Natasha's Law and PPDS Labelling: A Guide for Small Bakeries and Delis

Natasha’s Law came into force in October 2021, named after Natasha Ednan-Laperouse, who died after eating a baguette from a Pret a Manger outlet that contained sesame not listed on the packaging. It changed what small bakeries and delis are legally required to put on a label — and unlike a lot of food law, there is no small business exemption. If you package food on your premises before a customer orders it, this applies to you, whether you’re a two-person village bakery or a national chain.

I’ve watched this land unevenly across small food businesses. Some independent bakeries adapted fast and now have some of the clearest labelling I’ve seen anywhere; others are still relying on a “may contain nuts” sticker that doesn’t come close to meeting the requirement. This is a plain-English guide to what the law actually asks for, from someone who reads every label before buying.

What counts as PPDS food

Prepacked for Direct Sale (PPDS) food meets three conditions, and it’s genuinely all three:

1. It’s in packaging of some kind — a bag, box, film wrap, or sealed container.
2. It was packaged before the customer selected or ordered it.
3. It’s being sold from the same premises where it was packaged.

That covers far more of a typical bakery or deli’s stock than most owners initially assume: loaves bagged before opening, pastries sealed in cellophane on the counter, sandwiches made that morning and put in the chiller, boxed cakes, pre-portioned soup pots, and even free samples that have been wrapped in advance. If a customer picks it up already packaged, it’s very likely PPDS.

What isn’t PPDS: food made to order in front of the customer (a sandwich built while they wait), food sold completely loose and unwrapped, and food delivered to someone from a different premises to where it was made. Those still carry allergen information duties under separate regulations — you must be able to provide accurate allergen information on request — but they don’t need the same physical label.

What the label actually has to show

Every PPDS item needs, directly on the packaging, before it’s offered for sale:

• The name of the food — a genuine description, not just a brand name.
• A full ingredients list, in descending order by weight, with compound ingredients broken down into their actual sub-ingredients rather than left as a generic term.
• All 14 major allergens emphasised within that list — typically in bold, though capitals, underlining, or a contrasting colour are also accepted, as long as the emphasis is clearly visible.

The 14 allergens are celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya, and sulphur dioxide/sulphites above a set concentration. A “may contain nuts” sticker with no ingredients list underneath it does not meet this requirement — Natasha’s Law replaced exactly that kind of vague precautionary label with a mandatory full ingredients breakdown.

Minimum text size matters too: the x-height (roughly the height of a lowercase “x” in your chosen font) needs to be at least 1.2mm, dropping to 0.9mm only on very small packaging under 80cm² of surface area. A label that’s technically present but unreadable without a magnifying glass isn’t compliant in spirit, even if it ticks a box on paper.

Where small bakeries and delis get caught out

The most common failure isn’t malice — it’s compound ingredients. Sesame baked into a dough, milk powder in a bread improver, soya lecithin in a margarine or chocolate — these often sit two or three layers deep in a recipe and get missed because nobody traces the ingredient back to its own label. This is precisely the type of hidden allergen that led to Natasha’s death, so it’s worth treating supplier ingredient sheets as essential reading, not paperwork to file away.

Recipe drift is the second big one. A supplier changes their flour blend, a new member of staff swaps an ingredient without telling anyone, or a seasonal special gets added without a label being created for it. Every SKU needs its own label reflecting the recipe as it’s actually made that week — not the recipe as it was written six months ago.

Free samples trip people up too. If you’re handing out a pre-wrapped sample of a cake or bread, it counts as PPDS in the same way as the full-price item, even though no money is changing hands for it directly.

A practical way to stay on top of it

You don’t need expensive software to comply, though it becomes more valuable as your product range grows. What you do need is a system:

• One ingredients record per product, kept up to date the moment a supplier or recipe changes — not retrospectively when someone notices.
• A checking step before any new product goes on sale, where someone actually reads every sub-ingredient’s own packet, not just the finished recipe.
• A print-before-pack rule — the label goes on before the item is offered for sale, not stuck on afterwards or handed over separately on a card.
• A recall plan for a labelling error — if you discover a mistake after items have gone out, know in advance how you’ll withdraw stock and who you’ll tell.

Tie this into your wider allergen matrix if you have one for eat-in items, so the labelling data and the verbal allergen advice you give customers always match. A bakery that tells a customer a muffin is nut-free at the till, while the wrapper doesn’t emphasise almonds in the ingredients, has a serious inconsistency that a customer with allergies — or an inspector — will notice.

Enforcement and what’s coming next

Environmental Health Officers check PPDS compliance as part of routine food safety inspections, and self-reported compliance is lower among restaurants and cafés than it is among bakeries and butchers, according to industry surveys — which suggests dedicated food-production businesses have generally taken this more seriously than menu-based ones. It’s worth staying ahead of the curve rather than waiting to be caught behind it.

Separately, proposals often referred to as Owen’s Law — named after Owen Carey, who died after a reaction to buttermilk in chicken described only as “grilled” on a menu — would extend written allergen requirements to restaurant menus at the point of ordering, closing the loophole that currently allows purely verbal allergen information for made-to-order food. It hasn’t yet become law, but it’s a clear signal of the direction UK allergen regulation is heading, and any bakery or deli that also runs a small eat-in counter should keep an eye on it.

Frequently asked questions

Does Natasha’s Law apply to a tiny bakery that only sells locally? Yes. There is no exemption based on business size, turnover, or number of staff — if you produce and sell PPDS food, the law applies in full.

What if I sell at a farmers’ market rather than a fixed shop? It still applies, provided the food was packaged at the same place it’s being sold — that includes market stalls where you pack and sell from the same pitch.

Can I just write “contains nuts” instead of a full ingredients list? No. A short allergen-only statement doesn’t meet the requirement — you need the full ingredients list with allergens emphasised within it, not a standalone warning in place of it.

Is home-baked food sold online covered by Natasha’s Law? If it’s packaged before being ordered and sold from where it was made, yes — home bakers selling online or at events are explicitly included, with no small-business exemption.

What should I do if I find a labelling mistake after stock has already gone out? Withdraw the affected stock as soon as you can and be straightforward with any customers who may have bought it, particularly if the missed allergen is one of the 14 major ones. Treat it the same way you would any other food safety incident.