Natasha's Law Compliant Labelling for Food Supplements: Complete 2026 Guide

Natasha's Law Compliant Labelling for Food Supplements: Complete 2026 Guide

Natasha's Law — formally the Food Information (Amendment) (England) Regulations 2019 — came into force on 1 October 2021 and fundamentally changed how food businesses in England, Scotland, Wales, and Northern Ireland must label pre-packaged food for direct sale (PPDS). For food supplement manufacturers and distributors, the implications are significant: every product sold pre-packaged directly to consumers must now carry a full ingredient list with all 14 major allergens clearly emphasised.
This guide explains exactly what Natasha's Law requires, how it applies to food supplements, and how label-checker.com can automate your allergen compliance checking.
What is Natasha's Law?
Natasha's Law is named after Natasha Ednan-Laperouse, a 15-year-old who died in 2016 after suffering an anaphylactic reaction to sesame seeds baked into a Pret a Manger baguette. The sesame was not declared on the packaging because, at the time, PPDS food was exempt from full ingredient labelling.
The legislation closed that loophole. Under Natasha's Law, all PPDS food — including food supplements — must display:
- The name of the food
- A full ingredients list
- Allergen emphasis — all 14 major allergens must be highlighted in the ingredient list using bold, italic, underline, or contrasting colour
Key definition — PPDS food: Food that is packaged on the same premises from which it is sold, before the customer orders it. This includes supplements sold at health food stores, pharmacies, gyms, and online marketplaces where the product is pre-packed at the point of manufacture or dispatch.
The 14 Major Allergens Under UK Law
The UK Food Information Regulations 2014 (as retained in UK law post-Brexit) require the following allergens to be declared and emphasised whenever they are present as ingredients or processing aids:
| # | Allergen | Common Sources in Supplements |
|---|---|---|
| 1 | Cereals containing gluten | Wheat-based fillers, barley malt extract |
| 2 | Crustaceans | Marine collagen, glucosamine (shellfish-derived) |
| 3 | Eggs | Egg-white protein, lecithin |
| 4 | Fish | Omega-3 (fish oil), marine collagen |
| 5 | Peanuts | Peanut oil (carrier), protein blends |
| 6 | Soybeans | Soy lecithin (emulsifier), soy protein |
| 7 | Milk | Whey protein, casein, lactose |
| 8 | Nuts (tree nuts) | Almond oil, walnut extract |
| 9 | Celery | Celery seed extract |
| 10 | Mustard | Mustard seed extract |
| 11 | Sesame | Sesame oil, tahini |
| 12 | Sulphur dioxide & sulphites (>10 mg/kg) | Preservatives in liquid supplements |
| 13 | Lupin | Lupin flour, lupin protein |
| 14 | Molluscs | Glucosamine (mollusc-derived) |
Important: Cross-contamination risk statements (e.g., "May contain traces of nuts") are voluntary under UK law and do not substitute for mandatory allergen declarations. The Food Standards Agency (FSA) provides detailed guidance on precautionary allergen labelling (PAL).
How Natasha's Law Applies to Food Supplements
Food supplements are classified as food under UK law, meaning all food labelling legislation applies in full, including Natasha's Law. The following scenarios are covered:
Pre-Packaged for Direct Sale (PPDS)
- Supplements packaged in-house and sold directly from your premises or website
- Capsules, tablets, powders, and liquids bottled before the customer orders
- Subscription boxes assembled and dispatched from your warehouse
Pre-Packaged (Non-PPDS)
Pre-packaged products manufactured off-site and sold through third-party retailers were already required to carry full ingredient lists under the Food Information Regulation (EU) No 1169/2011 (retained in UK law). Natasha's Law extended the same requirement to PPDS products.
Loose / Unpackaged Supplements
Supplements sold loose (e.g., powder scooped to order) are not PPDS. However, you must still provide allergen information verbally or via written notice at the point of sale, per the FSA's guidance.
Allergen Emphasis: What "Highlighted" Means in Practice
The law requires that allergens are emphasised relative to the rest of the ingredient list. Accepted methods include:
- Bold text — the most widely used approach
- Italic text
- Underlined text
- Contrasting colour (e.g., red allergen names on a white background)
A compliant ingredient list for a whey protein supplement might read:
Ingredients: Whey Protein Concentrate (Milk), Maltodextrin, Cocoa Powder, Sunflower Lecithin (Soy), Xanthan Gum, Sucralose.
Note that the allergen emphasis must appear within the ingredient list itself, not only in a separate "Allergen Advice" box — although including a separate advisory statement is best practice and strongly recommended by the FSA.
Step-by-Step Compliance Checklist
Use this checklist for every food supplement label you produce or review:
1. Identify All Ingredients
List every ingredient, including processing aids that carry over into the final product in significant quantities.
2. Screen for the 14 Allergens
Cross-reference each ingredient against the 14 allergen list. Don't forget:
- Derived ingredients (e.g., glucosamine sourced from shellfish = crustacean allergen)
- Carrier solvents and excipients (e.g., soy lecithin in softgels)
- Flavourings that contain allergens
3. Apply Emphasis Consistently
Choose one emphasis method and apply it consistently across your entire product range. Inconsistency creates consumer confusion and regulatory risk.
