Natasha's Law: PPDS Labelling for Cafés and Restaurants

Which of your packed food needs a full ingredients label under Natasha's Law, what the label must show, and the central kitchen mistake that catches restaurant groups out.

Natasha's Law covers food that you pack on your own premises before a customer orders it, and then sell from those same premises. Think of the sandwiches wrapped at 7 a.m., the salad pots in the grab-and-go fridge, the brownies bagged up by the till. Since 1 October 2021, every one of those packs has needed a label showing the name of the food and a full ingredients list, with the 14 allergens emphasised, for example in bold.

The legal term is "prepacked for direct sale", or PPDS. Two neighbouring cases work differently. Food made and wrapped after the customer orders doesn't need a PPDS label. Food packed at your central kitchen and sent to another of your sites needs more than a PPDS label: it needs full prepacked labelling. That second case is where restaurant groups most often get it wrong.

The rules come from the Food Information (Amendment) (England) Regulations 2019. Wales, Northern Ireland and Scotland brought in matching rules on the same date.

Is it PPDS? The test

The FSA's technical guidance treats food as PPDS when it's packed before being offered for sale, by the same business that sells it to the customer, and sold:

on the same premises where it was packed,
on the same site, meaning a building complex such as a shopping centre or airport terminal, or
from moveable or temporary premises the business runs, such as a market stall, marquee or food van.

The packaging test matters too. The food has to be fully or partly enclosed, in packaging that can't be changed without opening it, and ready for sale.

Here's how that plays out in a typical café or restaurant:

Situation	PPDS?	What you need
Sandwiches made and wrapped in your kitchen, sold from your counter	Yes	Name and full ingredients list, allergens emphasised
Burgers wrapped and kept under a heat lamp before anyone orders	Yes	Same as above
Food made and wrapped after the customer orders	No	Allergen information available, as for any dish made to order
Unwrapped cakes on the counter, an open salad bar	No	Allergen information available, as for any dish made to order
Food packed at your central kitchen and sent to another branch	No, it's prepacked	Full prepacked labelling (see below)
Food sold for delivery	Not covered by PPDS labelling	Allergen information before the customer buys and again on delivery

For food that isn't PPDS and is made to order, see our guide to the 14 allergens and what restaurants must tell customers.

What the label must show

For PPDS food, the label needs:

The name of the food.
A full ingredients list, with any of the 14 allergens emphasised within it. The FSA lists "bold type, capital letters, contrasting colours or underlined text" as ways to do that. Bold is what most businesses use.

The label can be printed on the package or attached to it. Where the largest surface of the pack is 80 cm² or more, the text has to be big enough to read: an x-height of at least 1.2 mm. Very small packs, with a largest surface under 10 cm², are exempt from the ingredients list.

Every ingredient counts, including the ones inside other ingredients. If the mayonnaise in a sandwich contains egg and mustard, both go on the label. That's the step that fails when a supplier changes a recipe and nobody updates the label.

The central kitchen trap

Plenty of restaurant groups make sandwiches, salads or desserts at a central kitchen and send them out to every site. That food isn't PPDS, because it isn't sold from the premises where it was packed. In the FSA's words, food "packed at a different site to where it is offered to consumers … is not PPDS food, but it still requires a label with a name, ingredients list, allergens and other mandatory details."

Those "other mandatory details" are the full prepacked list from the FSA's packaging and labelling guidance: net quantity, a date mark, storage conditions, a UK business name and address, and a nutrition declaration, on top of the name and ingredients. A sticker that's fine for a café's own sandwiches isn't enough for the same sandwich trucked across town.

The FSA hasn't published a worked example for "another branch of the same chain". Its definition turns on the food being packed where it's sold, though, so that's the reading we'd plan around. There's one exception. Units within the same building complex, such as two outlets in the same station or hospital, can count as the same site.

If you're setting up a commissary, our guide to central kitchen operations covers the rest of the handover.

Where it goes wrong

Testing shows PPDS labelling still fails often. In FSA sampling reported in Our Food 2023, 17 of 47 PPDS foods had an undeclared allergen. The failures were "restricted to smaller food businesses", and many came down to labels or ingredients lists that were missing altogether.

In our experience, the label itself is rarely the problem. The process behind it is:

A supplier changes a product, and the spec sheet nobody read now lists sesame.
The kitchen runs out of one brand of pesto and uses another for one morning.
Last month's label stock is still in the drawer after a recipe change.
A handwritten label made in a rush leaves out the dressing.

The FSA's own allergen checklist asks businesses to have a way to "approve, record and report" ingredient substitutions. That one control prevents most of the list above.

Enforcement

Councils enforce PPDS labelling. An officer can serve an improvement notice for a missing or incomplete label, and failing to show allergens on PPDS food is a criminal offence. The FSA's technical guidance notes that the fine on conviction is "potentially unlimited". Scotland's councils enforce it as part of their routine risk-based inspections.

A labelling routine that holds up

One master recipe per product, built from the current supplier spec sheets. The label is printed from the recipe, never typed fresh.
No substitution without sign-off. If an ingredient changes, someone with authority approves it, records it, and reprints the label before the first pack goes out.
Check labels at opening. Pick three products, compare the label with the recipe, and bin old label stock after any change.
Train everyone who packs food, at least once a year. The FSA's free allergen training is a good baseline.
Not sure whether something needs a label? Use the FSA's labelling decision tool.

Allergen controls also feed into the confidence in management score of your food hygiene rating.

This guide explains the PPDS labelling rules. It isn't legal advice. Your council's food team or trading standards can advise on specific products.