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Kitchen deep cleaning - food law
Since Natasha's Law, food that is packaged on the premises before a customer orders it - prepacked for direct sale, or PPDS - must carry a full ingredients list with the 14 allergens emphasised. Getting that label right depends first on knowing what counts as PPDS, because the rule applies to some food and not other food sold in the same place. Here is what PPDS is, and how to label it.
The short answer
Prepacked for direct sale (PPDS) food is food that is packaged on the same premises from which it is sold, before the customer orders it - a sandwich made and wrapped in the morning and put on a shelf, a salad boxed ready to grab, a cake sliced and packaged for sale. Since Natasha's Law came into force (in October 2021), PPDS food must carry a label with a full list of ingredients, and within that list the 14 major allergens (where present) must be emphasised - in bold, capitals, underlining or a contrasting colour - so they stand out. This closed a gap: before the law, this kind of food did not have to carry full ingredient labelling, and the law is named after a young woman who died from an allergen (sesame) that was not listed on a pre-packaged sandwich. The key to applying the rule correctly is identifying what counts as PPDS, because whether food is PPDS depends not on what it is but on how it is packed and sold - and the same premises often sells PPDS food alongside food that is not PPDS, which is labelled differently. Food is PPDS if it is packaged before it is ordered, on the premises where it is sold. Food packed at the customer's request (made to order, or packed as they order) is not PPDS - it is handled like food sold loose, with allergen information given another way. Food packaged by someone else elsewhere and sold on (prepacked food from a supplier) is not PPDS either - it has its own manufacturer labelling. So within one deli or cafe, a pre-made wrapped sandwich on the shelf is PPDS (needing the full label), a sandwich made to order at the counter is not (allergen info given verbally or on a menu), and a branded packaged snack from a supplier is not (already labelled by its maker). Getting the labelling right therefore starts with correctly identifying which food is PPDS, and then giving that food the full ingredients list with the allergens emphasised that the law requires.
Key points
What PPDS is
Prepacked for direct sale food - PPDS - is defined by how it is packed and sold, not by what it is: it is food that is packaged on the same premises from which it is sold, before the customer selects or orders it. The typical picture is food a business makes and packages in advance, ready for customers to pick up: a sandwich made and wrapped in the morning and placed on a shelf or in a chiller, a salad boxed ready to grab, a cake cut and packaged for sale, a pasta pot filled and lidded ready to go. In each case the food is packaged before the customer orders it, on the premises where it is sold - and that is what makes it PPDS. The customer takes the already-packaged item; it was not made or packed in response to their order but prepared in advance and packaged ready.
This definition matters because it is precise and it is about the packing and selling, not the food itself. The same type of food can be PPDS or not depending on how it is handled: a sandwich packaged in advance and put on the shelf is PPDS, but a sandwich of the identical recipe made and wrapped when the customer orders it is not. So PPDS is not a category of food but a way food is prepared and sold - packaged, on-site, before ordering. Understanding this precise definition is the foundation of applying the allergen labelling rule correctly, because the rule attaches to PPDS food specifically, and identifying what is PPDS requires applying the definition to how each item is actually packed and sold, not judging by what the food is. A business needs to look at its range and work out which items are packaged in advance on-site (PPDS) and which are handled differently - because that determines which need the PPDS label.
What the label must show
For food that is PPDS, the labelling requirement under Natasha's Law is specific: the food must carry a label showing a full list of its ingredients, and within that list, the 14 major allergens - where they are present - must be emphasised so they stand out. So a PPDS label is not just a name and a use-by date; it is a full ingredients list, listing everything the food contains, with any of the 14 allergens highlighted within it. The emphasis can be done in various ways - bold type, capital letters, underlining, or a contrasting colour - the point being that an allergic customer scanning the label can see quickly whether their allergen is present, rather than having to read carefully through the whole list. So the two elements are the full ingredients list and the clear emphasis of the allergens within it.
This is a meaningful requirement because it gives the allergic customer the information they need to make a safe choice from a pre-packaged item they are picking up without being able to ask. Before the law, PPDS food did not have to carry this labelling, so an allergic customer picking up a pre-made sandwich had no reliable way to know its ingredients - which is the gap that led to a death and prompted the law. The full ingredients list with emphasised allergens closes that gap, giving the customer the same information they would get from a manufactured packaged food. So getting the PPDS label right means listing all the ingredients accurately (based on the actual recipe) and emphasising the 14 allergens clearly wherever they appear - so the label genuinely serves the allergic customer picking up the item. An incomplete ingredients list, or allergens not emphasised, fails the purpose, so the label has to be complete and the allergens clearly highlighted. This is the core of what PPDS labelling requires: the full ingredients, with the allergens made to stand out.
