Guide
Do ghost kitchens need PPDS labels?
If you pack food before the customer selects it and sell it from the same business and site, PPDS rules apply — even if there is no walk-in counter. Delivery packing after the order may follow a different analysis; map each channel.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
If you pack food before the customer selects it and sell it from the same business and site, PPDS rules apply — even if there is no walk-in counter. Delivery packing after the order may follow a different analysis; map each channel.
Decide PPDS using the FSA packing-before-selection test, then put name and ingredients with allergen emphasis on packs that meet it.
How to apply it
If you pack food before the customer selects it and sell it from the same business and site, PPDS rules apply — even if there is no walk-in counter. Delivery packing after the order may follow a different analysis; map each channel. Decide PPDS using the FSA packing-before-selection test, then put name and ingredients with allergen emphasis on packs that meet it. Walk the product in front of you against the checklist below before you print. The mistake to refuse is: Some models still need on-pack particulars. Others need clear pre-order allergen information. Read FSA distance-selling guidance for your model.
- Prepacked fridge items for collection are usually PPDS
- Made-to-order delivery bags packed after the ticket may not be classic PPDS
- Marketplace partners change who the FBO is — clarify contracts
- Allergen information must still be accurate either way
Worked example
Worked example for “Do ghost kitchens need PPDS labels?”: take one real SKU you sell this week. Apply the first check — prepacked fridge items for collection are usually PPDS. Then contrast it with made-to-order delivery bags packed after the ticket may not be classic PPDS. Write the name of the food and the full ingredients list from today’s recipe and supplier specs, emphasise every Annex II allergen each time it appears, and only then print. If the pack in your hand does not match that list, it is not ready for sale. (If you pack food before the customer selects it and sell it from the same business and site, PPDS rules apply — even if there is no walk-in counter.)
Checklist before you print
| Check | Why it matters |
|---|---|
| Prepacked fridge items for collection are usually PPDS | For “Do ghost kitchens need PPDS labels?”, “Prepacked fridge items for collection are usually PPDS” is the check that stops the pack drifting from what you actually sell. |
| Made-to-order delivery bags packed after the ticket may not be classic PPDS | For “Do ghost kitchens need PPDS labels?”, “Made-to-order delivery bags packed after the ticket may not be classic PPDS” is the check that stops the pack drifting from what you actually sell. |
| Marketplace partners change who the FBO is — clarify contracts | For “Do ghost kitchens need PPDS labels?”, “Marketplace partners change who the FBO is — clarify contracts” is the check that stops the pack drifting from what you actually sell. |
| Allergen information must still be accurate either way | For “Do ghost kitchens need PPDS labels?”, “Allergen information must still be accurate either way” is the check that stops the pack drifting from what you actually sell. |
Assuming delivery means no pack label
Some models still need on-pack particulars. Others need clear pre-order allergen information. Read FSA distance-selling guidance for your model.
Go deeper
Next: Natasha’s Law and distance selling. Pre-order information and pack labelling together. Then paste your ingredients into the free generator and confirm allergens before you print.
Questions
Does Deliveroo packaging change the rules?
Can one label cover three virtual brands?
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.
- Introduction to allergen labelling for PPDS foodFood Standards Agency / GOV.UK
- Labelling guidance for prepacked for direct sale (PPDS) food productsFood Standards Agency / GOV.UK
- Food allergen labelling and information requirements technical guidanceFood Standards Agency / GOV.UK
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