PPDS Labelling for Caterers: What Natasha's Law Means for Your Business

What is PPDS?

PPDS stands for pre-packed for direct sale. It applies to food that is packaged at the same place it is sold to the customer, before the customer selects or orders it. For caterers, this typically includes:

• Wrapped sandwiches made and sold at a market stall
• Boxed salads or meals prepared for a deli counter
• Pre-portioned desserts in sealed containers at a food event
• Packaged platters assembled on-site and sold directly

PPDS does not include food that is freshly prepared to order (a dish cooked and plated for a sit-down dinner) or food that is packed at a different premises from where it is sold (that is classified as pre-packed and has separate requirements).

The distinction matters because PPDS food triggers specific labelling obligations under what is commonly known as Natasha's Law.

What Natasha's Law requires

The Food Information (Amendment) (England) Regulations 2019 — known as Natasha's Law — came into force on 1 October 2021. It requires that all PPDS food carries a label with:

1. The name of the food
2. A full ingredients list
3. Allergens emphasised within the ingredients list (typically in bold)

Before this law, PPDS food was exempt from ingredient labelling. The change was introduced following the death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction to a Pret A Manger baguette that did not carry allergen labelling.

Equivalent regulations apply in Scotland, Wales, and Northern Ireland. The allergen list and labelling requirements are the same across the UK.

The 14 allergens you must declare

UK food allergen regulations specify 14 allergens that must be declared. These are listed in FSA allergen guidance for food businesses:

#	Allergen	Common sources for caterers
1	Celery	Stocks, soups, salads, celeriac
2	Cereals containing gluten	Wheat flour, breadcrumbs, pastry, rye, barley, oats
3	Crustaceans	Prawns, crab, lobster, crayfish
4	Eggs	Mayonnaise, quiche, cakes, pasta, meringue
5	Fish	Fish stock, Worcestershire sauce, some Asian sauces
6	Lupin	Some specialty flours and baked goods
7	Milk	Butter, cream, cheese, milk powder, some margarines
8	Molluscs	Mussels, oysters, squid, snails
9	Mustard	Mustard powder, sauces, dressings, marinades
10	Nuts	Almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts
11	Peanuts	Satay sauces, groundnut oil, some Asian dishes
12	Sesame	Sesame oil, tahini, hummus, some bread
13	Soybeans	Soy sauce, tofu, miso, soya flour, some vegetable oils
14	Sulphur dioxide and sulphites	Wine, dried fruit, some sausages, vinegar (above 10mg/kg or 10mg/L)

Some of these are not obvious. Fish appears in Worcestershire sauce. Celery is in many commercial stocks. Sulphites are in most wines. When you cost and plan a menu, you need to trace every allergen through every ingredient in every dish.

What does a PPDS label look like?

A compliant PPDS label must include:

Example — Chicken Caesar Wrap:

Chicken Caesar Wrap

Flour tortilla (wheat flour, water, vegetable oil, salt), chicken breast (chicken, salt, celery salt), romaine lettuce, Caesar dressing (rapeseed oil, water, egg yolk, mustard, Parmesan cheese (milk), lemon juice, garlic, anchovy paste (fish), salt, black pepper), Parmesan cheese (milk).

The allergens must be emphasised — bold is the most common method. The ingredients list must include every component, including sub-ingredients of compound ingredients.

How this applies to different types of catering

Market stall vendors

If you sell wrapped items at a market stall — sealed sandwiches, packaged cakes, bottled sauces — every item needs a PPDS label with a full ingredient list and emphasised allergens. This applies even if you made the item that morning at home and brought it to the market.

Private chefs and supper club operators

If you serve plated food at a client's home or a supper club, this is generally classed as non-prepacked food. You do not need to label individual dishes, but you must be able to tell customers which allergens are present in each dish — either verbally or by displaying allergen information (such as a printed allergen matrix).

Event caterers

If you provide buffet items in sealed containers or wrapped platters, these are PPDS and need labels. If you serve food directly from open dishes, it is non-prepacked and the verbal or written allergen information rule applies instead.

The line between PPDS and non-prepacked can be unclear. The FSA guidance states that if food is in packaging that a customer could reasonably believe to be the complete product (i.e., it looks sealed and ready to eat), it is likely PPDS.

Practical steps to get compliant

1. Audit your menu for allergens

Go through every recipe you serve. For each ingredient, check whether it contains any of the 14 allergens. Use the allergen matrix generator to build a visual chart of which allergens appear in which dishes.

2. Document your ingredients lists

For PPDS items, write out the full ingredients list for each product. Include sub-ingredients. Emphasise allergens. Store these lists so you can reprint labels when needed.

3. Set up a system for tracking changes

When you change a recipe or switch to a different brand of an ingredient, your allergen information may change. A packet of stock cubes from one brand may contain celery while another does not. Your records need to reflect what you actually use.

4. Print labels

Labels can be handwritten, printed on a standard printer, or produced using a label printer. There is no prescribed format — the requirements are about content (name, full ingredients list, allergens emphasised), not appearance.

5. Train anyone who handles food

Anyone preparing, packing, or serving food in your business needs to understand which allergens are present and how to communicate this to customers. For sole traders, this means maintaining your own knowledge. For caterers with staff, it means documented training.

What happens if you get it wrong

The FSA and local authority enforcement officers can inspect food businesses at any time. For PPDS labelling non-compliance, enforcement can range from informal advice for minor issues to formal action including improvement notices and, in serious cases, prosecution.

The more immediate risk is a customer having an allergic reaction. This can result in civil liability claims and, in the most severe cases, criminal prosecution under food safety legislation. Accurate allergen documentation is not just a regulatory box to tick — it is a duty of care.

Free tools for allergen tracking

• Allergen matrix generator — build a 14-allergen chart for your menu, print it for your kitchen or hand it to customers
• Catering cost per head calculator — cost your events with per-head pricing and margin

Each of the 14 allergens has hidden sources that frequently catch caterers out — celery in stock cubes, fish in Worcestershire sauce, sulphites in wine. Knowing where these appear in your ingredients is as important as tracking the obvious sources.

Sources

• FSA — Allergen guidance for food businesses
• The Food Information (Amendment) (England) Regulations 2019

This guide covers PPDS labelling requirements for UK caterers. It does not constitute legal advice. For definitive guidance on your specific situation, consult the FSA or your local authority environmental health team.