What is not PPDS
Because the same premises often sells PPDS food alongside food that is not PPDS, it is important to know what is not PPDS - because those other foods are handled differently and do not need the PPDS label. Two main categories are not PPDS. First, food packed at the customer's request - made to order, or packed as the customer orders it. A sandwich made and wrapped when the customer asks for it is not PPDS, because it was not packaged before the order; it is handled like food sold loose, with the allergen information given another way (verbally by staff, on a menu, or via an allergen guide) rather than on a full ingredients label. So made-to-order food, even if it ends up wrapped, is not PPDS as long as it was made and packed in response to the order.
Second, food that is prepacked elsewhere and sold on - packaged food from a supplier or manufacturer, sold as it came. A branded packaged snack, drink, or product that the business bought in already packaged is not PPDS; it already carries its manufacturer's labelling (including its own allergen information), so the business does not label it - it is sold as the manufacturer packaged it. So supplier-packaged food, already labelled, is not PPDS. The practical upshot is that within one deli, cafe or shop, different items are handled differently: a pre-made wrapped sandwich on the shelf is PPDS and needs the full ingredients label with emphasised allergens; a sandwich made to order at the counter is not PPDS and has its allergen information given verbally or on a menu; and a branded packaged snack from a supplier is not PPDS and carries its own manufacturer labelling. Getting the labelling right across the range therefore means correctly sorting the food into these categories - identifying which items are packaged in advance on-site (PPDS, needing the label), which are made to order (not PPDS, allergen info given another way), and which are supplier-packaged (not PPDS, already labelled). Misclassifying an item - treating a PPDS item as if it were not, and failing to label it - is the error the law exists to prevent.
Getting it right
Getting PPDS allergen labelling right is a two-step task: first identify which food is PPDS, then label that food fully and accurately. The identification step is where mistakes happen, because it requires applying the PPDS definition to how each item is actually packed and sold, rather than judging by what the food is. A business should look across its whole range and sort each item: is it packaged on-site before ordering (PPDS), packed at the customer's request (not PPDS, handled as made-to-order), or supplier-packaged and sold on (not PPDS, already labelled)? Getting this sorting right is essential, because the labelling requirement attaches to the PPDS items specifically, and any PPDS item not identified as such will not get the label it needs - which is exactly the failure the law targets.
Then, for the identified PPDS items, the labelling has to be done properly: a full, accurate ingredients list based on the real recipe, with the 14 allergens emphasised clearly wherever they appear. This depends on knowing the actual ingredients of each item (which requires accurate recipe information and awareness of what is in each component), and on keeping the labels current as recipes and ingredients change - a label that no longer matches the recipe is a wrong label. So the accuracy of the labelling depends on the accuracy of the underlying ingredient knowledge, which has to be maintained. Done properly, PPDS labelling gives allergic customers reliable information on the pre-packaged items they pick up, which is the whole point of the law. So the discipline is: correctly identify the PPDS food (the step where errors creep in), and then label it with a full, accurate, current ingredients list and clearly emphasised allergens. Both steps matter - a PPDS item missed at the identification stage gets no label, and a PPDS item with an inaccurate or unclear label gives wrong information - so getting the labelling right means getting both the identification and the labelling right.
The takeaway
Prepacked for direct sale (PPDS) food is food packaged on the premises from which it is sold, before the customer orders it - a sandwich made and wrapped and put on the shelf, a boxed salad, a packaged slice of cake. Since Natasha's Law, PPDS food must carry a label with a full ingredients list and the 14 major allergens emphasised within it (in bold, capitals, underlining or a contrasting colour) where present, so an allergic customer picking up the item can see quickly whether their allergen is there. This closed the gap that led to the law - PPDS food previously not having to carry full ingredient labelling.
Applying the rule correctly starts with identifying what is PPDS, because whether food is PPDS depends on how it is packed and sold, not what it is - and the same premises often sells PPDS food alongside food that is not. Food packed at the customer's request (made to order) is not PPDS - allergen information is given verbally or on a menu; food packaged elsewhere by a supplier is not PPDS - it carries its own manufacturer labelling. So within one cafe, a pre-made wrapped sandwich on the shelf is PPDS (needing the full label), a made-to-order sandwich is not, and a branded snack is not. Getting the labelling right therefore means two steps: correctly identify which food is PPDS (the step where errors creep in), and then give that food a full, accurate, current ingredients list with the allergens clearly emphasised. Both steps matter - a missed PPDS item gets no label, and a wrong label gives wrong information.
