Natasha's Law explained: allergen labelling for food brands
Table of contents
Share
Natasha's Law requires food that's prepacked for direct sale (PPDS) to carry the name of the food and a full ingredients list, with the 14 major allergens emphasised. It came into force across the UK on 1 October 2021. If you sell food online and ship through a warehouse, the law probably doesn't apply to you in the way you'd expect, but the rules that do apply are stricter, and a lot of them land on the fulfilment side of your business.
This guide covers what Natasha's Law actually requires, which products it captures, how it applies to ecommerce brands, and where allergen labelling tends to go wrong once stock leaves your hands and goes into a Third-Party Logistics (3PL) warehouse.
What is Natasha's Law?
Natasha's Law is the common name for the allergen labelling rules for prepacked for direct sale food, which came into effect on 1 October 2021. It's named after Natasha Ednan-Laperouse, a teenager who died from an allergic reaction to a baguette containing sesame. At the time, that baguette didn't need an allergen label.
The gap in the law was specific. Since December 2014, the Food Information to Consumers (FIC) Regulation has required food businesses to give allergen information for loose and PPDS food, but that information could be given verbally or on a sign rather than on the pack. Natasha's Law closed the gap by putting the information on the label itself.
The Food Standards Agency (FSA) publishes the guidance for England, Wales and Northern Ireland. Food Standards Scotland (FSS) publishes its own guidance for Scotland. The underlying requirements sit in the FIC Regulation, which the UK retained after Brexit.
What counts as prepacked for direct sale?
Food is PPDS when the same business packs it and sells it to the final consumer before anyone orders it. The FSA's technical guidance says that selling has to happen in one of three places:
The same premises: a café that packs sandwiches in the morning and sells them from its own chiller.
The same site: a business packing food in one unit and selling it from its other units in the same building complex, such as a train station, hospital or university.
Moveable or temporary premises run by the same business: a market stall, food truck or marquee selling food the business packed itself.
The FSA's examples include sandwiches and bakery products packed on site, fast food packed before ordering (a burger wrapped under a hot lamp), burgers and sausages prepacked by a butcher, and free samples packed where they're handed out.
Two other categories sit outside Natasha's Law, and the difference matters for ecommerce brands:
Category | What it is | Labelling rule |
PPDS food | Packed and sold by the same business at the same place, before ordering | Name of the food plus full ingredients list, allergens emphasised (Natasha's Law) |
Prepacked food | Packed by one business and supplied to another business, or sold to consumers away from where it was packed | Full mandatory labelling under the FIC Regulation, which was already required before 2021 |
Non-prepacked (loose) food | Food sold unpackaged, or packed only once the customer orders it | Allergen information must be available, but it can be given in writing or verbally |
The FSA's own example of prepacked food is a pork pie packed by one business and sold by another at a farmers' market. Most products sold by ecommerce food brands fall into that prepacked column, which means the full set of mandatory label information applies to them.
The same applies to supplements, which are regulated as food in the UK. If you sell capsules, powders or gummies online, your listings and labels need to meet these rules too, with allergens such as milk, soya and fish oil emphasised in the ingredients list.
Unsure which category your products fall into? The FSA’s allergen and ingredients labelling decision tool works it out in four questions, including whether the food is sold at a distance.
What a Natasha's Law label has to include
A PPDS label needs two things: the name of the food and a full ingredients list, with any of the 14 regulated allergens emphasised every time they appear.
You can choose how to emphasise them. The FSA and local authority guidance accept bold, italics, underlining, a contrasting colour or a different font, as long as the allergen clearly stands out from the other ingredients. Many businesses add an allergy advice line such as "For allergens, see ingredients in bold". That line can point readers to the ingredients list, but it can't replace the emphasis within it, and it mustn't contradict it.
