Quick answer: what applies in August 2026
Natasha's Law remains the rule for PPDS food. Food that is cooked or assembled only after a customer orders is not PPDS, but the business must still provide accurate information about the 14 regulated allergens. For non-prepacked food, the FSA recommends written allergen information supported by a conversation with staff.
Owen's Law remains a campaign for stronger restaurant allergen rules, not a separate law. Do not wait for a possible future change: apply the current PPDS rules, maintain a current allergen matrix and make accurate written information easy for customers and staff to use.
The 60-second status check
If you have one minute, here is the position as of August 2026:
| Rule | Status | Who it covers |
|---|---|---|
| Natasha's Law (Food Information (Amendment) Regs 2019) | In force since 1 Oct 2021 | PPDS food only — sandwiches/salads/cakes packaged on-premises before sale |
| Food Information Regs 2014 | In force | Everyone — restaurants must give accurate allergen information about every dish, however that information is provided |
| FSA out-of-home guidance (March 2025) | Best practice, not law | Restaurants, cafes, takeaways, delis, market stalls. Allergen info in writing + staff actively asking about allergies |
| Owen's Law | Campaign / proposal — not law | If it becomes law: full written allergens on menu boards as a legal mandate, not best practice |
The key distinction is PPDS versus non-prepacked food. Natasha's Law sets mandatory label content for PPDS products; other restaurant dishes remain subject to allergen-information duties, with the FSA recommending a written format backed by a staff conversation.
What Natasha's Law actually requires (still)
Natasha's Law is the everyday name for the Food Information (Amendment) (England) Regulations 2019. It came into force on 1 October 2021 in England and was followed by equivalent rules in Wales, Northern Ireland and Scotland. It is named after Natasha Ednan-Laperouse, who died aged 15 in 2016 after eating a Pret a Manger baguette containing undeclared sesame.
The law specifically covers prepacked for direct sale (PPDS) food — items packaged on the premises before the customer orders them. The most common categories:
- Sandwiches and wraps in a deli cabinet or grab-and-go fridge
- Salads in a chiller
- Pastries, slices and cakes wrapped on the counter
- Bottled smoothies, kombuchas, juices, made and bottled in-house
- Pre-portioned takeaway boxes for a buffet or delivery
For every PPDS item, the label must show: the name of the food, the full ingredients list, and the 14 regulated allergens emphasised within the ingredients list (typically bold). The 14 allergens are covered in detail in our separate guide — celery, cereals containing gluten, crustaceans, eggs, fish, lupin, milk, molluscs, mustard, nuts, peanuts, sesame, soya, sulphites.
A dish that is cooked to order — most of a typical restaurant menu — is not PPDS. The chef plates it in response to the customer's order. That's why the strict labelling rules don't apply on the printed menu the way they do on a packaged sandwich. The food is still subject to the wider duty to provide allergen information under the Food Information Regulations 2014; the difference is that for cooked-to-order food the law does not specify the format.
That difference in format is why a restaurant needs to identify which products are PPDS before deciding what must appear on each label or menu.
The big change — March 2025 FSA out-of-home guidance
On 5 March 2025, the Food Standards Agency published updated industry guidance for the out-of-home sector — restaurants, cafes, takeaways, delis, market stalls, and online food sales. The guidance applies in England, Wales and Northern Ireland.
The headline change: out-of-home food businesses should provide allergen information in writing for non-prepacked food, AND staff should actively ask customers about allergies at the point of order. "In writing" can mean any of:
- Allergen information directly on the menu (paper or digital)
- An allergen information booklet kept at the table or front-of-house
- An allergen matrix — typically dishes on one axis, the 14 allergens on the other, with ticks
- QR code on the menu linking to a digital allergen sheet
The FSA also published free supporting tools — allergy icons, an allergen matrix template, and an allergy poster — for restaurants to download and use.
Important nuance: the March 2025 guidance is best practice, not a new labelling law. It does not amend the Food Information Regulations 2014, but the underlying duty to provide accurate information about regulated allergens still applies.
A second, more subtle change in the March 2025 guidance: the FSA's view is that the catch-all phrase "No Gluten Containing Ingredients" (NGCI) should not be used. Restaurants have used NGCI labels as a halfway-house between "contains gluten" and a full "gluten-free" claim. The FSA's position is that NGCI is confusing for coeliac customers and should be phased out — use clear allergen-flag language (e.g. "contains wheat") or, where genuinely accurate, a fully verified "gluten-free" claim.
