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Natasha's Law: What UK Food Businesses Still Get Wrong

Food label showing allergen information for prepacked for direct sale PPDS product

In July 2016, a fifteen-year-old named Natasha Ednan-Laperouse ate a Pret a Manger baguette on a flight to Nice. The baguette contained sesame baked into the dough. It was not listed anywhere on the packaging. Natasha had a severe sesame allergy. She went into anaphylactic shock and died that day.

The inquest into her death revealed that under the law at the time, Pret was not required to list allergens on food prepared and packed on their premises. The packaging was technically legal. That was the problem.

Natasha’s Law — the Food Information (Amendment) (England) Regulations 2019 — came into force on 1 October 2021. Its purpose is simple: if you prepare and pre-pack food on your premises to sell directly to customers, you must now label it fully.

Four years on, the law is clear. But the mistakes are not going away.

What Is PPDS Food?

Natasha’s Law specifically applies to food that is Pre-Packed for Direct Sale (PPDS). Understanding this category precisely is where a lot of businesses go wrong.

PPDS food is food that is:

  • Prepared or packed on the same premises where it is sold, and
  • Packaged before a customer orders or selects it, and
  • Sold by the same business that packed it

The classic example is a grab-and-go sandwich made in the morning, wrapped, and placed in a chilled display before customers arrive. Other common examples include:

  • Bakery items wrapped and displayed in a cabinet (pastries, slices, rolls)
  • Pre-portioned salads or deli pots assembled earlier in the day
  • Hot food pre-cooked and wrapped before peak service (chicken pieces, pies)
  • Food samples pre-packed before being handed out
  • Meal prep boxes assembled in advance of collection or click-and-collect orders

What PPDS does not cover:

  • Food packed and sold by a different business (that is pre-packed food, which has always required full labelling)
  • Food prepared fresh to order in front of the customer (non-prepacked)
  • Food sold via distance selling — phone or online orders — though separate allergen disclosure rules apply there

If you are unsure whether something you sell counts as PPDS, the guiding question is: was it packaged before the customer requested or chose it, and are you the one who made and sold it? If yes, Natasha’s Law applies.

What Must Be on the Label?

Under Natasha’s Law, every PPDS product must carry three pieces of mandatory information directly on the packaging:

  1. The name of the food — a clear description of what it is
  2. A full ingredients list — all ingredients in descending order by weight
  3. Allergens emphasised within the ingredients list — any of the 14 major allergens present must be highlighted in a way that makes them stand out: typically bold, italics, or a contrasting colour

The 14 allergens you must highlight if present:

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

The Food Standards Agency has published a technical guide that specifies font size requirements and what voluntary statements (such as “may contain” precautionary labelling) must look like if you choose to include them.

The Mistakes EHOs Are Still Finding

1. Misidentifying What Is and Isn’t PPDS

Some businesses assume the law only applies to a traditional sandwich counter. In practice, anything sitting pre-wrapped in a display case — from flapjacks to sushi boxes to filled rolls — is almost certainly PPDS. Staff often sell these items without realising a full label is required.

2. Relying on a Handwritten or Informal Label

A sticker with just the product name and price is not enough. A handwritten “contains nuts” warning is not enough. The label must include the full ingredient list with allergens emphasised. No exceptions.

3. Inaccurate Allergen Information

This is the most dangerous error and the one that carries the most serious consequences. If an ingredient changes — a supplier updates a recipe, you switch to a different brand of flour, a sauce formulation is altered — and your label is not updated, you have an inaccurate label on a product in front of customers. Allergen information is only as good as your ingredient tracking.

4. Version Control Failures

Businesses often maintain allergen matrices on paper or in spreadsheets. When a menu item changes, old versions circulate. Staff make decisions based on outdated information. One of the most common EHO findings in this space is that documented allergen information does not match what is actually being used in the kitchen.

5. Distance Selling Confusion

If you sell PPDS food for collection via phone or your website, Natasha’s Law labelling does not apply to that transaction in the same way — but you are still legally required to provide allergen information to the customer before they place the order and at the moment of delivery. Many businesses assume that because the transaction is online, they have fewer obligations. They do not.

6. No Traceability From Label Back to Production

EHOs do not just look at the label. They want to follow the thread: from the label, back to the allergen matrix, back to the supplier specifications, back to the delivery records. If you cannot demonstrate that the information on your label is accurate and where it came from, you have a compliance gap — even if the label itself looks correct.

What an EHO Expects to See

When an Environmental Health Officer reviews your allergen compliance under Natasha’s Law, they will typically look for:

  • An up-to-date allergen matrix for all PPDS products you produce
  • Supplier specifications confirming ingredient allergen content, reviewed regularly
  • Evidence that staff understand allergen responsibilities — training records, awareness of the 14 allergens
  • A process for handling ingredient changes — how does the kitchen communicate a recipe change to whoever produces the labels?
  • Labels on every PPDS product with the correct mandatory information, consistently applied

The key word is consistency. A single incorrectly labelled product on a Thursday afternoon can result in a formal notice. An EHO is not looking for perfection — they are looking for evidence of a managed, documented system.

Managing Allergens Digitally

Paper-based allergen matrices create risk. They go out of date. They get lost. Staff refer to the wrong version. There is no audit trail.

Forkto’s allergen management tools let you build and maintain your allergen records digitally — tracking each product, its ingredients, and which of the 14 allergens apply. When something changes, you update it in one place. When an EHO visits, you have a clean, time-stamped record of exactly when information was reviewed and by whom.

Combined with digital checklists and delivery logging, Forkto gives you the traceability chain that EHOs expect to see: from supplier delivery, through production, to the label on the product.

A Quick Natasha’s Law Compliance Checklist

Use this to audit your own operation:

  • Have I identified every product I sell that is PPDS?
  • Does every PPDS product have a label with the product name, full ingredient list, and allergens emphasised?
  • Is my allergen matrix up to date and does it reflect exactly what I am currently using?
  • Do I have current supplier specifications confirming allergen content for all ingredients?
  • Do I have a process in place to update labels and allergen records when ingredients change?
  • Have all relevant staff received allergen awareness training?
  • If I sell food online or by phone for collection, am I providing allergen information before the order is placed and at delivery?
  • Can I trace the information on every label back through my records to a supplier specification?

If you answered no to any of these, that is your starting point.

The Bottom Line

Natasha’s Law is not a box-ticking exercise. It exists because a teenager died eating food she had every reason to believe was safe, and because the system at the time gave her no way to know otherwise.

The compliance requirements are not complicated. What trips businesses up is the consistency — keeping allergen records accurate, keeping staff informed, keeping labels up to date as menus evolve. That is an operational discipline, not a paperwork exercise.

If you want to make that discipline easier to maintain, take a look at how Forkto handles allergen management — it is built for exactly this kind of ongoing compliance work.