Natasha’s Law & Food Labelling: The Complete Guide for UK Multi-Site Operators (2026)

Natasha’s Law requires food that is prepacked for direct sale (PPDS) to carry the name of the food and a full ingredients list, with any of the 14 regulated allergens emphasised within that list. It has applied across the UK since 1 October 2021.

For multi-site operators the hard part is not the label. It is knowing that the recipe, the supplier specification, the training and the verification behind that label are current and consistent in every kitchen, every shift. This guide covers what the law requires, what counts as PPDS, where Owen’s Law sits in 2026, and how to run allergen compliance across a network.

Key Takeaways

• Natasha’s Law applies to PPDS food. Applicable products need the name of the food and a full ingredients list, with the 14 regulated allergens emphasised. In force since 1 October 2021.
• PPDS is not a type of food. It describes how food is packaged and sold. The same sandwich can be PPDS or not depending on whether it was wrapped before or after the customer ordered it.
• Owen’s Law is not law yet. The FSA published voluntary best practice guidance for non-prepacked food in March 2025, and the government began evaluating industry uptake in spring 2026. Weak voluntary adoption strengthens the case for legislation.
• For-sale labels and food prep labels do different jobs. One gives customers the information the law requires. The other supports shelf life, rotation and traceability inside the kitchen.
• Multi-site operators face an execution problem. Enforcement officers assess your systems and records, not your label printer.

What Is Natasha’s Law?

Natasha’s Law is the commonly used name for the allergen labelling requirements that apply to food prepacked for direct sale, usually shortened to PPDS. The requirements came into force on 1 October 2021.

Applicable PPDS food must display the name of the food, a full ingredients list, and any of the 14 regulated allergens used as ingredients clearly emphasised within that list.

The change followed the death of Natasha Ednan-Laperouse, who suffered a fatal allergic reaction in 2016 after eating sesame contained in a baguette that, under the rules at the time, did not have to carry a full ingredients label. The purpose of the legislation is to put potentially life-saving allergen information directly onto applicable packaged food.

“Natasha’s Law” is a campaign name rather than a statute. The requirements were introduced through four separate instruments, one for each UK nation, all amending the assimilated Food Information to Consumers Regulation.

What Counts as PPDS?

This is where operators most often get caught out, because PPDS is not a category of food. It describes how food is packaged and sold.

Broadly, food can be PPDS when it is packaged at the same place it is offered or sold, is packaged before the customer orders or selects it, and is presented to the customer in that packaging.

So a sandwich prepared and wrapped at 7am before being placed in a grab-and-go fridge is potentially PPDS. The same sandwich made and wrapped after a customer orders it is not. Same product, different process, different labelling requirements.

Food produced in a central production unit and delivered to sites is a third category. It is generally prepacked food rather than PPDS, and falls under wider labelling requirements that go beyond name and ingredients. A single brand can therefore be selling PPDS, prepacked and non-prepacked food across the same network at the same time.

Before classifying a product, ask four questions: when was it packed, who packed it, where was it packed, and how is it being offered for sale?

What Must Appear on a PPDS Label

For applicable PPDS food, the label needs the name of the food and a full ingredients list, with regulated allergens clearly emphasised. For example:

Chicken & Bacon Sandwich
Ingredients: Bread (WHEAT, BARLEY), chicken, mayonnaise (EGG, MUSTARD), bacon, lettuce.

The allergen has to stand out genuinely from the rest of the ingredients. Bold is common, but capitals, underlining, italics or a contrasting colour can also be used. Emphasis only works if it is distinguishable. A bold ingredients list with bold allergens achieves nothing.

It is also not enough to add a separate “Contains: egg, mustard, gluten” statement instead of supplying the required ingredients information. The allergen declaration has to work within the ingredients information that PPDS food requires.

The 14 regulated allergens

Celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, peanuts, sesame, soybeans, sulphur dioxide and sulphites above the applicable threshold, and tree nuts.