The 14 allergens are set out in the FIC Regulation. The naming rules catch people out more often than the list itself:
Allergen | What to name on the label |
Cereals containing gluten | The specific cereal: wheat (including spelt and khorasan), rye, barley or oats. Emphasising "gluten" alone doesn't meet the rule |
Crustaceans | For example prawns, crab, lobster |
Eggs | Eggs and products made from them |
Fish | Fish and products made from them |
Peanuts | Peanuts, listed separately from tree nuts |
Soybeans | Soya, with limited exemptions such as fully refined soybean oil |
Milk | Milk and products made from it, including lactose |
Tree nuts | The specific nut: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios or macadamias |
Celery | Celery and products made from it |
Mustard | Mustard and products made from it |
Sesame | Sesame seeds and products made from them |
Sulphur dioxide and sulphites | Only above 10mg per kg or 10mg per litre in the food as sold or prepared |
Lupin | Lupin and products made from it |
Molluscs | For example mussels, oysters, squid |
Prepacked food carries more than this. Under the FIC Regulation it also needs a net quantity, a best before or use by date, storage conditions, the name and UK address of the business responsible, nutrition information, and country of origin where the rules require it. That's the standard most ecommerce food brands are working to.
Does Natasha's Law apply to ecommerce food brands?
In most cases, no. The FSA's guidance states that the PPDS labelling requirements don't apply to food sold through distance selling, which covers anything bought over the phone or online. An ecommerce brand is covered by a different set of rules under Article 14 of the FIC Regulation, and those rules ask for more.
How Article 14 applies depends on what you're selling
Prepacked products: this covers most ecommerce food brands, whether you make the product yourself, use a co-packer or resell another brand. Every piece of mandatory information except the best before or use by date has to be available before the customer completes the purchase, usually on the product page. When the order arrives, the full label has to be there, date included. So your ingredients and allergen information needs to sit in two places, and both have to match.
Food you pack yourself and would otherwise count as PPDS: a bakery that sells in its shop and also takes orders online is a common example. The online orders don't need the Natasha's Law label, but the FSA says you must give customers mandatory allergen information free of charge before they buy, and again at the moment of delivery.
That second category creates a messy situation for brands selling across channels. The same brownie can need a full PPDS label on the shop counter, allergen information on the website, and allergen information again in the delivery box. Plenty of growing food brands deal with this by labelling every unit to the full prepacked standard, so one label works wherever the product is sold.
What this means in practice:
Your product pages need complete ingredients lists with allergens emphasised, and they need updating the moment a recipe or supplier changes.
What's on the product page has to match what's on the pack your customer receives.
If you sell through marketplaces as well as your own site, every listing needs the same information.
If you ship to EU customers, the label language rules for each destination country apply too.
Where allergen labelling goes wrong in fulfilment
Under the FIC Regulation, legal responsibility for the label sits with the business whose name the food is marketed under. That's you, even when the stock sits in someone else's warehouse. The label is usually correct when it leaves the factory. Problems tend to start after that, during storage, packing and dispatch.
Recipe changes with old stock still on the shelf: you add a sesame topping, update the product page, and print new labels. Your warehouse still has three weeks of the old version. Unless the two versions sit under separate SKUs or batch codes, a picker can send old stock against a page that now describes the new recipe, or the reverse. The fix is a new SKU or a tracked batch for every recipe change that affects allergens, plus a clear date for the product page switch.
Bundles, hampers and subscription boxes: kitting is where a 3PL physically assembles your products into a new sellable unit. Each item inside needs its own compliant label, and the listing for the bundle needs allergen information for every component. If a box changes contents month to month, the product page has to change with it.
Repacking loose or bulk product: if your 3PL decants bulk coffee, sweets or nuts into retail bags, that's a food packing operation. The new packs need full prepacked labelling, and the warehouse is now handling open food, which brings cross-contact risk with other allergens on site.
Relabelling and overstickering: importing brands often need UK labels applied to foreign packs, and correcting a label error usually means stickering stock in the warehouse. A sticker that peels off, covers the wrong panel or goes on the wrong variant leaves you with a non-compliant product in a customer's hands.
Delivery inserts: if you rely on a printed insert to provide allergen information at delivery, the right insert has to go in every parcel. That needs a written pick-and-pack instruction with a check built in, so it still happens when order volumes spike during peak.
