Sandwiches, salads, and anything else packaged on-site before a customer chooses it needs a full ingredients list with all 14 allergens clearly emphasized. Get this wrong and the consequences go well beyond an awkward inspection.
What Natasha's Law Actually Requires
Natasha's Law took effect on 1 October 2021, closing a labeling gap that had existed for food "prepacked for direct sale" (PPDS) — food made and packaged at the same premises where it's sold, before the customer selects or orders it: a sandwich made that morning and sealed in a display case, a salad box assembled behind the counter, a slice of cake wrapped and shelved. Before this law, PPDS food only needed a sign inviting customers to ask staff about allergens verbally. That gap proved fatal: the law is named after Natasha Ednan-Laperouse, who died at 15 after eating a Pret a Manger baguette containing sesame that wasn't declared on the packaging.
Under Natasha's Law, every PPDS item must display three things directly on the packaging: the name of the food, a full ingredients list in descending order by weight (with compound ingredients broken into their sub-ingredients), and all 14 legally recognized allergens emphasized within that list — typically in bold, capitals, or a contrasting typeface, consistently applied every time the allergen appears.
The 14 Allergens You Must Emphasize
Celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soybeans, and sulphur dioxide/sulphites (above 10mg/kg or 10mg/litre). If any of these — or an ingredient derived from them — is present, it must be emphasized in the ingredients list every time it appears, not just the first mention.
The March 2025 Update: Loose Food Is Catching Up
Natasha's Law itself only legally mandates written labeling for PPDS food. But in March 2025, the Food Standards Agency updated its guidance to actively encourage the wider out-of-home sector — restaurants serving loose, made-to-order food that doesn't meet the PPDS definition — to also provide written allergen information, rather than relying solely on verbal disclosure at the table. This followed further allergy-related deaths involving non-PPDS food where allergen information was communicated verbally and incompletely or inaccurately. While this guidance isn't yet a hard legal mandate the way PPDS labeling is, it signals the direction of travel — and a restaurant that already has a solid written allergen matrix for its loose menu is far better positioned if and when that guidance becomes a firmer requirement.
Getting the Labeling System Right
- Confirm which of your menu items actually meet the PPDS definition — the test is about when and where it was packaged relative to the customer's choice, not the food type itself.
- Build a master ingredients record for every recipe, including sub-ingredients of any compound ingredient (a sauce, a spice mix) rather than a single generic name.
- Choose one consistent emphasis method (bold is most common) and apply it identically across every label and every allergen.
- Update labels immediately whenever a recipe or supplier changes — a swapped supplier's sauce recipe is one of the most common ways an allergen quietly enters a dish without the label being updated.
- Extend the same rigor to your loose/non-PPDS menu items voluntarily, given the FSA's March 2025 guidance direction.
Our Allergen Menu Labeling Generator can map your ingredients against the UK's 14-allergen list and flag anything ambiguous.
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Sources
- Food Standards Agency — Allergen labelling for food businesses. food.gov.uk
- Royal Borough of Kensington and Chelsea — Allergens and labelling (PPDS / Natasha's Law summary). rbkc.gov.uk