PPDS Labelling: What It Means in Ireland and the UK

PPDS is the rule that caught out the most food businesses in the last five years, and it still catches people, because the category is defined by when the food was packed rather than by what it is.

Get it wrong in the wrong direction and you are labelling nothing on a product that legally needs a full ingredient list.

What counts as PPDS

Prepacked for direct sale means food that is packed on the same premises from which it is sold, before the customer orders it.

Three conditions, all of which have to be true:

1. The food is fully or partly enclosed by packaging
2. It was packed before being ordered
3. It is being sold from the premises where it was packed, or from a vehicle or stall belonging to that business

What the label has to say

A PPDS label needs:

• The name of the food
• A full ingredient list, in descending order of weight
• The fourteen declarable allergens emphasised within that list, using bold, capitals, contrasting colour or underlining

The emphasis point is where businesses get it wrong. Allergens must be highlighted inside the ingredient list. A separate "contains milk" box underneath does not satisfy the requirement on its own.

Why the rule exists

In 2016 Natasha Ednan Laperouse, aged fifteen, died after eating a baguette containing sesame that was not declared. The product was prepacked for direct sale, a category that at the time required no ingredient list at all.

The Food Information (Amendment) Regulations, known as Natasha’s Law, came into force in the UK on 1 October 2021. Ireland has equivalent requirements for PPDS food, and you should confirm your own position directly with the FSAI.

Loose food is different

Food sold loose or packed at the customer’s request does not need a written label, but allergen information must still be available and accurate.

It can be given verbally, provided there is clear signposting telling customers to ask. Verbal does not mean informal:

• The answer has to come from your ingredient records rather than from whoever is on the counter
• It has to be the same answer every time, from every member of staff
• Somebody on shift has to be able to give it, which is a training and rota question

See food hygiene training and allergen management.

The part that actually fails

Not the label design. The information behind it.

A PPDS label is only as accurate as your ingredient records, and the usual route to a wrong label is a supplier reformulating something and the change never reaching you, or reaching you and not reaching the label.

The 2024 mustard powder contamination is the clearest example available. Peanut contamination in one ingredient travelled through the supply chain to 59 brands and 307 products, with related recalls still appearing in 2026. Every business buying that powder had to answer one question: which of our runs used the affected lot?

Getting it right in practice

1. Work out which of your products are PPDS. Walk the shop floor and apply the three conditions to each line. Most businesses find items they had not classified.
2. Hold allergen data against every ingredient, not against the finished product, so a change to one ingredient updates everything containing it.
3. Derive labels from the recipe rather than maintaining a separate label document that drifts.
4. Make supplier specification changes a notifiable event, in writing, as a condition of approval.
5. Give label review a named owner and a closing date whenever a specification changes.
6. Re review on a schedule. Do not wait to be told.

This bites hardest in bakery and deli operations, where most of the range is packed on site and allergens are the dominant hazard.

Frequently asked questions