient in full, in descending order of weight as incorporated
Obtain full ingredient breakdowns for all compound ingredients (e.g., bought-in sauces, stocks, spice blends, breads)
Account for all processing aids and sub-ingredients
Note any carry-over allergens from processing
Keep your recipe documentation on file and dated

Step 3: Identify All Allergens in Each Product

Map each product against the 14 major allergens:

Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut — and products thereof)
Crustaceans
Eggs
Fish
Peanuts
Soybeans
Milk
Nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamias)
Celery
Mustard
Sesame seeds
Sulphur dioxide and sulphites (if above 10mg/kg or 10mg/litre)
Lupin
Molluscs

Step 4: Create Your Labels

Each PPDS label must include:

Name of the food — accurate and descriptive
Full ingredients list — all ingredients listed in descending order of weight
Allergen emphasis — all 14 allergens present must be highlighted (bold, italic, underlining, or contrasting colour) within the ingredients list

Label design requirements:

Text must be legible — adequate font size and contrast
Allergen emphasis must be consistent and clear
Consider the label medium — thermal-printed labels should use bold, not colour, as sole emphasis
Label should be securely attached and readable after refrigeration or handling

Not required under Natasha's Law (but may be required under other regulations):

Nutritional information (required for most standard pre-packed food but not specifically required by Natasha's Law for PPDS)
"Best before" or "use by" dates (required by date marking regulations separately)

Step 5: Assess Cross-Contamination and Precautionary Labelling

Conduct a cross-contamination risk assessment for each product
Identify shared equipment, surfaces, and production lines
Assess your cleaning and segregation procedures
Determine whether precautionary allergen labelling ("may contain") is appropriate for any products
If you include PAL, be specific about which allergens are covered
Document your assessment

Step 6: Build a Label Update Process

Designate who is responsible for label management
Create a process for updating labels when recipes change
Create a process for updating labels when suppliers change ingredients
Build allergen review into your new product development process
Schedule regular audits of all labels (at least annually, more frequently if your range changes regularly)

Step 7: Train Your Team

Ensure all staff who make, package, or label PPDS products understand Natasha's Law requirements
Train staff on the 14 major allergens and how to identify them in ingredients
Explain the importance of accurate labelling and the consequences of errors
Document training and keep attendance records

Step 8: Plan for Enforcement

Understand that local authority food safety officers can inspect your labels
Keep your recipe documentation available for inspection
Know the route to remediation if an error is identified
Have a recall or withdrawal plan in case a mislabelling issue is identified after products have been sold

Online Sales and Natasha's Law

If you sell your PPDS products through an online channel:

Display full allergen information on your product pages — the label requirements extend to online selling
Ensure packaging delivered to customers carries compliant labels
Update your website whenever your labels change

SafeServe, our Shopify app for food allergen labelling, helps you display allergen information accurately on your online store and keep it updated as your recipes evolve.

Try SafeServe free on the Shopify App Store and make Natasha's Law compliance part of your everyday process.

Understanding the Legal Consequences of Non-Compliance

Non-compliance with Natasha's Law is not treated as a minor administrative oversight by enforcement authorities. Local authority food safety officers have the power to issue improvement notices, suspend food business registrations, and in serious cases pursue criminal prosecution. Fines are unlimited in the Crown Court, and individual business owners can face personal liability alongside the business entity itself. The reputational damage from a public enforcement action — particularly one covered in local or national press — can be severe and lasting for a small food business.

Beyond enforcement, the human cost of a labelling failure is the most important reason to take compliance seriously. Natasha's Law was enacted following the death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction after eating a pre-packaged baguette that carried no allergen information. For customers with severe allergies, an unlabelled or mislabelled product is not an inconvenience — it is a genuine threat to their life. Every label your business produces is part of a safety system that real people depend on when making purchasing decisions.

