The Food Standards Agency has published its five-year review of Natasha's Law — the allergen labelling legislation that came into force in October 2021 requiring full ingredient and allergen labelling on all food prepacked for direct sale — and the picture it presents is one of genuine progress alongside persistent, worrying gaps.
Among large food businesses, retailers and national hospitality chains, compliance is described as "broadly strong," with labelling accuracy and allergen declaration across the 14 major allergens meeting regulatory requirements in the substantial majority of cases assessed. Among small and micro operators — the independent cafés, sandwich bars, bakeries and small caterers that form the long tail of the UK food sector — the picture is considerably less consistent.
Key findings
The FSA's review draws on data from local authority inspections, mystery shopping exercises, consumer complaints and allergen incident reporting over the five years since the legislation came into force. Among its principal findings:
- Large business compliance: 94% of inspected large and medium businesses were found to be fully compliant with PPDS labelling requirements across all products assessed
- Small operator compliance: The figure falls to 71% among businesses employing fewer than 10 staff — a figure the FSA describes as "inadequate" given the severity of the risk
- Most common failures: Missing allergen declarations (particularly for cereals containing gluten, sesame and celery), inaccurate ingredient lists, and labelling that does not survive recipe changes made after the label was created
- Near-miss incidents: Allergen incident reporting to the FSA has risen 22% over the review period, though the agency notes this may partly reflect improved reporting culture rather than an increase in actual incidents
- Consumer awareness: 78% of UK adults with a food allergy or intolerance are now aware of Natasha's Law, up from 54% at the time of implementation
Why small operators continue to struggle
The review identifies three primary reasons for the compliance gap among smaller businesses. The first is resource — small operators frequently lack dedicated staff time for compliance administration and may not have the systems in place to update labels consistently when recipes or ingredients change.
The second is knowledge. The FSA's own research indicates that a significant proportion of small food business operators do not fully understand which foods are captured by the PPDS definition, leading to either over-labelling (low risk) or under-labelling (high risk, particularly for foods made fresh and held for later sale).
The third is enforcement capacity. Local authority food safety teams remain under-resourced in many areas, meaning that inspection frequency for small food businesses falls short of what would be needed to maintain consistent pressure on compliance levels.
What comes next
The FSA has announced a new targeted support programme for small PPDS businesses to be launched later in 2026, including free online guidance, a revised labelling tool and a programme of local authority-led workshops. The agency has also indicated it will work with the Department for Business to explore whether the enforcement framework for repeat labelling failures needs strengthening.
For operators in scope: the five-year review makes clear that the FSA's attention to PPDS compliance is not diminishing. Businesses that have treated Natasha's Law as a one-time compliance exercise rather than an ongoing operational commitment should treat this review as a prompt to audit their current labelling practices.