Returns: food that comes back with a broken seal, damaged label or unclear batch code shouldn't go back into sellable stock. A 3PL that restocks returns by default needs a separate rule for your food lines.
Recalls: when the FSA issues an allergy alert, you need to know which customers received which batch, quickly. That depends on your 3PL recording batch or lot codes at dispatch, which plenty of general ecommerce warehouses don't do as standard.
Any warehouse storing or distributing food also has to be registered as a food business with its local authority at least 28 days before it starts operating. That's a quick first check before any conversation goes further.
Questions to ask a food and drink 3PL about allergens
A warehouse that's great with apparel or electronics can still be the wrong fit for food. These questions separate providers who handle food properly from those who simply have space.
Registration: are you registered as a food business, and when were you last inspected? Ask which local authority holds the registration and whether the inspection covered the area your stock would sit in.
Certification: do you hold a food safety certification? BRCGS Storage and Distribution is the most common standard for food warehousing in the UK. If they don't hold one, ask how they manage food safety instead.
Batch and date tracking: can your Warehouse Management System (WMS) track batch codes and dates? You want batch or lot capture at goods-in and at dispatch, plus First Expired, First Out (FEFO) picking so short-dated stock goes first.
Recipe changes: how would you keep old and new versions of a product apart? Ask whether they can quarantine stock on request the same day.
Repacking, kitting and relabelling: do you handle open food, and where? Ask how they separate it from other allergens on site and what cleaning happens between jobs.
Returns: what happens to returned food? The right answer is a defined process that checks seals, labels and batch codes before anything goes back on the shelf.
Recalls: how quickly can you pull every order containing a specific batch? Ask when they last did it for real.
Experience: which food brands do you already work with? Similar products, similar order volumes and similar storage needs (ambient, chilled or frozen) are a good sign. Ask for a reference you can call.
When you compare providers through fulfilment.com, you can filter for 3PLs that already handle food and drink, so you're asking these questions of a relevant shortlist from the start.
How allergen rules are enforced
Allergen labelling is enforced by local authority officers, usually Trading Standards or Environmental Health depending on the area. For most food labelling breaches in England, the first step is an improvement notice that gives the business time to fix the problem.
Allergens are treated more seriously. The FSA's technical guidance states that failing to meet the allergen labelling requirements in the Food Information Regulations 2014 is a criminal offence, and a business convicted under those regulations faces a potentially unlimited fine, set by magistrates case by case. Prosecution can happen without an improvement notice first.
Where a mislabelled product makes food unsafe, the Food Safety Act 1990 can also apply, with a maximum of an unlimited fine and up to two years' imprisonment. Then there's the commercial cost: product recalls, retailer and marketplace delistings, and the loss of customer trust that follows a public allergy alert.
Natasha's Law FAQs
When did Natasha's Law come into force?
It came into force on 1 October 2021.
Does Natasha's Law apply in Scotland?
Yes. Scotland introduced equivalent PPDS rules on the same date, with guidance published by Food Standards Scotland.
Does Natasha's Law apply to food sold online?
No. Food sold online or by phone falls under the distance selling rules in Article 14 of the FIC Regulation. For prepacked products, that means mandatory information on the product page before purchase and a full label on delivery.
What's the difference between PPDS and prepacked food?
PPDS food is packed and sold by the same business at the same place. Prepacked food is packed by one business and sold by another, or sold away from where it was packed. Prepacked food needs more information on the label.
Who's responsible if my 3PL sends out a product with the wrong label?
Responsibility for label information sits with the business the food is marketed under, which is normally your brand. That's why batch tracking, version control and clear packing instructions matter when you outsource fulfilment.
Does my 3PL need to be a registered food business?
Yes. Any premises storing or distributing food must register with its local authority at least 28 days before it starts.
Find a 3PL that's set up for food
Allergen compliance in fulfilment comes down to batch tracking, version control and a provider who's handled food before. Compare food and drink 3PLs on fulfilment.com and get quotes from providers that already work to these standards.