If your business is inspected and a labelling failure is found, you will typically be required to withdraw affected products from sale immediately and relabel your entire range before resuming. This kind of reactive correction is far more disruptive and costly than building a proactive compliance process from the outset. Treating your label management system as a core operational function — not an afterthought — is the most practical way to protect both your customers and your business.

Managing Supplier Changes Without Creating Allergen Gaps

One of the most common sources of unintentional allergen mislabelling is an unmanaged supplier change. When an ingredient supplier reformulates a product — changing a sauce recipe, switching a stock base, or updating a spice blend — the allergen profile of that ingredient can change without any direct notification to your business. If your labels are not reviewed and updated to reflect the new formulation, your printed allergen information becomes inaccurate even though nothing changed in your own kitchen. This is a genuine and well-documented compliance risk for small food businesses.

To manage this risk effectively, build supplier communication into your allergen management process as a formal step. Request ingredient specification sheets and full allergen declarations from every supplier when you first place an order, and ask to be notified of any formulation changes in writing. Some suppliers will offer this proactively; others will need to be asked directly. Keep copies of all specification sheets on file and date them so you can demonstrate that your label information was verified against current supplier data at a specific point in time.

When a supplier change does occur — whether you have switched suppliers entirely or an existing supplier has reformulated — your process should trigger an automatic label review before the new ingredient enters production. Assign this responsibility clearly to a named individual in your team. The Allergen Matrix tool is useful here because it allows you to update a single ingredient record and immediately see which products in your range are affected, reducing the manual effort of cross-referencing every label individually.

Seasonal and Limited-Edition Products Carry the Same Obligations

Many food businesses introduce seasonal specials, limited-edition flavours, or promotional items without applying the same labelling rigour they use for their core range. This is an understandable operational pressure — seasonal products are developed quickly and often sold in short runs — but Natasha's Law applies equally to every PPDS item you sell regardless of how long it is on your menu. A Christmas cake, a Valentine's Day brownie box, or a summer salad special must carry a fully compliant label from the first unit sold.

The practical challenge with short-run or seasonal products is that recipe documentation can be less thorough than for established lines. Ingredients may be sourced from new suppliers specifically for the product, compound ingredients like festive spice blends may not have been used before, and there is less time to conduct a full allergen review before launch. Building a short-form new product launch checklist — covering recipe documentation, allergen mapping, label sign-off, and supplier specification collection — gives you a repeatable process that does not slow product development significantly but ensures nothing is missed.

If you sell seasonal products online through your Shopify store, the same label content must appear on your product pages before any unit is available to purchase. Customers buying online are entitled to the same allergen information as those buying in person. Planning your label and product page content as part of your seasonal launch process — rather than as a last-minute addition — means you avoid the common situation of a product going live without compliant allergen information displayed.

Keeping Records That Will Support an Inspection

A well-maintained set of compliance records serves two important purposes. First, it gives you the operational visibility to identify and correct labelling issues before they become enforcement problems. Second, it demonstrates to a visiting food safety officer that your business has a systematic and documented approach to allergen management, which is a significant factor in how inspections are assessed and how any findings are treated. Businesses that can produce clear, dated documentation are in a meaningfully stronger position than those that cannot.

Your records should include dated copies of every label version you have used for each product, alongside the recipe documentation and supplier specification sheets that supported it. When you update a label — whether because a recipe changed, a supplier reformulated, or you corrected an error — keep the previous version on file with a note of why it was superseded and when. This version history demonstrates that your label management is an active and responsive process rather than a static one-time exercise.

Training records are equally important. If a member of staff is involved in making, packaging, or labelling PPDS products, there should be a record that they received allergen awareness training, when they received it, and who delivered it. You do not need a formal accredited qualification for every team member, but you do need to be able to show that training happened and was documented. Keep attendance records for any group training sessions and individual records for one-to-one or induction training.

Try Allergen Matrix free at saltai.app — no credit card required.

Pre-Packed Food Labelling: Natasha's Law Compliance Checklist