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Guide

How to label dairy-free PPDS food

Dairy-free means you are not using milk ingredients — it does not remove the duty to list everything else and emphasise soya, nuts, gluten cereals and other Annex II allergens that remain.

Reviewed against official guidance.SourcesNot legal advice.

The short answer

Dairy-free means you are not using milk ingredients — it does not remove the duty to list everything else and emphasise soya, nuts, gluten cereals and other Annex II allergens that remain.

Emphasise Annex II allergens inside the ingredients list — bold, capitals, colour or underline — as set out in FSA allergen labelling guidance.

How to apply it

Dairy-free means you are not using milk ingredients — it does not remove the duty to list everything else and emphasise soya, nuts, gluten cereals and other Annex II allergens that remain. Emphasise Annex II allergens inside the ingredients list — bold, capitals, colour or underline — as set out in FSA allergen labelling guidance. Walk the product in front of you against the checklist below before you print. The mistake to refuse is: Reprint from a corrected master.

  • Full ingredients list still required
  • Emphasise non-milk allergens that are present
  • Check dark chocolate and margarine specs
  • Do not reuse the dairy recipe label

Worked example

Worked example for “How to label dairy-free PPDS food”: take one real SKU you sell this week. Apply the first check — full ingredients list still required. Then contrast it with emphasise non-milk allergens that are present. 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. (Dairy-free means you are not using milk ingredients — it does not remove the duty to list everything else and emphasise soya, nuts, gluten cereals and other Annex II allergens that remain.)

Checklist before you print

CheckWhy it matters
Full ingredients list still requiredFor “How to label dairy-free PPDS food”, “Full ingredients list still required” is the check that stops the pack drifting from what you actually sell.
Emphasise non-milk allergens that are presentFor “How to label dairy-free PPDS food”, “Emphasise non-milk allergens that are present” is the check that stops the pack drifting from what you actually sell.
Check dark chocolate and margarine specsFor “How to label dairy-free PPDS food”, “Check dark chocolate and margarine specs” is the check that stops the pack drifting from what you actually sell.
Do not reuse the dairy recipe labelFor “How to label dairy-free PPDS food”, “Do not reuse the dairy recipe label” is the check that stops the pack drifting from what you actually sell.

Crossing out milk on an old label

Reprint from a corrected master.

Go deeper

Next: Milk on food labels. Butter, cheese, cream and lactose-free. Then paste your ingredients into the free generator and confirm allergens before you print.

Questions

Is lactose-free the same as milk-free?
No. Lactose-free milk is still milk.
Do oat drinks need emphasising as cereals?
Oats are an allergen when used — emphasise oats as required.

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.