Where the law requires specificity, vague descriptions are not enough. Do not rely on “nuts” when the relevant nut should be identified, or on “cereals” when the specific grain matters.

💡 Download: Our free Food Allergen Matrix template gives you a structured way to map allergens across your menu before you start building labels. An accurate matrix is the foundation everything else sits on.

What About Non-Prepacked Food, and Where Does Owen’s Law Fit?

Natasha’s Law did not remove your obligations for food that is not prepacked. Allergen information still has to be available and accurately communicated for loose items, food made to order and food served at the table, and customers must be told clearly how to obtain it.

What has changed is the expectation around how that information is provided.

In March 2025 the Food Standards Agency published best practice guidance on allergen information for non-prepacked foods. The headline recommendation is that written allergen information for the 14 regulated allergens should always be available, supported by a conversation between staff and the customer. The guidance applies to businesses operating in England, Wales and Northern Ireland, and it explicitly does not cover PPDS food, which has its own rules. Businesses in Scotland should refer to Food Standards Scotland.

That guidance is voluntary. You cannot currently be prosecuted for not following it.

Why 2026 matters

Owen’s Law is the campaign name for making written allergen information at the point of ordering a legal requirement for non-prepacked food. It follows the death of Owen Carey in 2017. It is a campaign, not legislation, and it has not been passed.

The FSA guidance was published as an interim step while the question is deliberated. The government committed to evaluating how widely businesses have actually adopted that voluntary guidance, with the evaluation beginning in spring 2026. The results will inform ministers on whether Owen’s Law needs to become statute. Limited uptake strengthens the case for mandatory legislation.

For multi-site operators, the practical read is straightforward. A voluntary standard that is being formally evaluated for adoption is a standard worth being able to evidence. If your allergen information is written, current and consistent across every location, you are ready either way. If it lives in a different format at every site, you have a problem now and a bigger one later.

💡 PRO TIP: Treat the FSA best practice guidance as a dry run for compliance. Getting written allergen information standardised across your estate while it is voluntary is considerably cheaper than doing it under a legislative deadline.

Two Different Types of Label

Food businesses use the word “label” to describe several different things. One distinction matters more than any other.

For-sale labels go with food being sold to the customer. Where food meets the definition of prepacked for direct sale, Natasha’s Law requires the name of the food, a full ingredients list, and the 14 regulated allergens emphasised within that list. The purpose is simple: give the customer accurate information about what is in the food before they eat it.

Food prep labels, sometimes called day labels, are used behind the scenes by kitchen teams, on chicken prepared this morning, a sauce opened yesterday or portioned ingredients being cooled and stored. Depending on your procedures, a prep label might carry the product name, prep or open date, use-by or discard date, staff initials, batch information and storage instructions. They support shelf-life management, rotation and traceability.

Prep labels are not Natasha’s Law labels. But both types depend on the same foundation: controlled, repeatable operations.

What Happens If You Get It Wrong

Enforcement is carried out locally and it has real consequences. Environmental health officers can issue improvement notices, seize products and pursue prosecution. Offences relating to food information can carry significant financial penalties, and where a labelling failure contributes to serious harm, the consequences escalate considerably.

Alongside the legal exposure sits the commercial cost: hygiene rating impact, franchise agreement breaches, media coverage and the loss of customer confidence that follows a serious allergen incident.

Your records decide the outcome

UK food law provides a due diligence defence, which broadly requires a business to show it took all reasonable precautions and exercised all due diligence to avoid an offence.

That defence depends on evidence rather than intention. It is not enough that your standard operating procedure describes the right process. You need to be able to produce, for a specific date at a specific site:

• the check that was completed, and by whom
• the training record showing the employee was assessed as competent
• the corrective action raised when something failed, and the record of it being closed
• confirmation that a supplier specification change reached every affected location

A ring binder in the back office rarely produces that in a form that survives scrutiny, and neither does a photograph of a paper checklist in a group chat. An enforcement officer is not visiting to admire your label printer. They are asking whether your kitchen follows your own procedures, and whether you can show it.

