UK allergen labelling rules require food businesses to identify regulated allergens accurately and present the information in the correct way for the type of sale. The applicable duties differ for prepacked food, prepacked for direct sale food, non-prepacked food and distance sales. This guide explains the current framework and the practical label controls needed to support compliance.
Related guidance for the next decision
For label production, review Soabar’s food packaging label solutions. Packs needing extra information space may suit multi-layer peel-and-reveal labels, while products entering a cold chain require a separate decision about best labels for fridge and freezer products.
The legal framework in the UK
Allergen information is governed by food-information law rather than a single stand-alone “allergen labelling act”. The core rules derive from assimilated Regulation (EU) No 1169/2011 on the provision of food information to consumers, implemented and enforced through domestic regulations. In England the relevant enforcement framework is the Food Information Regulations 2014, with corresponding regulations in Wales, Scotland and Northern Ireland. Businesses must check the rules applying where the food is sold.
The 14 regulated allergens
The regulated categories are cereals containing gluten, crustaceans, eggs, fish, peanuts, soya, milk, nuts, celery, mustard, sesame, sulphur dioxide and sulphites above the specified threshold, lupin and molluscs. The specific ingredient must be named; broad wording such as “contains allergens” is not enough. Ingredients derived from these categories may have exemptions, so formulation and supplier information must be accurate.
Prepacked food
For prepacked food, allergens used as ingredients must be indicated in the ingredients list and emphasised through a typesetting distinction such as bold type, a different style or background colour. If there is no ingredients list, the declaration uses “contains” followed by the allergen. The product may also require other mandatory particulars, including the name of the food, net quantity, durability date, storage conditions, responsible business details and nutrition information, depending on the product and exemptions.
Prepacked for direct sale and Natasha’s Law
Since 1 October 2021, food classed as prepacked for direct sale—PPDS—must display the name of the food and a full ingredients list with the regulated allergens emphasised. The change is widely known as Natasha’s Law. PPDS generally covers food packed before selection by the consumer on the same premises or site from which it is sold by the same food business. Classification should be checked carefully because made-to-order, prepacked and PPDS foods have different presentation requirements.
Non-prepacked food
For loose food, food packed at the consumer’s request and many catering situations, information about the 14 allergens must be available. The permitted method and required notices depend on the jurisdiction and selling context. Current FSA best practice encourages clear written allergen information supported by a conversation, rather than relying on memory or an “ask us” sign alone.
Distance selling
When food is sold by website, app or telephone, mandatory allergen information must be available before the purchase is concluded and again when the food is delivered. Businesses need a controlled link between recipe, online information, order handling, packing and the delivered item so that a formulation change is not missed on one channel.
“May contain” statements and cross-contamination
Precautionary allergen labelling is used to communicate an unavoidable risk of unintended presence after a proportionate risk assessment. It should not replace good hygiene, segregation, supplier controls or accurate ingredient declarations. Overuse can unnecessarily restrict consumer choice, while omission after a genuine unmanaged risk can endanger customers.
Keeping label information accurate
Create a controlled specification for every recipe and ingredient. Obtain current supplier declarations, manage substitutions, review processing aids and compound ingredients, approve artwork, check print legibility and verify the correct label at changeover. Staff should know how to stop production or sale when the recipe and label do not agree. Records should support traceability and recall action.
Label design and production
Legally required information must be clear, legible and not obscured. Small packs, curved containers and multilingual products can create space pressure; peel-and-reveal labels may provide additional room where an appropriate construction is permitted, but mandatory particulars must still be presented correctly. Soabar’s food packaging labels service supports printed food labels, while the food business remains responsible for verifying legal content.
Current guidance and territorial checks
Food law changes and guidance can be updated. The UK Government’s PPDS guidance was updated in July 2026, and businesses should use the latest Food Standards Agency or Food Standards Scotland decision tools and seek competent legal or regulatory advice for uncertain classifications, exports or unusual products. EU exports must meet the rules in the destination market; UK compliance alone does not establish compliance elsewhere.
Ingredient names and emphasis
The emphasis must identify the allergenic ingredient within the ingredients list, not merely add a separate generic warning. For cereals containing gluten and nuts, the required naming conventions matter; the label should identify the relevant cereal or nut rather than rely on an imprecise family term. Compound ingredients also need to be unpacked according to the applicable declaration rules. Recipes, raw-material specifications and artwork therefore need to use the same controlled ingredient language.
Recipe changes and substitutions
A substitute ingredient can change the allergen profile even when the product name and appearance stay the same. Emergency sourcing is a common risk point. Procurement should prevent an alternative raw material reaching production until its specification has been reviewed, the recipe record updated, label stock checked and affected staff informed. Covering an old label with an uncontrolled sticker is not a safe change process unless the replacement label itself is complete, accurate, legible and authorised.
Print legibility and pack size
Mandatory information is only useful when customers can find and read it. Font size, x-height, contrast, spacing, print quality, pack curvature, seams and reflections all affect legibility. Artwork should be assessed on the final container at actual size, not only on a magnified screen. Where space is genuinely restricted, the business should obtain competent guidance on the permitted presentation rather than shrinking the ingredients list until it is unreadable.
Label reconciliation on the packing line
The correct approved label must meet the correct product and recipe. Use line-clearance checks at product changeover, segregate obsolete stock, identify reels clearly and reconcile issued and returned quantities where risk warrants it. Barcode or vision checks can support control but do not replace an approved master and trained staff. A final pack check should confirm product name, date coding, ingredients, allergen emphasis and any batch-dependent information.
Claims such as “free from”
A “free from” claim communicates a stronger assurance than ordinary absence from the recipe. It requires robust controls over ingredients, cross-contamination, production, cleaning, verification and supplier management. Businesses should not use “free from”, “allergen-free” or similar wording as casual marketing copy. The claim must be accurate for the product and supported by the operation that makes and packs it.
What to do when information may be wrong
Stop affected production or sale, isolate stock and investigate immediately. Establish which recipes, ingredients, batches, labels, channels and customers are affected. Food businesses should follow their incident and recall procedures and contact the relevant authority when required. Corrective action should address the root cause—such as supplier change control, artwork approval or line clearance—not only replace the individual label.
Build the decision around evidence
Good label decisions are documented rather than assumed. Record the product specification, approved artwork, samples, test conditions and sign-off. Where the content carries safety, care, traceability or regulatory information, include an independent check by someone who did not prepare the original file. This simple separation catches familiar wording, transposed values and outdated versions that the original author may overlook. Evidence also makes later troubleshooting faster because the team can distinguish a design decision from an uncontrolled production change.
Manage changes before the next order
Products, ingredients, suppliers, containers, machinery and legal requirements can change during the life of a label. Set a review trigger for each relevant change rather than reordering automatically from the previous file. Confirm that material, adhesive, dimensions, wording, codes, orientation and quantities are still correct. Withdraw obsolete artwork and identify superseded label stock so it cannot return to the packing line. Repeat orders should be convenient, but convenience should never bypass content approval or application checks.
Work with the supplier early
Early discussion gives the label supplier room to solve constraints through material choice, artwork adjustment, finishing, roll format or printing method. Sending finished artwork only after every decision has been locked can hide avoidable problems. Share non-negotiable requirements and explain the production process, then allow suitable alternatives to be sampled. The strongest result combines the product owner’s knowledge of the item and customer with the supplier’s knowledge of print, materials, converting and equipment.
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