Questions
Prepacked for direct sale (PPDS) food is food that is packaged on the same premises from which it is sold, before the customer orders it. Typical examples are a sandwich made and wrapped in advance and placed on a shelf, a salad boxed ready to grab, or a cake sliced and packaged for sale - food prepared and packaged before the customer selects it, on the premises where it is sold. It is defined by how it is packed and sold, not by what it is: the same food can be PPDS or not depending on whether it was packaged in advance (PPDS) or made and packed to order (not PPDS). Since Natasha's Law, PPDS food must carry a full ingredients list with the 14 allergens emphasised, so identifying which of your food is PPDS is the first step to labelling it correctly.
A full list of ingredients, with the 14 major allergens emphasised within that list wherever they are present. So a PPDS label is not just a product name and a date; it lists everything the food contains, and highlights any of the 14 allergens so they stand out - in bold, capitals, underlining, or a contrasting colour. The purpose is to let an allergic customer picking up the pre-packaged item see quickly whether their allergen is present, without being able to ask. So the two requirements are the full, accurate ingredients list and the clear emphasis of the allergens within it. Both matter: an incomplete list or allergens not emphasised fails the purpose. The ingredients must be accurate to the actual recipe, and the label kept current as recipes change, because a label that no longer matches the food gives wrong information.
No. A sandwich made and wrapped when the customer orders it is not PPDS, because it was not packaged before the order - it was made and packed in response to the order. Made-to-order food is handled like food sold loose: the allergen information is given another way (verbally by staff, on a menu, or via an allergen guide) rather than on a full ingredients label. PPDS is specifically food packaged in advance, before the customer orders. So the same sandwich can be PPDS or not depending on how it is handled: made and wrapped in the morning and put on the shelf, it is PPDS and needs the full label; made and wrapped when the customer asks, it is not PPDS and its allergen information is given verbally or on a menu. The distinction is whether it was packaged before or in response to the order.
No - food that is prepacked elsewhere by a supplier or manufacturer and sold on is not PPDS, because it already carries its manufacturer's labelling, including its own allergen information. A branded packaged snack, drink or product that you bought in already packaged is sold as the manufacturer packaged it, and you do not add a PPDS label to it. So within your range, supplier-packaged items are not PPDS - they are already labelled by their maker. PPDS is specifically food you package on your own premises before it is ordered. So you sort your range: items you package in advance on-site are PPDS and need your full ingredients label; made-to-order items are not PPDS (allergen info given another way); and supplier-packaged items are not PPDS (already labelled by the manufacturer). Only the PPDS items need you to produce the full ingredients label.
Because whether food is PPDS depends on how it is packed and sold, not on what it is - so it requires applying the definition to how each item is actually handled, rather than judging by the food itself. The same premises often sells PPDS food alongside food that is not (made-to-order and supplier-packaged), and the same type of food can fall into different categories depending on how it is prepared. So a business has to look across its whole range and correctly sort each item: packaged in advance on-site (PPDS), packed to order (not PPDS), or supplier-packaged (not PPDS). This is where errors creep in, because it is easy to misjudge - and any PPDS item not identified as such will not get the label it legally needs, which is exactly the failure the law targets. So identifying the PPDS food correctly is the crucial first step, and the one that requires care.
It can leave an allergic customer without the information they need to eat safely, with potentially serious consequences, and it is a breach of food law. The whole point of PPDS labelling is to give allergic customers reliable ingredient and allergen information on pre-packaged items they pick up without being able to ask - so a PPDS item that is not labelled, or is labelled with an incomplete or inaccurate ingredients list, or with allergens not emphasised, leaves that customer exposed to an allergen they were not warned about. This is the very situation the law was made to prevent, following a death from an unlabelled allergen. So incorrect PPDS labelling is not a minor administrative error but a food-safety failure that can cause serious harm, as well as a legal breach with consequences for the business. This is why both steps - identifying the PPDS food and labelling it fully and accurately - have to be got right.
Accurate labelling works alongside controlling allergen cross-contamination - our kitchen deep cleaning keeps surfaces and equipment clean, supporting the allergen management behind the label. Ask us about a deep clean.
