PPDS food labelling in the UK (Natasha's Law)

Food prepacked for direct sale must carry its name and a full ingredient list with the allergens emphasised, directly on the pack or on a label attached to it, in England, Scotland, Wales and Northern Ireland since 1 October 2021. What the duty covers, what the label needs, and the small-pack rule.

The two duties, in all four UK nations

In England, regulations 5A and 6A of the Food Information Regulations 2014 require a food business operator who offers food prepacked for direct sale to provide, directly on the package or on a label attached to it, the name of the food (regulation 6A) and the list of ingredients with the allergens (regulation 5A). Both were inserted by the Food Information (Amendment) (England) Regulations 2019 (SI 2019/1218) and came into force on 1 October 2021; both were substituted in their current wording by SI 2022/481, in force from 19 May 2022.

Scotland, Wales and Northern Ireland made the same two duties in their own instruments: the Food Information (Scotland) Amendment Regulations 2021 (SSI 2021/70), the Food Information (Wales) (Amendment) (No. 2) Regulations 2020 (SI 2020/295) and the Food Information (Amendment No. 2) Regulations (Northern Ireland) 2020 (SR 2020/80). Each took effect on 1 October 2021. The duties are widely known as Natasha's Law; the legislation itself does not use that name.

What “prepacked for direct sale” means

The 2014 Regulations give the term the meaning it has in Article 2(2)(e) of the assimilated Regulation 1169/2011, which takes “foods packed on the sales premises at the consumer's request or prepacked for direct sale” out of the definition of prepacked food. Those are two different categories: food packed because a customer ordered it is not PPDS, and the PPDS duties do not reach it.

The legislation does not define the term further. Where a product sits near the boundary, confirm it with your local authority's food team before you print. Both duties apply to a sale to the final consumer or to a mass caterer; the on-pack requirement does not apply where the offer for sale is made by distance communication, such as an online or telephone order (regulations 5A(2) and 6A(3)). The allergens are still owed at a distance: Article 14(2) of the assimilated Regulation applies Article 44, which makes them mandatory for this food, so they must be available before the purchase is concluded and at the moment of delivery.

The ingredient list

Regulation 5A brings in the ingredient-list rules of the assimilated Regulation: Article 9(1)(b) read with Article 18 and Annex 7, so the ingredients are listed in descending order of weight and compound ingredients and additives are designated as on a prepacked label; ingredient names follow Article 17 and Annex 6; Articles 19(1) and 20 say when a list or a constituent may be left out; and the presentation and legibility rules of Article 13(1) to (3) apply.

Regulation 5A does not bring in Article 22, the general quantity declaration (QUID). Meat is the exception: in all four nations, regulation 7 of the 2014 Regulations requires food prepacked for direct sale that contains meat and any other ingredient to declare the quantity of its meat ingredients (Article 9(1)(d), read with Article 22 and Annex 8), on a label attached to the food or on a notice, ticket or label readily discernible where the customer chooses it. The regulation excludes the foods in its own schedule and, in terms that differ slightly between the nations, food a mass caterer sells as part of that business.

Allergens: named and emphasised

Article 21(1) applies in full: each of the 14 substances or products in Annex 2 is named in the ingredient list with a clear reference to its name as Annex 2 lists it, and that name is emphasised “through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour”. Where several ingredients come from one allergen, the label makes that clear for each of them.

There is one relief: the allergen need not be indicated where the name of the food clearly refers to it. In England a failure on the allergen part of regulation 5A is a criminal offence (regulation 10(1)(c)); the rest is enforced through improvement notices under the Food Safety Act 1990.

Very small packs

On a package or container whose largest surface is less than 10 cm², Article 16(2) lets the list of ingredients be provided by other means or made available on request. Regulation 5A applies that relief only to the ingredient list, so the allergens stay on the pack: in the absence of an ingredient list, Article 21(1) requires the word “contains” followed by the allergen's name.

How LabelYog builds it

LabelYog writes the UK ingredient declaration from your recipe: ingredients in weight order, compound ingredients broken down, and the 14 allergens recognised and emphasised in the declaration, the same engine that builds a full UK prepacked label. Print it on the pack or on an attached label, check the boundary questions with your local authority, add the meat percentage where regulation 7 applies, and you have the PPDS particulars from one recipe.

At a glance

• Name of the food on the pack or an attached label (regulation 6A)
• Full ingredient list in descending order of weight (Article 18)
• Each of the 14 Annex 2 allergens named and emphasised by font, style or background colour (Article 21(1))
• The allergen made clear for every ingredient that comes from it
• Meat and any other ingredient? The meat percentage on the label or a notice (regulation 7)
• Directly on the package or on a label attached to it, not on a shelf card
• Under 10 cm²: ingredients by other means, but “Contains” plus the allergens still on the pack
• The same duties in England, Scotland, Wales and Northern Ireland since 1 October 2021

Questions

You can try the free tools without an account, read what a paid plan adds on pricing, or see how we compare with other label software before deciding anything. Every market we build for has a rule-book page of its own.