Prepacked, PPDS & Non-Prepacked Labelling

Under the FIC, what makes a food item 'prepacked'?

• AIt is labelled with a price, a best-before date and the name of the shop where it was purchased
• BIt is wrapped by a member of staff after the customer has placed their order
• CIt is put into packaging before being offered for sale and cannot be altered without opening or changing that packaging✓
• DIt is sold in a container the customer fills themselves from a self-service display

Answer: Prepacked food is enclosed, fully or partly, in packaging applied before the food is offered for sale, in a way that the contents cannot be altered without opening or changing that packaging. Food wrapped only after a customer orders it does not meet this definition, and loose food that a customer bags up themselves from a self-service display is not prepacked. A price label or date mark is unrelated to the prepacked or non-prepacked distinction.

From what date did the PPDS labelling changes, often called Natasha's Law, take effect across all four UK nations?

• A1 October 2019
• B1 October 2022
• C1 October 2021✓
• D1 January 2024

Answer: The PPDS labelling changes came into force across England, Wales, Northern Ireland and Scotland on 1 October 2021, requiring a full ingredients list with emphasised allergens on this category of food. 1 January 2024 is instead the date on which EU law retained after EU exit became assimilated law in Great Britain, an unrelated change. The other dates are simply earlier or later than the true commencement date.

What is the minimum x-height for mandatory label text, including allergen information, on a prepacked food whose largest surface is 80 cm squared or more?

• A0.5 mm
• B0.9 mm
• C1.2 mm✓
• D2.0 mm

Answer: Mandatory label text, including the ingredients list with its emphasised allergens, must have an x-height of at least 1.2 mm. Packs whose largest surface is under 80 cm squared may use 0.9 mm instead. This comes from Article 13 of the Food Information to Consumers regulation.

A sandwich bar makes a baguette to a customer's specification and wraps it in film only after the order is taken at the counter. How should this item be classified for allergen labelling?

• APrepacked for direct sale, because it leaves the counter wrapped in film
• BNon-prepacked food, because it was not packed until after the sale process had already begun✓
• CExempt from allergen labelling entirely, because it was made to the customer's own specification
• DPrepacked food, because it will be eaten off-site

Answer: PPDS status depends on whether food was packed before it was offered for sale, not on whether it ends up wrapped. A baguette wrapped only after the order is taken is treated the same as any other non-prepacked food, such as a meal served in a restaurant, even though it is now in packaging. Prepacked food is a different category covering items packaged by one business for sale by another, and being made to a customer's own specification does not remove the duty to give allergen information.

What must a PPDS food label include under the labelling changes that came into force on 1 October 2021?

• AThe name of the food only, since PPDS items are exempt from ingredients lists
• BA single 'Contains' statement listing the allergens, without a full ingredients list
• CA telephone number customers can call for allergen information instead of a label
• DThe name of the food and a full ingredients list with every allergenic ingredient emphasised each time it appears✓

Answer: PPDS food must carry the name of the food plus a complete ingredients list, with allergenic ingredients emphasised, for example in bold or a contrasting colour, every time they occur. A short 'Contains' statement without the full list is only permitted for certain prepacked foods with very small packaging, not PPDS. PPDS items are not exempt from ingredients lists, and a phone number cannot replace the required on-pack information.

Which of these is the clearest example of PPDS food, as described in the FSA's technical guidance?

• AA packet of pre-made sandwiches delivered ready-wrapped from a separate manufacturer's factory and simply placed on a shelf
• BA rotisserie chicken that has already been boxed and placed under a hot lamp before any customer has ordered it✓
• CA hot dog served to a customer on an open cardboard tray with nothing else covering it
• DA burger that is assembled and then wrapped only once the customer has placed their order

Answer: A rotisserie chicken that is boxed and displayed under a lamp before it is chosen by a customer has been packed in anticipation of a sale, which is the essence of PPDS food. Sandwiches wrapped by a separate manufacturer and merely restocked on a shelf are prepacked food, not PPDS, because the packer and the seller are different businesses. An open cardboard tray does not stop the contents being altered, so it fails the packaging test, and a burger wrapped after the order is taken is non-prepacked, not PPDS.

A bottle of wine needs no ingredients list but contains sulphites above 10 mg per litre. How must the allergen be declared on its label?

• AWith the word 'Contains' followed by the allergen's name, such as 'Contains sulphites'✓
• BThrough a precautionary 'may contain sulphites' statement on the back label
• CIt needs no declaration, because a product without an ingredients list is exempt
• DOn a shelf-edge notice next to the bottles, instead of on the label itself

Answer: Where a prepacked food has no ingredients list, its allergens are declared with the word 'Contains' followed by the allergen's name. This comes from Article 21 of the Food Information to Consumers regulation. Precautionary 'may contain' wording is for unintended cross-contamination, not for an ingredient that is actually present.

