Allergens

Natasha's Law: Complete Guide to Allergen Labelling for Food Businesses

Natasha's Law changed allergen labelling for UK food businesses. Here's exactly what's required, who it affects, and how to label prepacked food correctly.

Allergen warning symbol with the 14 major food allergens displayed as tags

What is Natasha's Law?

Natasha's Law came into effect on 1 October 2021 in England, Wales, and Northern Ireland. Named after Natasha Ednan-Laperouse, who tragically died after eating a prepacked baguette containing sesame — an allergen not listed on the label — the law requires full ingredient lists and allergen labelling on all Prepacked for Direct Sale (PPDS) foods.

Before Natasha's Law, food businesses selling PPDS items were not legally required to display full ingredient lists. A simple "see counter for allergens" sign was considered sufficient. That changed on 1 October 2021.

What Foods Are Covered?

PPDS food is food that is packaged at the same place it is offered or sold to consumers, and is packaged before the customer orders or selects it. Common examples include:

  • Sandwiches, wraps, and baguettes made in-store and wrapped before sale
  • Sliced pies, pasties, and sausage rolls displayed in a cabinet
  • Salads in pots or containers prepared in the kitchen
  • Cakes and pastries wrapped or boxed before sale
  • Packs of deli items (cheese, meats) prepared on-site
  • Packs of sushi made fresh that morning
  • Ready meals prepared by a caterer and sold in a farm shop

What is NOT PPDS?

The following are not PPDS and have different labelling requirements:

  • Food sold loose — e.g., a bakery handing a croissant over the counter directly. Allergen information must still be provided but can be given verbally (with written backup available).
  • Food packed off-site — e.g., a branded packet of crisps. These must comply with EU FIC Regulation labelling rules (full ingredients list with allergens in bold).
  • Food ordered by the customer then packed — e.g., a Subway sandwich made to order. Not PPDS because the customer ordered it before it was packaged.

The 14 Major Allergens

UK food law identifies 14 allergens that must be declared when present in food. These are:

  1. Cereals containing gluten (wheat, rye, barley, oats)
  2. Crustaceans (prawns, crabs, lobster)
  3. Eggs
  4. Fish
  5. Peanuts
  6. Soybeans
  7. Milk
  8. Tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, pistachios, Brazil nuts, macadamia nuts)
  9. Celery
  10. Mustard
  11. Sesame
  12. Sulphur dioxide / sulphites (above 10mg/kg or 10mg/L)
  13. Lupin
  14. Molluscs (mussels, oysters, squid)

What Must Appear on the Label?

A PPDS label must include:

  1. The name of the food — e.g., "Chicken and Sweetcorn Sandwich"
  2. A full ingredients list — listed in descending order of weight
  3. Allergens emphasised — allergens must be clearly distinguished, typically in bold within the ingredients list

Example label:

Chicken and Sweetcorn Sandwich
Ingredients: Wheat Flour (contains Gluten), Chicken Breast (25%), Sweetcorn (15%), Mayonnaise (Rapeseed Oil, Egg Yolk, Vinegar, Salt, Sugar), Water, Yeast, Salt, Milk Powder.

Common Compliance Mistakes

  • Not updating labels when recipes change — If a chef swaps a supplier and the new ingredient contains a different allergen, labels must be updated immediately.
  • Generic "may contain" statements — While precautionary allergen labelling (e.g., "may contain nuts") is sometimes necessary, it should not be used as a substitute for proper kitchen controls. Overuse erodes trust.
  • Handwritten labels with missing information — Every PPDS item needs the full three-part label. Handwritten labels that skip ingredients or allergen emphasis are non-compliant.
  • Pre-labelling with outdated allergen info — Labels printed weeks in advance may not reflect current recipes or supplier changes.
  • No written allergen information for non-PPDS food — Even for food sold loose (not PPDS), you must have allergen information available for customers. This can be written on a menu, a chart, or a folder at the counter.

Penalties for Non-Compliance

Local authorities enforce Natasha's Law through Environmental Health Officers. Non-compliance can result in:

  • Improvement notices requiring immediate changes
  • Prosecution with fines of up to £5,000 per offence
  • Criminal prosecution for serious allergen incidents under food safety legislation
  • Reputational damage and loss of customer trust

How to Stay Compliant

  1. Build an allergen matrix — Create a master document listing every product and which of the 14 allergens it contains. Update it every time a recipe or ingredient changes.
  2. Train all staff — Every team member who handles food should understand the 14 allergens, how to read labels, and what to do when a customer asks about allergens.
  3. Use a labelling system — Digital tools can generate compliant labels automatically from recipe data, reducing the risk of human error.
  4. Cross-reference suppliers — Check every new ingredient against your allergen matrix before adding it to a product.
  5. Audit regularly — Review your labels, allergen matrix, and staff knowledge at least quarterly.

How SmartHaccp Helps with Allergen Compliance

SmartHaccp includes a built-in allergen management module. You can define ingredients, map allergens to products, and maintain a living allergen matrix that updates automatically when recipes change. Staff can access allergen information instantly, and you can generate compliance reports for EHO inspections.

Start your free 14-day trial and simplify your allergen compliance today.

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