Owen's Law: campaign, not current legislation
Owen's Law is a campaign to make written allergen information a statutory restaurant requirement. It is named after Owen Carey, who died after eating food containing an allergen he had told restaurant staff about.
The Owen's Law proposal would require, in restaurants:
- The 14 major allergens listed in writing on menus or menu boards, before the customer has to ask
- Staff actively asking every customer about allergies at the point of order
- Mandatory documented allergen training for every food-handling employee (not voluntary)
As of August 2026, those proposals have not been enacted as a separate UK law. They are clearly marked here so restaurant owners do not confuse a campaign with current statutory requirements. Following the FSA's written-information best practice is still the safer operational standard.
Related allergen practice worth knowing
Precautionary allergen labelling ("may contain")
"May contain traces of nuts" and similar statements — known as precautionary allergen labelling (PAL) — have come under scrutiny because restaurants over-use them as a defensive catch-all. The FSA's direction in 2025-2026 is that PAL should be used only when there is a genuine, evidenced risk of cross-contamination, not as a routine disclaimer on every menu. Over-using PAL is itself unhelpful — allergic customers learn to ignore it, which is exactly the opposite of what the label is for.
What every UK indie restaurant should do this week
The cost of applying the current guidance is low compared with the harm caused by incorrect allergen information. Five concrete moves you can make in a working week:
- Build or refresh your allergen matrix. Put dishes on one axis and the 14 allergens on the other. Include every marinade, sauce, garnish and oil. Link the matrix to your wider controls in a free HACCP plan template UK.
- Get it in writing on the menu — or one click away. Long-term: allergen info should appear directly on the menu, either inline per dish or via a clear "see allergen matrix on the back" instruction. Short-term: a printed allergen booklet kept at the host stand and pass satisfies the guidance.
- Train every server and document it. Staff should know how to start an allergen conversation, where the written information is kept and when to stop and check with the kitchen. Record induction and refresher training.
- Allergens on the kitchen ticket, never verbal. If a customer has an allergy and your POS doesn't carry the allergen flag onto the kitchen ticket — fix that this week. Verbal allergen handovers at a busy pass are how restaurants end up on the phone with the FSA. We covered this in detail in our FOH ↔ kitchen communication piece.
- Phase out "No Gluten Containing Ingredients" (NGCI) labels. Replace with clear language: "contains wheat", "contains barley", or a verified "gluten-free" claim if you can support it. The FSA position is that NGCI confuses customers and should not be used.
If you do all five this week, you will be closer to the FSA's current best practice and have a clearer audit trail when recipes, suppliers or staff change.
The trap — common allergen mistakes that show up at inquests
Court reports and inquests in UK allergen-related deaths since Natasha's Law repeat the same five patterns. None are exotic. All are avoidable on a normal Tuesday.
| Pattern | Where it goes wrong | Fix |
|---|---|---|
| Marinades not disclosed | Menu says "grilled chicken"; chicken was marinated in buttermilk. Diner had a dairy allergy. | Treat every marinade as a named ingredient. Add to the matrix. |
| Verbal allergen handover | Server tells the kitchen "this one's a nut allergy" — the kitchen half-hears, the ticket prints without the flag. | Allergens on the ticket only. Never verbal at the pass. |
| "It's always been gluten-free" regular customer assumption | Regular orders the same dish for years; supplier changes their thickener; no one flags it. | Allergen matrix updated every time a supplier or recipe changes — even when nothing else changes. |
| "May contain" used as a blanket | Every dish is labelled "may contain traces of nuts" — customer learns to ignore. | Use PAL only where there's evidenced cross-contamination risk. Real exposure assessment, not defensive blanket. |
| "The chef knows" | Allergen handling depends on one chef being on shift. Day off, locum cooks, mistakes the dish. | Written allergen procedure in the kitchen — same for any chef. Not "the chef knows". |
What changes for chains, what changes for indies
Big chains have had compliance teams working on the March 2025 guidance since the day it dropped — most of them update their allergen matrices weekly and their menus quarterly. The strict-letter compliance gap is small at scale.
