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Natasha’s Law and PPDS labelling
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Natasha’s Law is the name used for a change in allergen labelling on food that is packed before you choose it, by the same business that sells it to you. The Food Standards Agency’s technical guidance says the new rules came into effect across all four UK nations on 1 October 2021. From that date, this food, called prepacked for direct sale or PPDS, needs a label with the name of the food and a full ingredients list, with any of the 14 regulated allergens emphasised every time they appear. The Food Standards Agency is clear that the label should not replace a conversation about your allergy. This article is about reading that label, and about knowing when you are not looking at PPDS food at all.
Why the law has Natasha’s name
The Food Standards Agency’s announcement says the change followed the death of teenager Natasha Ednan-Laperouse, after an allergic reaction to a baguette she had eaten which did not display allergen information on the packaging. Before the change, some food made, packed and sold on the same premises did not have to show ingredient or allergy information on the product. The point of the law is that a person standing in front of that pack can read what is in it, without having to find a member of staff who might not know. We are not going to add details of her life beyond what that announcement says. The labelling duty is the part that changes a sandwich counter.
What counts as PPDS
PPDS food is packed before it is offered for sale, by the same food business, to the final consumer. The Food Standards Agency’s technical guidance describes that as food packed on the same premises, or on the same site, or packed by that business and sold from its moveable or temporary premises, such as a marquee, a market stall or a mobile vehicle. “Prepacked” means the food is in packaging, fully or partly, before it is offered for sale, and the contents cannot be altered without opening or changing the packaging.
GOV.UK’s guide for people eating out gives everyday examples: boxed sandwiches, or burgers wrapped up before you buy them. A cafe fridge of sandwiches made in that cafe that morning is the situation the law was written for. So is a burger wrapped and labelled before you point at it. You should see the name of the food and an ingredients list. Allergenic ingredients have to be emphasised, for example in bold, capital letters, a contrasting colour or underlining. The list should be headed as ingredients. If you cannot read the ingredients without opening the pack, the label is not doing the job the rules describe.
What is not a PPDS label
A meal cooked after you order, and served on a plate, is not PPDS food. GOV.UK separates three situations: food in a restaurant, a takeaway, and PPDS food such as boxed sandwiches. The restaurant meal still needs accurate allergen information. You might get it from a menu, or from a prompt that tells you to ask a member of staff. You can phone ahead and ask again when you arrive. Nobody has to cook you a different dish. They do have to be able to tell you about the 14 allergens in the dish they are selling. Our page on how to tell a restaurant is that conversation.
Loose food is a third category. A bakery, butcher or deli counter selling food that is not packed before you choose it has to provide allergen information for loose items that contain any of the 14. That information can be written or spoken. If it is spoken, there has to be a signpost to where you can get it. A roll filled while you wait is not the same legal object as a boxed sandwich packed that morning. Both still need an allergen answer. Only the boxed one needs the full ingredients list on the pack.
Distance selling has its own timing. If you order a takeaway, the business must tell you about the 14 allergens before you buy, on a website, a menu or the phone, and again when the food is delivered, in writing or from the person who hands it over. The Food Standards Agency’s technical guidance also notes that the full ingredients-list rule is about PPDS food you buy in person. Food sold only by phone, online or mail order follows the distance-selling rules on allergen information instead. If you are standing in the shop, look for the label. If you are ordering to a door, ask at both stages, and ask for your container to be marked if other people’s food is in the same bag.
How we read the label
We read the ingredients, not the front-of-pack marketing. A word such as “natural” or “fresh” is not an allergen statement. The allergens have to be emphasised inside the list, every time they appear, so a sauce that contains milk and a bread that contains wheat should each show those names in a way you can see. If the name of the food clearly refers to the allergen, such as a product simply called milk, the indication inside the list is not always required. We still read the rest of the list, because a product can contain a second allergen that the name does not mention.
Sesame, peanut, gluten, milk and egg are the ones we most often go looking for on a packed sandwich or a wrapped burger, which is why the guides for sesame, peanut, gluten, milk and egg sit next to this article. The label answers “is it an ingredient?”. It does not, on its own, answer every cross-contamination question. “May contain” remains voluntary. If you need to know about a shared slicer or a shared toaster, ask as well as reading. The Food Standards Agency says the PPDS label should not stop that conversation.
When the label is missing
If food looks as though it was packed on site before you chose it, and there is no ingredients list, ask a member of staff before you buy it. If they cannot tell you what is in it, we do not buy it. Missing or wrong allergen information is something you can report to the local authority food safety team. The steps are in how to report a restaurant that got your allergy wrong. A complaint about a refund is a different problem, and the Food Standards Agency points people with payment disputes to Citizens Advice rather than to the food safety team.
PPDS labelling also does not choose the restaurant for you. You can search for restaurants for a food allergy, or search on the SafePlate homepage, which is free, and then read the label or ask the kitchen when you arrive. In London, Bristol and Nottingham the city guides explain who handles food law locally. They do not certify a cafe fridge.
If you want the foods written down for a kitchen, the usable allergy chef card, in 38 languages, is part of SafePlate Plus. The allergy chef card page is a preview for everyone else. A preview can show you the kind of wording. It cannot be filled in as your card. And if you think someone is having anaphylaxis after eating, the label is no longer the priority. Call 999, and follow the NHS steps we have set out for a reaction in a restaurant.
Sources
Set up your foods before you search. This is not medical advice. Confirm the meal with the kitchen. In the UK, if you think someone is having anaphylaxis, call 999.