PPDS vs Non-PPDS: The Decision Guide for UK Food Labels

Three questions decide whether your food needs full PPDS labelling. Get all three right and the rest of the compliance question mostly falls into place. Get one wrong and you either over-label food that didn't need it, or under-label food that did, which is the version that gets Trading Standards involved.

Here's the test, and then the cases that actually trip people up.

The three-part test

Food is PPDS if the answer to all three of these is yes:

1. Is the food in packaging when the customer sees it?
2. Was it packaged before the customer chose or ordered it?
3. Was it packaged at the same place it's being sold?

Miss any one of the three and it isn't PPDS. It might still need allergen information under general non-prepacked rules, just not a full ingredients label with allergens emphasised.

That sounds simple. In practice, most of the confusion lives inside question three, and inside a handful of scenarios that don't map cleanly onto "bakery sells sandwich."

Where this actually gets confusing

• A sandwich sealed and put in the chiller before anyone orders it: yes, PPDS. Meets all three criteria.
• A sandwich made to order while the customer waits, then wrapped: not PPDS. Packaged after the order, so it fails criteria 2.
• Cakes sealed in cellophane before a market stall opens: yes, PPDS. Same premises, packaged before sale.
• Loose cakes on a stand, bagged only once a customer points at one: not PPDS. Packaged at the customer's request.
• Cupcakes under a single covered display dome, sold individually: usually not PPDS. The dome isn't packaging for an individual item, and the cupcakes aren't sealed one by one.
• Ice cream tubs packed on-site and sold from the same counter: yes, PPDS, even though it feels more like a manufactured product than a fresh-food item.
• Soup with a bread roll on a restaurant menu: not PPDS. It isn't presented in packaging at all.
• Food ordered by phone or online and delivered: not PPDS. Distance sales fall outside the PPDS labelling requirement, though allergen information must still be given before purchase and again at delivery.
• A stall inside a shopping centre selling food packed at a different unit in the same centre: it depends. The FSA treats a shopping centre or similar complex as one "site," so food can count as PPDS even when packaging and selling happen in different units within it.

If you're still not sure after working through these, the FSA runs a free allergen and ingredients food labelling decision tool that walks through your specific situation. When in doubt, most enforcement officers apply the same default we'd suggest: treat it as PPDS. Over-labelling costs you a slightly longer ingredients list. Under-labelling costs a lot more.

A note on distance sales

This one catches out more businesses than it should. If a product would normally count as PPDS but you're selling it by phone, website, or app for delivery, the PPDS labelling requirement doesn't apply to that sale. You still have to make full allergen information available before the customer buys and again at the point of delivery. It's a different mechanism, not an exemption from telling people what's in the food.

What to do once you know your product is PPDS

A confirmed PPDS product needs, at minimum:

The name of the food A full ingredients list, in descending order of weight All 14 legally recognised allergens emphasised consistently, wherever they appear

The part that actually causes problems isn't usually the initial label. It's keeping every SKU's label in sync as recipes change, suppliers reformulate, and new products borrow old templates. That's the gap between a business that's careful and a business that's compliant, and it's worth checking your current labels against the full requirement rather than assuming last year's template still holds up.

Check your current labels against the PPDS requirement before your next print run, not after.