The harder operational test of 2026 is the indie restaurant: 20-30 covers, one owner-operator, two chefs, a rotating cast of part-time servers. The compliance lift is the same — written allergens, staff asking, documented training — but the resourcing is one person with a laminator on a Sunday. The good news is that the rules are completely doable at indie scale. The bad news is that "I'll get to it" is what every owner-operator says, until the FSA notice arrives or worse.
The five-move list above is sized for an indie kitchen. It addresses the controls that matter now, without assuming that a proposed future law has already passed.
Where Blueroll fits
The reason we built Blueroll the way we did is exactly this — the allergen matrix should not live on a laminated sheet that gets food-stained and forgotten. It should live in the recipe itself, so that every menu PDF, every kitchen ticket, every server-side reference, and every customer-facing digital menu shares the same allergen flags automatically. Change the supplier of a single ingredient and the system propagates the change to every dish that uses it. Try Blueroll free for 14 days — allergen tagging is built into recipe entry, and the FOH ticket carries the flag automatically.
You don't need our app to comply. The five moves above work on paper. But the cost of "I'll get to it" is hours of work that does not happen, leaving outdated information in front of staff and customers.
Frequently asked questions
Does Natasha's Law apply to restaurants that cook food to order?
Not directly. Natasha's Law (the Food Information (Amendment) (England) Regulations 2019, in force since October 2021) applies specifically to PPDS — prepacked for direct sale — food: items made on the premises and packaged BEFORE the customer orders them. Sandwiches in a deli cabinet, salads in a chiller, cakes in a wrapper. A dish cooked to order is not PPDS, so the strict labelling rules don't apply at the menu level. BUT restaurants are not off the hook: under the Food Information Regulations 2014, restaurants must still provide accurate allergen information about every dish, and as of March 2025 the FSA expects it to be in writing.
What is the FSA's March 2025 best practice guidance and does my restaurant have to follow it?
The FSA recommends that allergen information for non-prepacked food is available in writing and supported by a conversation with staff. This is best-practice guidance rather than a new labelling law, but the underlying legal duty to provide accurate information about the 14 regulated allergens still applies.
What is Owen's Law and is it law yet?
Owen's Law is a campaign for stronger written allergen information in restaurants, proactive questions from staff and better training. As of August 2026 it has not been enacted as a separate UK law. Restaurants must follow the allergen rules already in force, including Natasha's Law for PPDS food, and should follow current FSA best practice for non-prepacked food.
What applies to restaurants in 2026?
PPDS food must show the food name and a full ingredients list with any of the 14 regulated allergens emphasised. For food cooked to order or otherwise sold non-prepacked, businesses must provide accurate allergen information; the FSA recommends making it available in writing and supporting it with a staff conversation.
What's the cheapest fastest way to comply with the March 2025 FSA guidance this week?
Three things, in order. (1) Build an allergen matrix — every dish on one axis, the 14 UK allergens on the other, tick the boxes. Print it. Laminate it. Keep one at the pass and one at front-of-house. (2) Add a single line to your menu or menu boards saying allergen information is available — and physically show the matrix on request. Long-term, allergens should appear on the menu itself; short-term a separate document satisfies the guidance. (3) Train every server, every shift, on the rule: ALWAYS ask the table "any allergies?" before taking the order. Document the training (one A4 sheet signed by each server is enough).
Related guides
- The 14 EU allergens — complete UK guide
- Free HACCP plan template UK
- How to fix front-of-house and kitchen communication (allergens on ticket, never verbal)
- First-week onboarding checklist for new restaurant staff (includes documented allergen training)
- How to onboard a new chef in 14 days, not 6 weeks
- Restaurant opening checklist — 30 pre-service checks
Sources & further reading
Primary sources (UK government & FSA): GOV.UK — PPDS allergen labelling changes for restaurants, cafes and pubs (updated 17 July 2026); FSA — Natasha's Law and PPDS food; FSA — Updated out-of-home allergen guidance (5 March 2025); FSA — Best-practice allergen information for non-prepacked food.
Owen's Law status: Owen's Law — Campaign requirements; FSA Board minutes — Owen's Law discussion.
Disclaimer: This article is a plain-English summary of UK allergen requirements as of August 2026. It is not legal advice. For a binding interpretation in your specific case, consult a food law solicitor or your local authority's environmental health team.
