What Must Go on a PPDS Food Label in the UK?

A UK food business selling food that is prepacked for direct sale (PPDS) must put the name of the food and a full ingredients list on the package, with any of the 14 regulated allergens emphasised every time they appear. The first task is to classify the food correctly: not every wrapped sandwich, boxed salad or bakery item is PPDS.

TapTick can help teams keep routine checks, exceptions and corrective actions in one visible evidence trail. The business remains responsible for creating accurate labels from controlled recipe and supplier information. See the TapTick features.

What does PPDS mean?

PPDS means food that is placed into packaging before the customer selects or orders it and is offered for sale by the same food business that packed it. The packaging may enclose the food completely or partially, but the contents cannot be altered without opening or changing the packaging.

The same-business and location tests matter. Official Scottish guidance includes food packed and sold on the same premises, food packed and sold by the same business at different units within one building complex, and food packed by the same business for sale from its mobile or temporary premises.

Common examples can include:

• sandwiches made, wrapped and placed in a display cabinet before selection;
• boxed salads prepared on site and put on a refrigerated shelf;
• wrapped deli-counter cheese or meat prepared before the customer chooses it;
• bakery items packaged on site before sale; and
• burgers, wraps or similar food packed before an order is placed.

The facts decide the classification, not the product name. A sandwich can be PPDS, non-prepacked or fully prepacked depending on when and where it was packed and which business offers it for sale.

How can you tell whether food is PPDS?

Use a repeatable decision test for every product:

1. Is it food for a final consumer or mass caterer?
2. Was it put into packaging before the customer selected or ordered it?
3. Does the packaging enclose it so the contents cannot be changed without opening or altering the package?
4. Did the same food business pack it and offer it for sale at the relevant premises, site, or mobile or temporary operation?

If the answer to all four questions is yes, the food is likely to be PPDS. Check the official flow chart for the nation in which the food is sold when the arrangement is unusual.

Food packed only after the customer orders or selects it is not PPDS. Food packed by one business and supplied to a separate business for sale is generally prepacked food rather than PPDS and is subject to the wider prepacked-food labelling rules. Moving production to a central kitchen can therefore change the classification even if the recipe and packaging look the same.

What must the label show?

The core PPDS requirements apply throughout the UK from 1 October 2021. The label must show:

• the name of the food;
• a full ingredients list; and
• any of the 14 regulated allergens emphasised within that list when they are present as ingredients.

The food name must use a legal name where one is prescribed. If there is no legal name, use a customary name or an accurate descriptive name that lets the customer understand the true nature of the food and distinguish it from products with which it could be confused.

Do not treat those three items as the complete labelling law for every product. Existing rules can require additional particulars, warnings or ingredient percentages in specific circumstances. Meat products, sweeteners, certain colours, high-caffeine products and alcoholic drinks are examples where further provisions may need to be checked.

How should allergens be emphasised?

If a regulated allergen is present as an ingredient, its name must be emphasised within the ingredients list. The 14 regulated groups are:

• celery;
• cereals containing gluten;
• crustaceans;
• eggs;
• fish;
• lupin;
• milk;
• molluscs;
• mustard;
• peanuts;
• sesame;
• soybeans;
• sulphur dioxide and sulphites above the specified concentration; and
• the regulated tree nuts.

Emphasis can use bold type, capital letters, underlining or a contrasting colour. Choose a method that remains clear on the actual label and use it consistently. Emphasise the allergen every time it appears, including inside a compound ingredient. A general “contains” box should not replace emphasis in the ingredients list.

Name the allergen clearly. For a cereal containing gluten, identify the cereal, such as wheat or barley. For nuts, identify the specific regulated nut rather than relying only on the word “nuts”.

How should ingredients be listed?

The list must be headed or preceded by the word “ingredients”. Ingredients are normally listed in descending order of weight at the time the product is made, subject to the exceptions in food information law.

Compound ingredients need particular attention. A sandwich label cannot normally list only “bread” if the bread itself contains several ingredients. The relevant components of the bread must be declared in accordance with the rules, and allergens within them must be emphasised. The same principle applies to sauces, dressings, seasoning mixes, mayonnaise, fillings and other bought-in components.

Build the label from the current recipe and the current specifications supplied for every ingredient. Do not copy an old label, website description or handwritten recipe without checking that it matches what staff are actually using.

Can the label be handwritten?

Yes. FSA guidance says PPDS labels may be handwritten provided they meet the applicable presentation and font-size requirements, remain clearly legible and emphasise allergens appropriately.