4. Include a Separate Allergen Advisory (Best Practice)
Add a dedicated "Allergen Advice" or "Contains:" statement below the ingredient list, e.g.:
Allergen Advice: Contains Milk, Soy.
5. Check Font Size and Legibility
The minimum font size for ingredient lists is 1.2 mm (x-height) for most packaging. The allergen emphasis must be clearly visible at this size.
6. Review Cross-Contamination Risks
If your facility handles multiple allergens, consider whether a PAL statement is appropriate. The FSA's PAL guidance provides a risk-based framework.
7. Verify with an Automated Compliance Tool
Manual label reviews are time-consuming and error-prone. label-checker.com uses AI-powered allergen detection to automatically identify and verify all 14 allergens across your ingredient list — including synonyms and derived ingredients.
Common Mistakes That Lead to Non-Compliance
Based on 30+ years of food industry expertise, these are the most frequent allergen labelling errors we see:
1. Missing derived allergens — Glucosamine listed without noting its shellfish origin; soy lecithin listed without the soy emphasis.
2. Inconsistent emphasis — Some products use bold, others use capitals, others use a separate box. Inconsistency undermines consumer trust and may not satisfy the "emphasis" requirement.
3. Allergen advice box only — Placing allergen information only in a separate box without emphasising allergens within the ingredient list is not compliant with Natasha's Law.
4. Outdated formulations — Supplier ingredient changes that introduce new allergens without triggering a label review. This is a critical supply chain risk.
5. Small-batch exemptions misapplied — There is no small-business exemption from Natasha's Law. All PPDS food businesses, regardless of size, must comply.
Enforcement and Penalties
Local authority Trading Standards officers enforce food labelling legislation. Penalties for non-compliance include:
- Improvement notices requiring corrective action within a specified timeframe
- Prohibition orders preventing sale of non-compliant products
- Prosecution for serious or repeated breaches — unlimited fines and up to two years' imprisonment under the Food Safety Act 1990
- Product recalls — which can cost tens of thousands of pounds and cause lasting reputational damage
The Food Standards Agency publishes enforcement data annually. Allergen mislabelling consistently ranks among the top reasons for food recalls in the UK.
How label-checker.com Automates Natasha's Law Compliance
label-checker.com was built specifically for UK food supplement businesses that need fast, accurate, and repeatable label compliance checking. Our platform:
- Scans ingredient lists for all 14 major allergens, including 407+ ingredient synonyms and derived sources
- Flags missing emphasis — identifies allergens present in your ingredient list that are not bolded or highlighted
- Checks PPDS requirements — verifies that your label includes all mandatory information under UK FIR 2014 and Natasha's Law
- Generates compliance reports — downloadable PDF reports for your quality management system (QMS) records
- Supports multi-jurisdiction checking — UK, EU, and US (FDA) compliance in a single workflow
"With 30+ years in the food supplement industry, we built label-checker.com because we know how easy it is to miss a derived allergen or forget to update a label after a formulation change. Our AI checks what humans miss." — Label Checker Team
Frequently Asked Questions
Does Natasha's Law apply to online supplement sales?
Yes. If you pre-package supplements before dispatch, they are PPDS and must carry a full ingredient list with allergen emphasis. This applies to all sales channels including your own website, Amazon, eBay, and other marketplaces.
What if my supplement contains no allergens?
You are not required to include an "Allergen Advice: None" statement, but many businesses do so voluntarily to reassure consumers. You must still include a full ingredient list.
Are vitamins and minerals exempt from Natasha's Law?
No. All food supplements — including single-nutrient vitamins and mineral tablets — are subject to Natasha's Law if they are PPDS.
How often should I review my labels?
Every time there is a formulation change, supplier change, or regulatory update. We recommend a formal label review at least annually, using an automated tool to catch changes that may have been missed.
Can I use "Contains:" instead of bolding allergens in the ingredient list?
No. The "Contains:" statement is a supplementary best-practice advisory. The law requires allergens to be emphasised within the ingredient list itself.
What is the difference between Natasha's Law and the Food Information Regulations 2014?
The Food Information Regulations 2014 (FIR 2014) implement EU FIC Regulation 1169/2011 in UK law and cover all pre-packaged food. Natasha's Law (2021) extended the same full-labelling requirement to PPDS food, which was previously exempt.
Related Resources
- UK Food Supplement Labelling Requirements 2026 [blocked] — full guide to all mandatory label elements
- Understanding Health Claims for Food Supplements [blocked] — GB Health Claims Register and authorised claims
- Amazon UK Food Supplement Compliance [blocked] — selling supplements on Amazon with full label compliance
- Our Compliance Services [blocked] — how label-checker.com supports your label review workflow
- About label-checker.com [blocked] — 30+ years of food industry expertise
External Authority Sources:
- Food Standards Agency — Allergen Guidance for Businesses
- UK Food Information Regulations 2014 (Legislation.gov.uk)
- EFSA — Allergen Risk Assessment
- MHRA — Food Supplements Guidance
Last updated: April 2026. This article is for informational purposes only and does not constitute legal advice. Always consult the Food Standards Agency or a qualified food law specialist for specific compliance queries.
The Ultimate Guide to Food Supplement Label Compliance
This article is part of our comprehensive compliance guide covering UK, EU, and US regulations — including allergens, health claims, MHRA herbs, novel foods, CITES, RASFF, and FDA requirements.