Natasha’s Law for Butchers: Which Products Need an Ingredients Label?

Labelling your products may seem like a simple task. However, depending on when, where, and how the food was packed, orders have very different requirements.

Natasha’s Law introduced additional ingredient and allergen labelling requirements for food that is prepacked for direct sale, usually shortened to PPDS. For butchers, it is important to know which products fall into this category.

What Is Natasha’s Law?

Natasha’s Law is a regulation introduced across the UK in 2021. It requires all food that is prepacked for direct sale (PPDS) to display its name and a full ingredients list, with any of the 14 regulated allergens clearly emphasised.

The law is named after Natasha Ednan-Laperouse, who died following an allergic reaction to a baguette that did not list the correct allergens on the packaging. At the time, the product did not require a comprehensive ingredients label. Her family’s campaign changed the way that allergens are treated on PPDS food, allowing people to easily check their food before buying it.

What Is PPDS Food?

You can easily determine whether a product is prepacked for direct sale by checking:

• Is it in packaging?
• Was it packed before the customer selected or ordered it?
• Was it packed by the same business at the site where it is being sold?

An open display tray and individually wrapped packs are treated differently. A pre-wrapped pack can still be PPDS when it is kept behind the counter and handed to the customer.

There is also a provision for food packed and sold by a business from a temporary or mobile place, such as a farmers’ market stall. Food packed at another fixed site, or supplied ready-packed by another business, generally follows the prepacked-food rules.

Simply stating that food is "prepared for the display" does not tell you enough on its own. You must check whether the food is loose or already enclosed in individual packs before the customer orders.

What Goes on a PPDS Label?

When creating a label for a PPDS meat product, the information must be presented clearly and follow a specific format:

• The food’s name: Generally use its legal name. Sometimes an accurate descriptive name is allowed.
• An ingredients list: Introduce it with “Ingredients” or a heading containing that word. Generally, list ingredients in descending order of weight when the product is made.
• Clearly emphasised allergens: Highlight any of the 14 regulated allergens whenever they appear in the ingredients list. Bold type is suggested.

These are the core PPDS requirements. Other food-information rules may also apply to the product.

Check Bought-In Ingredients Carefully

Rusk, glazes, seasonings and marinades can each contain several ingredients. Use the supplier’s specification when preparing your label. Their individual ingredients usually need to be included.

Where they are present, examples of allergen emphasis include:

• WHEAT flour in rusk.
• yoghurt (MILK) in marinade.
• MUSTARD powder in seasoning mix.

Include Meat Content Where Required

Some meat products also need a meat-percentage declaration, known as a Quantitative Ingredient Declaration, or QUID.

For PPDS meat products where this is required, the information can appear on the pack, a notice, or ticket visible where the customer chooses the food. For example, the ingredients list might state “Pork (75%)”.

Make the Label Readable

Mandatory text normally needs a minimum x-height of 1.2 mm (the height of a lowercase “x”). A minimum of 0.9 mm is permitted where the package’s largest surface is below 80 cm².

Does Plain Meat Require an Ingredients List?

A single-ingredient food can be exempt where its name clearly identifies the ingredient. Adding a marinade or seasoning removes that exemption. If the resulting product is sold as PPDS, it will normally need an ingredients list. If it is displayed loose and packed after selection, the non-prepacked rules apply instead. See the ingredients-list exemptions.

The exemption does not remove other applicable requirements, including beef origin and traceability labelling.

Selling PPDS Products Online

The PPDS ingredients-list requirement does not apply in the same way online. However, mandatory allergen information must still be made available to the customer before the purchase is completed (e.g., over the phone or on the website) and when delivered.

A Labelling Routine

Consistency is the best way to prevent labelling errors. A few checks can help prevent the wrong information reaching a pack:

1. Keep an approved, up-to-date recipe and current supplier specifications for each product.
2. Use those records to prepare your ingredient and allergen information.
3. Review the information whenever a recipe, ingredient or supplier changes.
4. Print and inspect a sample label before labelling the batch.
5. Check that the label matches the product, is readable, and is attached securely.

For further guidance, use the FSA’s allergen guidance for butchers in England, Wales, and Northern Ireland, or the Food Standards Scotland PPDS guidance if operating in Scotland. If your business uses unusual packing or off-site selling arrangements, contact your local authority’s food standards team for tailored advice.