Whether printed or handwritten, the mandatory information must appear on the package or on a label attached to it. It must be visible and clearly legible, and the customer should not have to open the packaging to find it.

A workable fallback matters. If a printer, label program or network fails, decide in advance whether staff will use an approved handwritten template, reserve pre-printed labels or stop producing PPDS food until accurate labels are available. A blank label and a hurried guess are not a safe contingency.

Should a PPDS label say “may contain”?

Precautionary allergen wording such as “may contain” is not one of the core mandatory PPDS particulars. Official guidance recommends communicating a genuine residual risk of unintended allergen presence on the package, but only after a risk assessment shows that the risk cannot be removed through controls such as segregation and effective cleaning.

Do not use blanket “may contain all allergens” wording as a substitute for assessing cross-contact. Unnecessary warnings can mislead customers and restrict choice. Equally, supplier precautionary information should not disappear when a component is incorporated into a PPDS product: assess it and pass on relevant information.

How should recipe and supplier changes be controlled?

The business packing the product is responsible for the accuracy of its label. That requires more than designing the label correctly once. Put a controlled change process around recipes, ingredients and labels:

1. Keep an approved recipe for each PPDS product.
2. Link every bought-in component to its current supplier specification.
3. Review the label before a recipe, brand, pack size or supplier substitute goes live.
4. Remove obsolete labels from the preparation and packing area.
5. Check the first finished pack against the recipe at the start of production and after a change.
6. Record who approved the change and when it became effective.

A “temporary” ingredient substitution is still a change. If the replacement mayonnaise, bread or sauce has a different composition, the old label may immediately become inaccurate.

What should you do if a label is wrong?

Stop selling the affected food and prevent further packs from reaching the display. Identify the products, batches, preparation times and locations involved. Compare the actual ingredients with the label and assess whether the error creates a food-safety risk, particularly an undeclared allergen.

Then:

• isolate and clearly mark affected stock;
• correct the recipe, source data or label template;
• check whether any affected food has already been sold or transferred;
• escalate immediately under the incident and withdrawal or recall procedure where consumer safety may be affected;
• contact the relevant local authority or regulator when required or when the response is uncertain;
• record the decision, quantities, locations and corrective actions; and
• verify the corrected label before production restarts.

Relabelling may be possible only when the business can prove the corrected information is accurate and the food remains safe and suitable. Do not simply place one label over another without controlling which products are affected and preventing the obsolete version from being used again.

What should multi-site operators standardise?

Multi-site businesses should control the data centrally enough to avoid inconsistent labels while leaving clear responsibility at site level. Standardise:

• the test used to classify a product as PPDS;
• the approved recipe and ingredient-specification record;
• the allergen emphasis format;
• label-template ownership and version numbers;
• the approval route for substitutions and recipe changes;
• the first-pack or opening check;
• printer-failure and label-shortage contingencies;
• withdrawal of obsolete label stock;
• incident escalation for a suspected mismatch; and
• periodic verification that the pack, recipe and label agree.

A central template cannot protect customers if a site changes an ingredient without updating the label. A local check cannot work if staff do not know which recipe version is approved. The control needs both reliable source information and verification at the point of packing.

Law, guidance and good practice

• Law: since 1 October 2021, PPDS food across the UK must carry the food name and a full ingredients list with regulated allergens emphasised within it.
• Law: the name, ingredients and presentation must meet the food-information rules applicable in the nation where the food is sold; additional product-specific requirements can apply.
• Official guidance: the FSA guidance applies to England, Wales and Northern Ireland; Food Standards Scotland publishes separate Scottish guidance.
• Guidance: handwritten labels are acceptable when they meet the applicable presentation requirements and remain visible and legible.
• Guidance: precautionary allergen wording should reflect a real residual risk identified by assessment and should not replace good hygiene or cross-contact controls.
• Good practice: version-controlled recipes, supplier specifications, first-pack checks, obsolete-label withdrawal and a documented change process reduce the risk of a correct label becoming incorrect later.

Practical PPDS label checklist

• Confirm that the food meets the PPDS definition.
• Use the correct legal, customary or descriptive food name.
• Include a full ingredients list headed “Ingredients”.
• List ingredients in the required order.
• Break down compound ingredients where the rules require it.
• Emphasise every regulated allergen each time it appears.
• Check for product-specific particulars and warnings.
• Make the label visible and clearly legible without opening the pack.
• Match the label to the current recipe and supplier specifications.
• Verify the first finished pack and every changed product.
• Remove obsolete labels from use.
• Keep a controlled contingency for printer or system failure.
• Stop sale and escalate any ingredient-label mismatch.