Do School Cake Sales Need Natasha's Law Labels?

What Natasha's Law actually covers

Quick recap: Natasha's Law (which came into force on 1 October 2021) requires full ingredient labelling with allergens in bold on all PPDS (Pre-Packed for Direct Sale) food sold by food businesses. For a full explanation of what "PPDS" means, see our Natasha's Law FAQ.

The key phrase in this context is "food business". Under the Food Safety Act 1990, a food business is defined as any undertaking — whether for profit or not — which carries out any of the activities of preparation, processing, manufacturing, packaging, storing, transporting, distributing, handling or offering for sale or supply of food. Crucially, the definition includes not-for-profit activity. A school raising money for new sports equipment is technically engaged in a commercial undertaking when it sells food, even if no individual profits personally.

But the law also has proportionality built into its enforcement. Trading Standards and the Food Standards Agency do not treat a parent bringing a tray of brownies to a once-a-year fête the same way they treat a business operating a weekly market stall. The practical question is always: where does this activity sit on the spectrum?

When does a school cake sale become a food business?

There is no bright-line rule, but the FSA and Trading Standards generally apply the "food business" label — and with it, food safety and labelling obligations — when the following conditions are met:

• Activities are regular and ongoing. A weekly tuck shop selling pre-packaged goods is almost certainly a food business. A one-off annual summer fête is much less likely to be treated as one.
• Food is sold for money. Even charitable fundraising where money changes hands counts as commercial activity under the legislation. The fact that profits go to the school rather than an individual does not change this.
• The activity is organised and systematic. A formal PTA event with a committee, advance planning, and consistent operations looks more like a food business than a spontaneous collection of homemade cakes on a table.
• The food is pre-packaged before sale. Homemade cake slices wrapped in cling film and priced up the night before are PPDS food. Cakes cut and served fresh at the event are loose food — different rules apply.

Applying that framework:

The grey area and the real risk

Even where Natasha's Law doesn't technically apply, the risk remains very real. If a child with a peanut allergy eats an unlabelled homemade cake from a bake sale and has a severe allergic reaction, the organisers could face significant liability — regardless of whether the event legally required allergen labelling under Natasha's Law. Civil liability for allergen incidents does not depend on whether the seller was a "food business" within the meaning of food safety legislation.

Schools have a particular duty of care to pupils. If a school event results in a child having an anaphylactic reaction to an unlabelled product, the consequences — legal, financial and reputational — can be serious even if no law was technically broken.

This is why best practice for any school food sale — regardless of whether Natasha's Law strictly applies — includes:

• Ask every contributor to provide a written list of ingredients for their products when dropping them off. A simple handwritten note is fine.
• Display allergen information on a board or table card next to each item: "Contains: eggs, wheat, milk" (and so on).
• Include a general notice at the stall: "Some products may contain nuts, gluten, milk and other allergens. Please ask for ingredient information before purchasing."
• Identify and clearly mark any products that are free from the top 8 allergens.
• Keep nut-containing products and nut-free products on separate tables with clear signage.
• Never mix products from different contributors in shared packaging.

None of this requires purchasing labelling software or printing professional stickers. A hand-written sign and a moment's thought can meaningfully reduce risk for the school, the PTA, and most importantly, for children with allergies.

What the Food Standards Agency says

The FSA's published guidance acknowledges this grey area directly. Their position is:

• Charity cake sales by individuals who are not food businesses are generally not covered by food business legislation, including Natasha's Law labelling requirements.
• Schools and PTAs that operate regular food sales should take a precautionary approach to allergen information, even if full legal compliance is not strictly required.
• Where there is any doubt, the FSA encourages organisations to provide allergen information voluntarily.

It's worth noting that local authorities (who enforce food safety law through Trading Standards and Environmental Health) can take varying approaches. Some councils take a stricter line than the FSA guidance and advise all school food events to provide ingredient information regardless of scale. Contact your local authority for their specific guidance if you are unsure — this is always the safest approach.

When a school DOES need Natasha's Law labels

There are circumstances where a school, a school kitchen, or a PTA is unambiguously operating as a food business and where full compliance with Natasha's Law — and broader food safety law — is clearly required. These include:

• A school canteen or kitchen that is registered as a food business (most school kitchens are) and sells PPDS food alongside hot meals.
• A regular tuck shop operating multiple times per term, selling pre-packaged products — whether commercial branded products or homemade items in packaging.
• A school café or hospitality programme where students prepare and sell food as part of a course.
• A PTA that operates food sales at regular intervals throughout the year — monthly events, termly cake stalls, and similar — where the cumulative activity takes on the character of a regular food business.
• Any situation where food is sold under a food business registration, whether held by the school, the PTA as a registered charity, or a parent organisation.

If your school or organisation is in any of these categories, PPDS products need compliant labels: the food name, a full ingredient list in descending order by weight, and allergens emphasised in bold. This applies to homemade products as much as commercially produced ones.

Practical approach for school events

Whether or not your school event is legally required to carry Natasha's Law labels, here is a practical checklist that covers all bases and protects everyone involved:

• Ask all contributors to write down their ingredient list when dropping off products — a simple card or sticky note is sufficient
• Use a table at each stall showing: Product | Contains | May Contain — even a handwritten version on card is valuable
• Post a clear notice at the stall entrance: "Please ask a member of the team if you have any food allergies or dietary requirements"
• Keep nut-containing and nut-free products on separate tables with clear signs
• Never mix products from different contributors in shared packaging or serving vessels
• If a product's ingredients cannot be confirmed (contributor unavailable, unknown recipe), label it "allergen information unavailable — do not consume if you have allergies"
• For regular school tuck shops: register as a food business with your local authority and use proper PPDS labelling
• Consider appointing one PTA member per event as the "allergen lead" responsible for maintaining ingredient cards and answering queries

What about teachers or staff selling their own baking?

This scenario comes up more often than you might think — a teacher who bakes sells slices in the staffroom, or a member of support staff runs a weekly "cake Friday" where colleagues pay £1 a slice for homemade bakes.

Under the Food Safety Act, a person selling homemade cakes regularly for money is technically operating as a food business, even if the scale is tiny and the setting is informal. If it happens once — a birthday, a charity day — the grey area logic discussed above applies. If it becomes a regular arrangement (weekly, fortnightly, etc.), food business registration and allergen labelling requirements become relevant.

In practice, Trading Standards are unlikely to pursue enforcement action against a teacher selling occasional homemade biscuits to colleagues. But if a colleague has an allergic reaction to an unlabelled product, the liability picture is less forgiving. The sensible approach for regular staff cake sales is to include a simple ingredient card with each product, even if it's handwritten.

For staff employed in a school kitchen who prepare food sold to pupils, there is no ambiguity — full food business regulations apply.

Summary: the key questions to ask

If you're trying to work out whether Natasha's Law applies to your school food activity, ask these four questions:

The safe position is always to provide allergen information, regardless of legal obligation. The cost of doing so — a handwritten card, a display board, a moment's thought — is negligible. The cost of not doing so, if something goes wrong, is not.