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Natasha’s Law & labelling PPDS food – free guidance UPDATE

14 Sep 2024
By: Safer Food Scores

Natasha’s Law has transformed food labelling requirements for thousands of food businesses across the UK. Introduced to improve allergen information for consumers, the legislation requires certain foods that are pre-packed for direct sale (PPDS) to carry a full ingredients list with allergens clearly emphasised.

To help businesses understand their responsibilities, Safer Food Scores has updated its free Natasha’s Law guidance, covering the key requirements, exemptions and practical compliance considerations.

What Is Natasha’s Law?

Natasha’s Law is the name given to changes introduced to the UK’s Food Information Regulations, which came into force on 1 October 2021.

The legislation was introduced following the tragic death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction after eating a baguette that did not display allergen information on its packaging.

The purpose of Natasha’s Law is to provide consumers with clearer allergen information and help people with food allergies make safer and more informed choices.

What Does Natasha’s Law Require?

Under Natasha’s Law, foods that are pre-packed for direct sale (PPDS) must be labelled with:

  • The name of the food.
  • A full ingredients list.
  • Allergens clearly emphasised within the ingredients list (usually in bold).
  • Any required additive declarations.
  • Relevant information regarding irradiated or genetically modified ingredients where applicable.

The legislation removed the previous exemption that allowed many PPDS foods to be sold without full ingredient labelling.

Which Businesses Does Natasha’s Law Apply To?

Natasha’s Law applies to any food business that prepares and packs food on the same premises from which it is sold or supplied.

Examples include:

  • Restaurants
  • CafĂ©s
  • Coffee shops
  • Takeaways
  • Bakeries
  • Butchers
  • Delicatessens
  • Street food vendors
  • Schools and colleges
  • Nurseries
  • Care homes
  • Workplace canteens

If your business prepares and packages food before the customer selects or orders it, Natasha’s Law may apply.

Which Foods Are Covered by Natasha’s Law?

Natasha’s Law applies to foods that are classified as Pre-Packed for Direct Sale (PPDS).

A food is generally considered PPDS when:

  • It is packed on the same premises where it is offered or sold.
  • It is packaged before the customer selects or orders it.
  • The packaging encloses the food so that it cannot be altered without opening or changing the packaging.

Examples may include:

  • Sandwiches packaged in a cafĂ©.
  • Salads prepared and packaged for display.
  • Cakes boxed before sale.
  • Grab-and-go products displayed in chilled units.

What Is the Definition of Pre-Packed Food?

For Natasha’s Law purposes, food is considered pre-packed when it is enclosed in packaging, either fully or partially, in such a way that the contents cannot be changed without opening or altering the packaging.

The packaging may include:

  • Wrappers
  • Boxes
  • Pots
  • Bags
  • Containers with lids

The key consideration is whether the food was packaged before the customer selected or ordered it.

Which Foods Are Exempt from Natasha’s Law?

Certain foods do not fall within the PPDS category and therefore are not covered by Natasha’s Law.

Examples include:

Food Packed After Ordering

Food packaged only after a customer places an order is not PPDS.

Examples include:

  • Takeaway meals packed to order.
  • Freshly made sandwiches prepared after ordering.
  • Bakery items placed into bags at the point of sale.

Food Supplied to Another Business

Food packed by one business and supplied to another business is not PPDS. However, full food information requirements may still apply.

Distance Selling

Foods ordered through websites, apps or telephone ordering systems are subject to separate allergen information requirements rather than Natasha’s Law.

How Do You Comply with Natasha’s Law?

To comply with Natasha’s Law, businesses should:

Review Products

Identify which products meet the definition of PPDS.

Gather Accurate Ingredient Information

Maintain up-to-date specifications for all ingredients and suppliers.

Produce Compliant Labels

Ensure labels include:

  • Food name.
  • Full ingredients list.
  • Clearly highlighted allergens.
  • Any other mandatory declarations.

Implement Change Controls

Whenever recipes, suppliers or ingredients change, labels should be reviewed and updated accordingly.

Train Staff

Employees involved in food production, purchasing and labelling should understand the requirements and know how to maintain accurate information.

What Is the Minimum Font Size for Natasha’s Law Labels?

Mandatory information must be printed in a font size that meets legal requirements.

The minimum x-height is:

  • 1.2 mm where the largest surface area of the packaging is 80 cm² or more.
  • 0.9 mm where the largest surface area is less than 80 cm².

For very small packages with a surface area below 10 cm², simplified requirements may apply, although allergen information must still be provided.

What Happens If You Do Not Comply?

Failure to comply with Natasha’s Law can result in enforcement action from Trading Standards or Environmental Health Officers.

Depending on the circumstances, enforcement may include:

  • Advice and guidance.
  • Improvement notices.
  • Formal enforcement action.
  • Product seizure.
  • Prosecution.

The most serious cases involve inaccurate allergen information where a consumer suffers an allergic reaction.

Such incidents can result in significant legal consequences, including unlimited fines and, in severe cases, imprisonment.

Common Natasha’s Law Compliance Mistakes

Food businesses frequently encounter problems when:

  • Recipes change without labels being updated.
  • Supplier specifications are incomplete.
  • Allergens are not correctly highlighted.
  • Staff create labels manually without verification.
  • PPDS foods are incorrectly classified as non-PPDS.

Regular label reviews and robust management controls can help reduce these risks.

Download Our Free Natasha’s Law Guidance

Safer Food Scores has updated its free Natasha’s Law guidance to help businesses understand their obligations and assess whether their current labels comply with legal requirements.

The guide covers:

  • PPDS food definitions.
  • Legal exemptions.
  • Mandatory labelling requirements.
  • Font size rules.
  • Common compliance mistakes.
  • Enforcement risks.

How Can Safer Food Scores Help?

Safer Food Scores provides food labelling reviews, nutritional analysis, allergen management support and Natasha’s Law compliance assessments.

Our experts can review your existing labels, assess recipes and ingredient specifications, identify compliance gaps and provide practical recommendations to help protect your customers and your business.

Contact us to find out how we can help you achieve Natasha’s Law compliance with confidence.

Any guidance given in our articles is not official and Safer Food Scores can take no responsibility if the information is used to form part of any legal or regulatory compliance for your business. However, please do get in touch if you are interested in our support services and would like to benefit from official guidance relating to your particular circumstances, email [javascript protected email address]

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