Where Natasha’s Law Becomes an Operations Problem

Printing the label is the easy part. Everything behind the label is where operators have to maintain control.

Take a chicken sandwich. Its PPDS label depends on an approved recipe, current supplier specifications, the correct product actually being used at site, an employee following the procedure, the correct label being applied, and a manager verifying it. If one of those steps breaks, a well-designed label template does not help.

Now multiply that by 30 menu items, 100 employees, 50 locations, seven days a week. This is the point at which multi-unit food safety stops being a documentation problem and becomes an execution problem.

Three ways standards drift across locations

1. Somebody substitutes an ingredient. The approved mayonnaise runs out and a manager buys another brand. It looks the same and works in the recipe, but the ingredients are not necessarily identical. If the substitution is not controlled, your allergen information becomes disconnected from what is actually being served.
2. A supplier changes a specification. A reformulated product arrives and a new spec lands at head office. You then need to know which recipes are affected, which locations need the information, whether the old document has been removed, and whether employees have actually seen the change. Emailing an attachment is not the same as controlling a change.
3. Nobody verifies, and head office cannot see. A label being applied does not mean anybody checked it against the current standard. You might have excellent standards, but can you tell whether store 14 followed them this morning, which staff have not completed allergen training, and whether the same issue keeps recurring at one site?

How Operandio Supports Allergen and Labelling Compliance

Operandio is an all-in-one operations platform built for franchise and multi-unit businesses. Instead of allergen procedures in one system, training in another and food safety checks on paper, it connects the pieces allergen compliance depends on.

Checks that happen on the shift. A procedure sitting in a folder does not guarantee anything happens. Operandio turns food safety procedures into recurring tasks and checks that appear on the shift, with evidence captured and completion timestamped. When something fails, it becomes a corrective action with an owner, a due date and a record of the resolution, rather than “I told the kitchen manager about it”.

One controlled version of the procedure. Knowledge & Document Management keeps operational information in one environment with version control and role-based access, so locations stop quietly developing their own variants of the standard. When something changes, Employee Communication pushes the update to affected sites, requires acknowledgement and tracks completion.

Training you can evidence. A mobile-first LMS lets you assign allergen awareness, Natasha’s Law and PPDS procedures, and site-specific labelling processes. Understanding is assessed and completion is tracked by employee and by location, which is far more useful than reconstructing training records when somebody asks for them.

Prep labelling standardised across the network. The Food Prep Labelling System replaces handwritten labels with digital ones. You configure shelf-life rules centrally, the employee selects the product, and Operandio calculates the discard date and prints. So restaurant A is not deciding a product lasts three days while restaurant B has somebody handwriting four. Every label printed is logged with user, time and template details, giving audit-ready traceability alongside your inspections, temperature records and corrective actions in the same platform. Our guide to shelf-life tracking and labelling explains the wider rotation benefits.

Operandio is also hardware agnostic, working with Zebra, Epson, Gainscha, Sato, Star Micronics, Brother and other leading printers, so better labelling does not have to start with a hardware replacement project.

💡 PRO TIP: Build PPDS label verification into your opening checklist rather than your monthly audit. Daily verification catches an incorrect label within hours instead of weeks.

Make Food Safety Easier Across Every Location

A printer will print whatever information you send to it. It cannot guarantee that the recipe is current, that the supplier specification has not changed, that staff completed training, that every site received the update, or that somebody verified the process. The label is the output. Compliance comes from the system behind it.

Operandio helps franchise and multi-unit food businesses standardise what happens on the frontline: food prep labelling, food safety checks, training, inspections, corrective actions, operational knowledge and reporting in one platform.

Interested in seeing how this works across your locations? Book a demo with Operandio and we will walk through allergen procedures, prep labelling, training records and multi-site reporting using your own operation as the example.

FAQs

This article provides general operational information and should not be treated as legal advice. Always refer to current Food Standards Agency, Food Standards Scotland and applicable legislative guidance when determining your organisation’s food labelling requirements.

Last reviewed: September 2026