A single-portion sauce sachet has a surface area smaller than 10 cm squared. What allergen labelling flexibility does this give the business?

• AThe full ingredients list can be left off the sachet if the presence of any Annex II allergen is declared using a 'Contains' statement and the ingredients information is available by other means✓
• BThe allergens can be described only as 'may contain allergens', without ever naming any of the individual allergens involved
• CNo allergen information needs to be given at all, because the sachet's packaging is far too small to fit any of the 14 allergen names printed clearly enough for a customer to read without difficulty
• DThe business can replace the ingredients list entirely with a barcode that links through to an external website with more details

Answer: Where packaging is smaller than 10 cm squared in surface area, the ingredients list itself can be omitted, but any Annex II allergens present must still be declared, typically with a 'Contains' statement, and full ingredient information must remain available to the customer by other means. Skipping allergen information altogether is never permitted regardless of pack size. A vague statement naming no specific allergen, or substituting a barcode for the required on-pack declaration, would not meet the requirement.

A bakery sells PPDS pastries only through a mail-order website, never in person. How does the ingredients-list requirement apply to these online sales?

• AThe bakery must still print a full PPDS ingredients list with allergens emphasised on every parcel, exactly as it would for a pastry sold over the counter
• BThe full PPDS ingredients list is not required for mail-order sales; instead the distance-selling rules apply, so allergen information must be available before the purchase and again at delivery✓
• CThe bakery is exempt from providing any allergen information at all, because the PPDS labelling rules only ever apply to food that is sold face to face
• DThe bakery only needs to give allergen information once, at the point the order is delivered to the door, so nothing has to be shown on the website first

Answer: Where PPDS food is sold entirely online, by phone or by mail order, the national ingredients-list rule for PPDS does not apply; instead the distance-selling provisions require allergen information to be available before the purchase is completed and again when the food is delivered. This is a genuine relaxation, so insisting on a full printed PPDS label for every parcel misstates the rule. Selling online never removes the duty to give allergen information, and giving it only once, at delivery, would fail the two-stage requirement.

A customer orders through a drive-through screen at a restaurant, with staff and customer both present at the same location when the order is placed. Does this count as distance selling for allergen-information purposes?

• AThis is distance selling, because the restaurant also takes telephone orders for exactly the same menu items
• BThis is not distance selling, provided the customer pays in cash rather than by card at the window
• CThis is not distance selling, because the customer and the business are simultaneously physically present at the point of order✓
• DThis is distance selling, because the order is placed through an electronic screen rather than face to face with a member of staff

Answer: Distance selling means the consumer and the supplier are not simultaneously physically present, and a drive-through order screen does not remove that simultaneous presence, so it is not treated as distance selling. Using an electronic screen instead of speaking to a person makes no difference to this classification. Whether telephone orders are also taken, or how a customer pays, has no bearing on whether the drive-through order itself counts as distance selling.

A hotel lays on a breakfast buffet with ten different dishes. How must allergen information be presented for this format?

• AAllergen information only needs to be given if a guest asks about a specific dish
• BAllergen information must be given for each dish separately, not as one single statement covering the whole buffet✓
• COne general sign at the entrance to the buffet stating that allergens 'may be present somewhere' is considered enough
• DOnly the three most popular dishes need allergen information

Answer: Buffet-style service still requires allergen information for each dish individually, for example through labels on each dish or a chart, rather than one blanket statement for the buffet as a whole. A vague sign warning that allergens 'may be present' somewhere in the buffet does not tell a customer which dish to avoid. Limiting detailed information to only the most popular dishes, or waiting for a guest to ask, does not meet the requirement to make information for every dish easily accessible.

Which of these is a means by which a restaurant can lawfully provide allergen information for its non-prepacked, cooked-to-order meals?

• AA symbol on the menu with no accompanying words or key explaining what it means
• BA note on the receipt printed after the meal has already been eaten
• CA verbal answer given only when a customer happens to overhear another table asking
• DFull written allergen information set out on the menu or a chalkboard✓

Answer: Full written allergen information on a menu or chalkboard is one of the accepted ways of meeting the requirement for non-prepacked food, alongside giving the information verbally with a clear written signpost. Information a customer only picks up by chance, or that only appears after the meal has been eaten, does not make the information easily accessible before the food is chosen. A symbol without accompanying words and numbers is not permitted, because it risks misleading or confusing the consumer.

A shop sells a prepacked bag containing only whole peanuts, labelled simply 'Peanuts'. What allergen declaration does the packaging need beyond the product name?

