For caterers
Natasha's Law for Caterers: When PPDS Labels Apply
Natasha's Law requires full ingredient labels on food prepacked for direct sale. For event caterers it applies less often than expected. When it does.
Does Natasha's Law apply to event caterers?
Sometimes. Since 1 October 2021, food that is prepacked for direct sale (PPDS) must carry a label with the name of the food and a full ingredients list with the 14 allergens emphasised. Food is PPDS when it is packed on the same premises where it is sold, before the customer orders it, and is enclosed so it cannot be altered without opening the packaging. The FSA's guidance for event caterers makes one point that matters a great deal: food ordered in advance by a host, such as a company or a wedding couple, is not PPDS, even if it arrives wrapped, because the host is not the final consumer present when it is packed.
When it does apply
A van or stall at a public event selling sandwiches, salads, cakes or pots of food that were wrapped before the customer asked for them. Individually wrapped items on a counter at a festival, a market or a sports ground. A café-style unit at a venue where you pack food in the morning to sell through the day. In each case the customer is the final consumer, buying food that was packed before they ordered it.
When it does not
Food packed at the customer's request, such as a wrap made to order and wrapped in front of them. Open food, such as a buffet platter, a hot dish served from a pan, or fruit in a bowl. Large sharing platters meant for several people. Food ordered in advance by a host for their guests. None of these needs a PPDS label, but all of them need allergen information available.
What must a PPDS label show?
The name of the food and a full ingredients list, with any of the 14 allergens emphasised in the list, for example in bold, capitals, a contrasting colour or underlining. Allergens in any ingredient or processing aid count. Labels must be legible and on the pack, not on a nearby sign.
What about everything else?
For all non-prepacked food, you must be able to give accurate information on the 14 allergens in each dish, in writing or verbally, with a clear sign telling customers how to get it if it is given verbally. A written allergen matrix for each menu, kept up to date when recipes or suppliers change, is the practical way to do this. Brand swaps by a wholesaler are a common source of error: check the ingredients each time a substitute arrives.
Where to learn more
The FSA publishes guidance specific to event caterers on PPDS, and a free online allergen training course with a certificate of completion. Both are worth working through, and inspectors will ask how you manage allergens when they rate you.
Common questions
What are the 14 allergens?
Celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, tree nuts, peanuts, sesame, soya, and sulphur dioxide or sulphites.
Does a wedding buffet need PPDS labels?
No. Food ordered in advance by the couple is not PPDS under the FSA's guidance for event caterers. You must still provide allergen information.
Does a sandwich I wrap in front of the customer need a label?
No. Food packed at the customer's request is not PPDS.
What is the penalty for getting it wrong?
Enforcement is by the council and can range from advice to improvement notices and prosecution. The real risk is to a customer with an allergy.