Four questions from the FSA's two-part test. Not a chat, and not a verdict on a named product.
Was it packed before they ordered?
Question 2 of 4
The FSA test asks whether the food was already in that packaging before the customer ordered or selected it.
Last reviewed 23 Aug 2026 from FSA guidance
Was it put in that packaging before the customer ordered or selected it?
Prepacked for direct sale (PPDS) is, in the FSA's words, "food that is packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected".
"Any food that is not in packaging or is packaged after being ordered by the consumer." That food is not PPDS.
Sources
- GOV.UK: Introduction to allergen labelling for PPDS food
- GOV.UK: PPDS allergen labelling changes for butchers
Guidance, not legal advice. Your local environmental health team has the final word.
Contains public sector information licensed under the Open Government Licence v3.0. Crown copyright. Source file last reviewed 23 Aug 2026.
This is general guidance, not legal advice, and it decides nothing about a specific product. The food business operator is legally responsible for what appears on the label, always. Software can derive a label from your data; it cannot take on that responsibility, and no tool can certify a product or a business.
More guides
Natasha’s Law for small food businesses: what PPDS actually requires
The pillar guide: scope, the 14 allergens, emphasis rules, and what an inspector looks for.
The 14 allergens, and the ways packs hide them
Cocoa butter isn’t dairy. “Reconstituted buttermilk (1%)” is. Real examples of how declarations mislead.
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