Bakery allergen labelling is one of the least forgiving jobs in food compliance. A patisserie counter changes its range every few weeks, recipes run to twenty ingredients or more, and anything packed before a customer orders it is legally PPDS. Dill has started working with Le Café by Nicolas Rouzaud in London, and that counter is a good illustration of what the rules actually ask for and where the real work sits.
Published 28 August 2026. Last reviewed 28 August 2026.
What PPDS actually requires
Natasha's Law is the everyday name for four separate statutory instruments, one per UK nation: England SI 2019/1218, Wales WSI 2020/295, Northern Ireland SR 2020/80 and Scotland SSI 2021/70. All four came into force on 1 October 2021.
Food is prepacked for direct sale, or PPDS, when it is packed on the same premises it is sold from, before the customer orders it. A croissant put into a box after someone asks for it is not PPDS. A tray of eclairs boxed at 7am ready for the counter is.
The legal requirement for PPDS is short. The pack needs the name of the food and a full ingredient list, with any of the 14 regulated allergens emphasised inside that list. Emphasis means bold, capitals, a contrasting colour or similar, so the allergen stands out from the rest of the ingredients.
What PPDS does not require
This is where most counters over-label. A use-by date, a nutrition declaration, storage instructions, the business name and address, and net quantity are not PPDS requirements. Some of them may apply to you for other reasons, including your own food safety management system, but they do not come from Natasha's Law.
Three more things worth being precise about:
- A standalone "Contains: milk, eggs" line does not satisfy the rule on its own. The allergen has to be emphasised within the ingredient list itself.
- There is no small business exemption. A single-site bakery has the same duty as a national chain.
- Distance selling is exempt from the on-pack ingredients duty. If you ship, the information has to reach the customer at the point of order and again at delivery, but the box itself is treated differently.
On enforcement, the penalty under the Food Information Regulations is a fine at level 5 on the standard scale on summary conviction. There is no prison sentence attached to it. In practice, what an environmental health officer looks at first is consistency: whether the label on the shelf matches the recipe in the kitchen.
Why a patisserie is the hard version of this
Most PPDS guidance is written with a sandwich counter in mind. A patisserie breaks that model in three ways.
The range moves. A seasonal entremet arrives, a tart comes off, a chef reworks a ganache. Every one of those changes is a label change. If labels live in a template file, the template becomes wrong the moment the kitchen moves and nobody notices for a month.
The recipes are nested. A gateau is a recipe made of other recipes: a sponge, a praline, a glaze, a chocolate decoration. The ingredient list on the box has to be broken down to the actual ingredients, not the components. Doing that by hand for thirty products is where errors get in.
The wording is legally defined and it is easy to get slightly wrong. The allergen is "cereals containing gluten", with the specific cereal named, not "gluten". The allergen is "nuts", meaning eight named species: almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios and macadamias. "Tree nuts" is American wording and is not the legal term here. The FSA allergen guidance sets out all 14.
There is a fourth problem that is not legal at all. On a luxury counter the box is part of the product. A compliant ingredient list has to go onto that box without making it look like a supermarket meal deal. That is a design constraint, and pretending it does not exist is why so many bakeries end up with a handwritten sticker on the underside.
What this looks like in a pastry kitchen
Nicolas Rouzaud spent seven years at Le Bristol Paris under Eric Frechon and the late Laurent Jeannin, became Head Pastry Chef at The Lanesborough in 2014, and joined The Connaught in 2017, where he opened The Connaught Pâtisserie and still lends his name to the patisserie there. Le Café is his own. It is the kind of kitchen where a single entremet runs four recipes deep and the range moves with the season, which is exactly the setting where PPDS gets difficult.
The principle is simple enough. Recipes are held once. For any product set up in the system, the ingredient list on the label is generated from that recipe rather than typed, allergens are emphasised automatically using the legal wording, and the label prints on Brother hardware at the counter.
When a chef changes a recipe, they change it in one place and the labels built from it follow. Underneath that sits a log of what was printed and when, which is the part that matters when someone asks you to prove what a label said three months ago.
It is worth being clear about scope. A counter like this sells across several categories, from pastry to sandwiches, and a labelling system is rolled out product by product rather than switched on across everything at once. The point is not that a system solves a counter overnight. It is that once a product is in it, the label stops depending on anyone remembering to update a template.
Six things to check on your own counter
- Is anything prepacked before the customer orders it? If yes, it is PPDS, whatever you call it internally.
- Does the ingredient list on the label come from the recipe, or from a document someone typed once?
- Are allergens emphasised inside the ingredient list, rather than only in a separate "contains" line?
- Are you using the legal wording, including "cereals containing gluten" with the cereal named?
- Who updates the label when a chef changes a recipe on a Tuesday afternoon, and how long does that take?
- Could you show an inspector what a given product's label said last quarter?
One honest note on use-by dates
Dill prints a use-by date by default, and most bakery operators want one. It is worth being clear that this is shelf life management, not a Natasha's Law requirement. Both are useful. They are not the same duty, and treating a date field as proof of PPDS compliance is a common way to end up non-compliant while feeling covered.
Further reading
Our full Natasha's Law and PPDS guide covers the rules in detail, including a decision tool for working out whether a product is PPDS.
If you run a bakery or patisserie counter and PPDS is currently held together by a spreadsheet and someone's memory, that is the conversation worth having. Bring the messy version of your setup, not the tidy one.