First, work out which category you are in
Almost every argument about labelling comes from people applying the wrong ruleset. Three categories cover most businesses:
- Prepacked — packed before being offered for sale, where the contents cannot be altered without opening the pack. Full labelling applies.
- Prepacked for direct sale (PPDS) — made and packed on the same premises you sell it from. Needs the name of the food plus a full ingredients list with allergens emphasised. This is what Natasha's Law changed.
- Non-prepacked / loose — served or packed at the customer's request. Allergen information must be available, and you must signpost clearly how the customer gets it.
What a prepacked label has to carry
- The name of the food — a true description, not just a brand name.
- An ingredients list in descending weight order, with the 14 regulated allergens emphasised within it.
- QUID — the percentage of an ingredient where it is named in the product name, pictured, or emphasised.
- Net quantity, with the correct units and the average quantity rules applied.
- A date mark — 'use by' for microbiologically highly perishable food, 'best before' otherwise.
- Storage conditions and conditions of use, including after opening where relevant.
- The name and address of the food business responsible for the information.
- Country of origin or place of provenance where required, including the primary ingredient rules.
- Preparation or cooking instructions where the food needs them to be used safely.
- A nutrition declaration per 100g or 100ml, unless exempt.
- Alcoholic strength for drinks over 1.2% ABV.
- Any mandatory additional statements — for example certain sweeteners, high caffeine, or packaging gas.
All of it must be easy to see, easy to read and not obscured, with a minimum x-height for the type. A technically correct label printed too small to read is still a non-compliant label.
The 14 allergens, and how to declare them
Cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame, sulphur dioxide and sulphites above the threshold, lupin and molluscs.
The allergen must appear in the ingredients list and be emphasised so it stands out — bold is the usual method. Name the specific cereal or nut. A separate "contains" panel on its own is not enough, and a "free from" claim is a much bigger commitment than it looks: it requires validated controls and, in practice, testing evidence.
Natasha's Law and PPDS, practically
If you make it and pack it on the premises you sell it from — sandwiches, salad pots, cakes, bakery items wrapped before the customer asks — it needs the name of the food and a full ingredients list with allergens emphasised, on the pack or attached to it.
The operational problem is rarely the first label. It is version control on a menu that changes: seasonal specials, substituted suppliers, a different brand of mayonnaise. You need a simple, owned process for recipe change to trigger a label change, or the labels drift out of true within weeks.
Date marking
- 'Use by' is a safety date, for microbiologically highly perishable food. Selling past it is an offence and the shelf life must be justified.
- 'Best before' is a quality date.
- Shelf life needs evidence behind it — challenge testing, shelf-life trials or a documented justification. A number that came from a similar product is not evidence.
- The date has to be legible on the pack for its whole life, which means checking your printer and substrate, not just the artwork.
Where labels get rejected
- Ingredients not in descending weight order, or a compound ingredient not broken down.
- QUID missing where the product name or the picture emphasises an ingredient.
- Allergen present in an additive or processing aid and not declared.
- Nutrition figures rounded or calculated wrongly, or expressed per portion only.
- Legal name replaced by a marketing name, so the customer cannot tell what the food is.
- Claims that are not permitted, or health claims made about an ingredient rather than the product.
- Vegan, vegetarian, halal or organic claims made without the controls or certification behind them.
- Old artwork still in circulation after a recipe change — the version control failure.
- Print quality: type too small, poor contrast, key information wrapping around a seam.
A process that keeps labels right
- One person owns artwork approval, and no label goes to print without their sign-off.
- A specification per product, with the ingredients list generated from the actual recipe.
- Recipe or supplier change triggers a label review as a matter of course.
- Version numbers and dates on artwork, with obsolete versions withdrawn from the floor.
- On-line checks that the correct label went on the correct pack, recorded.
- An allergen matrix kept current, and used by both the kitchen and whoever answers customer questions.
- A periodic review of live labels against live recipes — not just when something changes.
Want your labels checked before they print?
Allergen matrices, ingredient declarations, PPDS labels and artwork review — from £450. It is a great deal cheaper than a reprint, and considerably cheaper than a withdrawal.
