Natasha's Law and PPDS: does it apply to what you bake?

Natasha's Law came into force on 1 October 2021, after the death of Natasha Ednan-Laperouse, who ate a baguette whose sesame was not declared because the law at the time did not require it to be.

The change was narrow and specific. It created full ingredient labelling for one category of food: prepacked for direct sale.

The test, in one question

Was the food put into its packaging before the customer asked for it, at the same place it is being sold?

If yes, it is PPDS.

Three things have to be true together. The food is in packaging. The packaging went on before the order. And the selling happens on the same site as the packing — including a market stall or a van you also bake in, which counts as the same operation even though it moves.

Worked examples

PPDS:

• Cupcakes boxed in the morning, put out in your cabinet
• A wrapped tray bake in a bake shed with an honesty box
• Cellophane-bagged cookies on your market stall, bagged at home the night before
• Sandwiches made at 7am and put in the chiller

Not PPDS:

• A loaf handed over in a paper bag as the customer buys it — non-prepacked
• A cake boxed while the customer waits — non-prepacked
• Wholesale trays delivered to a café — prepacked, and subject to the heavier full prepacked rules
• A wedding cake made to order and delivered — not PPDS; allergen information is still required, just not by this route

The awkward middle case is the market stall where you bag things as people buy them. That is non-prepacked. Bag a batch in advance to save time and the same product becomes PPDS. Same cookie, same stall, different legal category, decided entirely by when the bag went on.

What PPDS requires

Two things on the packaging:

1. The name of the food
2. A full ingredient list, in descending order of weight, with the 14 regulated allergens emphasised

That is it. No mandatory weight, date mark, address or nutrition panel — those belong to full prepacked food. Many bakers add a best-before date anyway, which is good practice and not a requirement.

Emphasis means the allergen words are visually distinct: bold, capitals, underlined, or a contrasting colour. Consistently applied.

The parts that go wrong

Compound ingredients not broken down. "Chocolate chips" is not an ingredient — it is four, one of which is usually soya lecithin. If you cannot list what is inside something you bought, you cannot label a product containing it. Get the specification from the supplier.

"May contain" used as a substitute. Precautionary allergen labelling is voluntary and covers unavoidable cross-contamination. It does not cover ingredients you deliberately added, and it is not an alternative to the list.

Allergens declared but not emphasised. Very common, and easy to fix.

Labels that drift from the recipe. You change a supplier, the new one's margarine contains soya, and the label file on your laptop does not know. Nothing about that failure is visible on the printed sticker, which is what makes it the dangerous one.

The record behind the label

The regulations are about what the customer can read. The inspection is about what you can show.

If someone asks about a batch from two months ago, what helps is the recipe it came from, where each ingredient's allergen data came from, and which version of the label was live at the time — with a date and a name against the approval.

BakeCheck keeps ingredients with their allergen data, computes labels from the recipe, blocks approval when an ingredient's allergens are undeclared, and keeps every version so the trail exists before anyone asks for it.

Where to read the actual rules

The Food Standards Agency publishes PPDS guidance for businesses, including a technical guide on emphasis and compound ingredients, at food.gov.uk. Your local authority's environmental health team will also advise, for free, before a visit rather than during one.

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General guidance, not legal advice. Rules differ between England, Wales, Scotland and Northern Ireland.