Natasha's Law in 2026: what UK restaurants must know now

Why we're writing this in May 2026

Most "what is Natasha's Law" articles online were written in 2021 when the law first came in. They are out of date in three important ways. The FSA published major new best-practice guidance for the out-of-home sector in March 2025. The government publicly committed in June 2025 to evaluating how well restaurants have actually adopted that guidance. And that evaluation — the part that decides whether allergen rules go from "best practice" to "the law" — is happening right now, in Spring 2026.

This article is for an indie UK restaurant owner who wants 15 minutes of plain English and then knows what to do this week. No legalese. No "consult a solicitor". Just the four things that have actually changed since the original law and the practical compliance moves a small kitchen can make without hiring a consultant.

The 60-second status check

If you have one minute, here's where every piece of UK allergen law stands in May 2026:

Two things should jump out. First — Natasha's Law in its strict form covers a much narrower category of food than most people think (PPDS, not "everything in a restaurant"). Second — the things that affect restaurants most in 2026 are NOT Natasha's Law itself but the March 2025 FSA guidance and the Spring 2026 review that follows.

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 word "format" is where the action of 2025-2026 has happened.

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.

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.

Why "best practice" feels closer to law than it sounds

In June 2025, the government committed during a House of Lords debate to evaluating how well businesses have adopted the March 2025 FSA guidance — and that evaluation began in Spring 2026. It is happening now. The FSA is gathering data on whether restaurants have moved to written allergen menus and proactive staff questioning, and the results will be reported to ministers later in the year.

The conclusion of that review then informs whether Owen's Law — the proposal to make written allergen information a statutory legal requirement, not just best practice — should be drafted into legislation. Owen's Law is named after Owen Carey, who died aged 18 on his birthday in April 2017 after eating a chicken burger at a Byron Burger restaurant in the O2, having clearly told the server he had a dairy allergy. The chicken was marinated in buttermilk; the menu did not mention this. The inquest in 2019 found that Owen "died from a severe food induced anaphylactic reaction from food eaten and ordered at a restaurant despite making staff aware of his allergies." His family has campaigned for Owen's Law since.

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)

If the FSA's Spring 2026 review concludes that voluntary uptake is not high enough, those three requirements are the strongest candidate for statutory legislation. Most legal commentary suggests a realistic timeline of 2027-2028 if the law passes — but the operational expectation is already in place via the March 2025 best practice. The pragmatic read for a restaurant in 2026: do the work now under "best practice", get used to it, and you won't need to scramble if it becomes law.

Two adjacent changes worth knowing

September 2026 — schools allergy guidance comes into force

Statutory guidance for managing allergies in English schools comes into force on 1 September 2026. Schools will be required to stock spare adrenaline auto-injectors, provide allergy awareness training for all staff, and adopt comprehensive policies for managing allergies and medical conditions. This doesn't apply to restaurants directly — but if you supply meals to a school, run an after-school programme, or host birthdays, expect more questions from parents about your allergen practices. The bar for "we'll be fine, no one's ever asked" has moved.

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 voluntary March 2025 guidance is being graded in Spring 2026 — and the cost of complying is low compared to the cost of an Owen-Carey-style incident or a regulatory shift you weren't ready for. Five concrete moves you can do in a working week:

1. Build (or refresh) your allergen matrix. One page. Dishes down, the 14 allergens across. Tick the boxes. Treat every marinade, sauce, garnish and oil as an ingredient — the buttermilk-on-grilled-chicken trap is exactly what Owen's Law was built to prevent. Free FSA matrix template is on food.gov.uk.
2. 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.
3. Train every server. Document the training. The single line every server needs to internalise: "Before I take your order — any allergies in the group?" One A4 sheet, signed by each server, dated, kept in the staff folder. Re-do it every six months and on every new hire. Mandatory training is the third leg of Owen's Law; if you've already documented it, you're ahead.
4. 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.
5. 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.

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.

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. Print it, do them, you're done. The bar for "ready when Owen's Law passes" is lower than you think.

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 what every indie restaurant has been pricing wrong — it's hours of weekend work that doesn't happen, and then an FSA review window that passes you by.

Related guides

• The 14 EU allergens — complete UK guide
• 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