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Guide

Do cafés need to label sandwiches?

If sandwiches are wrapped or boxed before the customer chooses them — for example stacked in a fridge — they are usually PPDS and need a Natasha’s Law label. Sandwiches made to order after the customer asks are typically not PPDS, though allergen information must still be accurate and available.

Reviewed against official guidance.SourcesNot legal advice.

The fridge test

Morning prep that fills a refrigerated display with named, wrapped sandwiches is the textbook PPDS case. Each pack needs the food name and full ingredients list with allergens emphasised — including bread, spreads, fillings and garnish.

Made to order

If the sandwich does not exist until the customer orders, and staff assemble it then, you are usually outside PPDS packing rules. You still need a reliable way to tell customers about allergens in breads, butters and fillings.

Café sandwich traps

  • Pesto, mayonnaise and pickles hiding tree nuts, egg or mustard
  • Bread mixes and seeded rolls with sesame or cereals containing gluten
  • Caesar dressing and anchovies (fish)
  • Buttering every sandwich from a shared block (milk) without declaring it

Hybrid counters

Some cafés prewrap half the range and make the rest to order. Only the prewrapped packs need PPDS pack labels — but train staff so the two systems do not get mixed up.

Questions

Does a sticker with only allergens meet the rule?
No. PPDS needs a full ingredients list with allergens emphasised inside it — not an allergens-only sticker.
What about toasties wrapped after payment?
If packing happens after the customer has chosen and ordered, it is usually not PPDS. Confirm with your local authority if your process is unusual.

Official sources

Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.

Read next

Cafés industry guide

Sandwiches, pastry cabinets and breakfast packs.

Try it

Create a label free

Paste ingredients and emphasise allergens in one pass.

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