Food Labelling and Allergens — Natasha's Law for Market Sellers

What counts as prepacked for direct sale?

This is the key question. "Prepacked for direct sale" (PPDS) means food that is:

• Packaged at the same place it is sold to the consumer.
• Already in its packaging before the customer selects or orders it.

For craft fair and market contexts, PPDS includes:

• Cakes or brownies wrapped in clingfilm or bags before customers choose them.
• Jams, preserves, or confectionery packaged at home and sold from your own market stall.
• Sandwiches or wraps made and wrapped before the customer orders.

What does NOT count as PPDS:

• Food that is not in any packaging — for example, loose cakes on a tray where the customer points and you wrap it after they choose. This is "non-prepacked" food.
• Food packaged after the customer orders it.
• Food packed by one business and sold by a different business — this is "prepacked food" and already requires full labelling under existing regulations.

The distinction matters. If you display unwrapped cakes and bag them after the customer selects, Natasha's Law labelling does not apply — but you must still provide allergen information by other means (verbally, on a sign, or on a menu board).

The 14 declarable allergens

UK food law requires you to declare these 14 allergens wherever they appear in your products:

• Celery (including celeriac)
• Cereals containing gluten (wheat, rye, barley, oats)
• Crustaceans (prawns, crab, lobster)
• Eggs
• Fish
• Lupin
• Milk (including lactose)
• Molluscs (mussels, oysters, squid)
• Mustard
• Nuts — tree nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia nuts)
• Peanuts
• Sesame seeds
• Soybeans (soya)
• Sulphur dioxide and sulphites (at levels above 10mg/kg or 10mg/litre)

These must be emphasised in the ingredients list — bold type is the most common method. They must appear within the ingredients list itself, not in a separate allergen box (though you can add additional highlighting if you wish).

What goes on the label?

A PPDS label must include:

• The name of the food — e.g. "Chocolate Brownie", "Strawberry Jam".
• A full ingredients list — every ingredient, listed in descending order of weight.
• Allergenic ingredients emphasised — typically in bold within the ingredients list.

Practical points:

• Every recipe variation needs its own accurate label. If you make three flavours of brownie, you need three different labels.
• Handwritten labels are legally acceptable but must be legible and accurate.
• If your recipe changes — even slightly — the label must be updated immediately.
• The label must be on the packaging itself, not on a separate card or leaflet.
• There is no legal requirement for a "may contain" warning for cross-contamination, but it is good practice if you prepare different products in the same kitchen.

What about non-prepacked food?

If you sell unwrapped food (the customer selects, you then bag or serve it), Natasha's Law labelling requirements do not apply. However, you must still provide allergen information for the 14 declarable allergens. You can do this by:

• A clearly visible sign or menu board listing allergens for each product.
• Verbal information — but you must be able to provide accurate information on request, and it is best practice to have it written down as backup.

The FSA published updated guidance in March 2025 encouraging written allergen information even for non-PPDS food. This is guidance rather than law, but it signals the direction of travel and is strongly recommended.

Top tip: even if you sell unwrapped food, having a printed allergen chart for each product looks professional, protects your customers, and protects you.

Enforcement

Local authority environmental health officers and Trading Standards can inspect food businesses for compliance with allergen labelling requirements. Non-compliance can result in:

• Informal advice and a request to fix the issue.
• Formal improvement notices.
• Prosecution in serious or repeat cases.

Allergen labelling is taken very seriously. A mislabelled product could cause a fatal allergic reaction. Officers understand that small-scale sellers may need guidance, but you are expected to know and follow the rules.

Keep a file of your recipes and ingredient lists — if an officer asks, being able to show your workings demonstrates you are taking it seriously.

Practical tips for market sellers

• Print labels at home before the event. A simple template with your business name, product name, and ingredients list is all you need.
• Keep a master list of all your recipes with full ingredient breakdowns, including allergens.
• If you buy ingredients, check the packaging for allergen declarations — suppliers sometimes change recipes.
• If you share a kitchen with other household members, be aware of cross-contamination risks and consider including a "may contain" statement.
• The FSA offers free online allergen training courses — they take about an hour and are well worth doing.
• If in doubt about whether something is an allergen, check the FSA's guidance or contact your local environmental health team.