Natasha's Law: Allergen Compliance Guide for Food Businesses
What Is Natasha's Law?
Natasha's Law — formally the Food Information (Amendment) (England) Regulations 2019, with equivalent legislation in Wales, Scotland, and Northern Ireland — came into force on 1 October 2021. Named after Natasha Ednan-Laperouse, who died from an allergic reaction to a Pret A Manger baguette in 2016, the law requires all food that is prepacked for direct sale (PPDS) to carry a full ingredients list with the 14 major allergens clearly emphasised.
Before Natasha's Law, PPDS food only needed to have allergen information available on request. The new law requires this information to be physically present on the packaging, making it immediately visible to consumers without needing to ask. This is a significant change for businesses that make and package food on their premises for direct sale.
What Counts as Prepacked for Direct Sale (PPDS)?
PPDS food is food that is packaged at the same premises where it is sold, before the consumer selects it. This includes sandwiches made and wrapped in a shop for customers to pick up, salads packaged in containers for self-service, baked goods wrapped for display, boxed meals prepared for collection, and any food packaged before a specific customer orders it.
PPDS does not include food packaged for a specific customer after they order it (this is "made to order" and has different requirements), food packaged at a different premises from where it is sold (this is "prepacked" and was already covered by existing labelling rules), or loose food sold without packaging (allergen information must still be available but does not need to be on a label).
The distinction matters because it determines which labelling requirements apply. If you are unsure whether your food is PPDS, the FSA provides detailed guidance and a decision tool on their website.
The 14 Major Allergens
UK law identifies 14 allergens that must be declared on food labels and made available to consumers. These are celery, cereals containing gluten (wheat, rye, barley, oats), crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts (almonds, hazelnuts, walnuts, cashews, pecans, brazils, pistachios, macadamia), peanuts, sesame, soybeans, and sulphur dioxide (at concentrations above 10mg/kg).
On PPDS labels, these allergens must be emphasised in the ingredients list using bold, italics, underlining, or a different colour — consistently throughout the label. The allergen name must appear as it is listed in the legislation (for example, "wheat" rather than just "flour").
How to Comply
Step 1: Audit your products. List every PPDS item you sell and document its full ingredients, including sub-ingredients. A cheese sandwich requires listing the ingredients of the bread, butter, cheese, and any garnishes. If you use pre-made components (such as bought-in bread), obtain the full ingredient specifications from your supplier.
Step 2: Create labels. Every PPDS item must have a label showing the product name and a full ingredients list with allergens emphasised. The label must be physically attached to or clearly associated with the food. Handwritten labels are acceptable if they are legible and complete, though printed labels are strongly recommended for consistency.
Step 3: Manage ingredient changes. If you change a recipe or supplier, update your labels immediately. An out-of-date label is worse than no label — it provides false assurance. Implement a process for reviewing labels whenever ingredients change.
Step 4: Train your staff. All staff involved in preparing, packaging, or selling PPDS food must understand the labelling requirements. They should know which products contain which allergens, how to respond to allergen queries, and what to do if a labelling error is discovered. Document all training with dates and signatures.
Step 5: Prevent cross-contamination. Labelling is only effective if the food actually contains what the label says. Implement procedures to prevent cross-contamination during preparation: separate equipment for allergen-free items, cleaned surfaces between preparations, and clear workflows that minimise allergen transfer.
Allergen Management Beyond PPDS
Even for food that is not PPDS, UK law requires you to provide allergen information to customers. For loose food (served without packaging), you must be able to tell customers which of the 14 allergens are present in each dish. This information can be provided verbally, on a menu, on a chalk board, or through any other clear method — but it must be available and accurate.
Create an allergen matrix for your full menu. This is a grid showing each dish against each allergen, with clear markings for "contains", "may contain" (for cross-contamination risks), and "does not contain". Display this matrix where staff can reference it and where customers can see it. Update it whenever your menu changes.
Enforcement and Penalties
Allergen labelling is enforced by local authority Environmental Health Officers and Trading Standards Officers. Non-compliance can result in an improvement notice (requiring you to fix the issue within a specified timeframe), a fixed penalty notice, and in cases where non-compliance causes harm, prosecution under the Food Safety Act 1990 or the Food Information Regulations 2014.
More practically, allergen compliance is assessed as part of your food hygiene inspection. Poor allergen management will lower your confidence in management score, directly reducing your FHRS rating. Given that allergen management demonstrates proactive food safety management, strong compliance can actually improve your overall rating.
Impact on Your Food Hygiene Rating
Environmental Health Officers now routinely assess allergen management during food hygiene inspections. They will ask about your allergen procedures, check your allergen information provision, and may quiz staff on their allergen knowledge. Businesses that demonstrate strong allergen management — clear labelling, maintained allergen matrices, trained staff, and documented procedures — signal the kind of proactive management that inspectors reward with higher confidence in management scores.
Conversely, businesses with poor allergen management face both lower FHRS ratings and potential enforcement action. This makes allergen compliance a double priority: it protects your customers and it protects your rating.
Getting Started
If you are not currently compliant with Natasha's Law, start with an audit of your PPDS products and create accurate labels. Then build your allergen matrix for all menu items and train your staff. The FSA provides free resources, templates, and guidance at food.gov.uk/allergen-guidance.
For a personalised improvement plan that includes allergen management alongside your other food safety priorities, check your rating at hygienefix.co.uk. Our action plans include allergen compliance steps tailored to your business type and inspection scores.