• AThe name alone is sufficient, because it already clearly identifies the single Annex II allergen the bag contains✓
• BA precautionary 'may contain nuts' statement is needed next to the product name
• CA full ingredients list is required, because the product is prepacked rather than sold loose
• DA separate 'Contains: peanuts' statement repeating the allergen on the bag

Answer: Where a food's name consists of a single ingredient and clearly identifies the Annex II allergen present, such as a bag simply labelled 'Peanuts', the name itself is enough and no further allergen indication or repeated 'Contains' statement is required. This exemption does not apply where the name does not obviously point to the allergen, such as gingelly oil, which is sesame oil and would still need a 'Contains: sesame' statement, so being prepacked does not by itself trigger a full ingredients list here. A precautionary 'may contain' statement is only for a genuine cross-contamination risk and is not what this rule requires.

A shop sells prepacked biscuits on its website. When must the allergen information be available to the online customer?

• AOn the pack once it has been delivered, with nothing needed on the website
• BOn the website before purchase, so the pack itself can be left unlabelled
• CBefore the purchase is completed, and on the pack when it is delivered✓
• DWhen the customer emails to ask for it, within a reasonable time

Answer: For prepacked food sold at a distance, the mandatory information, including allergens, must be available before the purchase is completed and again when the food is delivered. The website gives the customer what they need to choose safely. The label on the pack lets them check it again before eating.

A takeaway serves a hot dog on an open cardboard tray, with nothing else covering it. Why does this not count as PPDS food?

• ACardboard is not classed as packaging under the Food Information to Consumers regulation, because it is a paper-based material rather than a plastic one
• BThe hot dog is sold from a takeaway, and PPDS labelling rules apply to supermarkets and food manufacturers rather than to takeaways
• CThe tray does not enclose the food in a way that prevents the contents being altered without opening or changing the packaging✓
• DThe hot dog is sold at a price below the threshold that triggers PPDS labelling

Answer: PPDS status depends partly on whether food is enclosed in packaging that cannot be altered without opening or changing it, and an open cardboard tray leaves food freely accessible, so this test is not met. PPDS rules are not limited to supermarkets or manufacturers; cafés, takeaways and other food businesses that pack food on site before it is ordered are covered too. Cardboard can be packaging in other contexts, and there is no price threshold anywhere in the guidance that determines PPDS status.

A pork pie is packed by one bakery and then sold, still in that same packaging, by a different trader at a farmers' market. How is this pie classified for allergen labelling?

• AAs prepacked food, because it was packed and sold by two different businesses rather than the same one✓
• BAs non-prepacked food, because the trader who is now selling it did not make the pie themselves or handle its original packaging
• CAs PPDS food, because it is sold from a temporary market stall
• DAs exempt from allergen labelling altogether, because farmers' market stalls fall outside the scope of food law

Answer: PPDS specifically covers food packed and sold by the same food business; when one business packs the food and a different business sells it, it is prepacked food and must carry a full ingredients list rather than being treated as PPDS. Selling from a temporary stall only brings food into the PPDS category when the packer and the seller are the same operator. Not having made the food does not turn it into non-prepacked food, and market stalls are not exempt from allergen labelling.

How must allergenic ingredients be shown within a prepacked or PPDS food's ingredients list?

• AEmphasised using a method such as bold text, a contrasting colour, capital letters or underlining, chosen at the business's discretion✓
• BListed twice, once in the ingredients list and again in a separate 'Contains' box
• CHighlighted when the food business separately chooses to make a voluntary gluten-free claim
• DPrinted in a footnote at the bottom of the label, separate from the ingredients list

Answer: Businesses have flexibility in exactly how they emphasise Annex II allergens within the ingredients list, using methods such as bold type, a contrasting colour, capital letters or underlining, provided the allergen stands out from the surrounding text. Where a full ingredients list is already provided, repeating the allergens again in a separate 'Contains' statement is not permitted, because information must be presented in one consistent format. Allergens must be emphasised within the list itself, not tucked away in a footnote, and this duty applies regardless of whether any gluten-free claim is made.

How does the allergen information duty for non-prepacked food, such as a meal served in a restaurant, differ from the duty for PPDS food?

• ANon-prepacked food only requires information about which allergenic ingredients are used, not a full ingredients list, whereas PPDS food requires a full emphasised ingredients list✓
• BNon-prepacked food requires a full ingredients list with every allergen emphasised in exactly the same way as prepacked food, while PPDS food only requires a verbal answer given on request
• CThere is no real difference at all; both categories must always carry exactly the same identical printed label
• DNon-prepacked food carries no allergen information duty at all in any circumstances whatsoever, while only PPDS food is legally required to give customers any information about allergens

Answer: For non-prepacked food, the legal duty is to make customers aware of which allergenic ingredients are used, without requiring a complete ingredients list, whereas PPDS food specifically requires a full ingredients list with allergens emphasised every time they appear. This is the reverse of the true position - it is PPDS food, not non-prepacked food, that requires a full ingredients list, and non-prepacked food is never limited to a bare verbal answer on request. The two categories are not treated identically, and non-prepacked food carries its own allergen information duty even though it is different in form from the PPDS duty.