Labels are the single most useful safety tool a free-from shopper has — and also where the vocabulary gets slippery. Here is what the main phrases on UK food packaging and menus actually mean, with the source for each.
“Gluten free”: a claim with a number behind it
“Gluten free” is one of the few free-from phrases with a legal threshold. Food carrying it must contain no more than 20 parts per million of gluten. As Coeliac UK explains, the rule covers prepacked food and food sold in restaurants and cafés, and it can appear on specialist products such as gluten-free bread made with gluten-free wheat starch as well as on naturally gluten-free foods made with controls against cross-contamination. Oats labelled gluten free must themselves meet the 20ppm limit.
“No gluten-containing ingredients”: what the FSA says now
Some menus describe dishes as having “no gluten-containing ingredients” (NGCI). The recipe may contain no wheat, barley, rye or oats, but the dish has not necessarily been prepared with gluten-free controls. In its updated technical guidance the Food Standards Agency advises against NGCI statements because they can mislead people with coeliac disease. Where businesses still use them, the FSA says they should make clear the dishes are not suitable for people with coeliac disease unless they meet the gluten-free standard. If you have coeliac disease, look for “gluten free” and ask how the food is prepared.
“May contain”: precautionary allergen labelling
“May contain”, “not suitable for people with a peanut allergy” and “made in a factory that also handles…” are precautionary allergen labels (PAL). They are voluntary. Since September 2023, FSA best-practice guidance says businesses should:
- use a PAL only where there is an unavoidable risk of cross-contamination that cannot be controlled by segregation and cleaning;
- name which of the 14 allergens it refers to — “may contain peanuts”, rather than a vague “may contain nuts”;
- not put a PAL alongside a “free from” claim for the same allergen.
Because the statement is voluntary, the absence of “may contain” does not prove there is no risk. If you are unsure, contact the manufacturer.
Natasha’s Law and PPDS food
Food prepacked for direct sale (PPDS) is packed on the same premises where it is sold, before you order it — think of a sandwich or salad made and boxed in the café that morning. Before 1 October 2021 its allergen information could be given by any means, including verbally. Since 1 October 2021, PPDS food must be labelled with the name of the food and a full ingredients list with the 14 allergens emphasised. In England the change was made by the Food Information (Amendment) (England) Regulations 2019, which came into force on 1 October 2021; equivalent rules apply in Wales and Northern Ireland, and it is widely known as Natasha’s Law.
Vegan is not the same as dairy free
A vegan label tells you the recipe contains no animal products. It is not an allergy guarantee. The FSA notes that customers sometimes assume vegan food is free from milk, egg, fish, crustaceans and molluscs, but low-level cross-contamination can happen in production. A “dairy free” or “milk free” claim, by contrast, is a free-from claim — which the FSA describes as a guarantee that the food is suitable for people with that allergy, backed by strict controls.
How to read a label in thirty seconds
- Read the ingredients list, not just the front. The 14 allergens are emphasised each time they appear — usually in bold. See the 14 allergens explained.
- Look for the cereal or nut by name. Gluten appears as wheat, barley, rye or oats; nuts as almond, hazelnut and so on.
- Check for any “may contain” or “not suitable for” statement, usually just after the ingredients.
- Check the claim on the front — “gluten free” carries a legal limit; “vegan” does not mean allergen free.
- Re-check every time. Recipes and factories change. The FSA also publishes allergy alerts when food is withdrawn or recalled because of an allergen.
Questions
What does “gluten free” mean on a UK label?
It is a legally protected claim: the food must contain no more than 20 parts per million (20mg/kg) of gluten. Coeliac UK notes that it applies to prepacked food and to food sold in catering, and that oats labelled gluten free must themselves meet the same limit.
Can I trust “no gluten-containing ingredients” (NGCI)?
Treat it with care if you have coeliac disease. The Food Standards Agency advises businesses not to use NGCI statements because they can mislead people with coeliac disease, and says that if a business does use them it should make clear the food is not suitable for people with coeliac disease unless it meets the gluten-free standard.
Is “may contain” a legal requirement?
No. Precautionary “may contain” labelling is voluntary. FSA best-practice guidance says it should only be used where there is an unavoidable risk of cross-contamination that cannot be controlled, and should name the specific allergen — for example “may contain peanuts”, not just “may contain nuts”.
What is Natasha’s Law?
It is the name commonly given to the rules for food prepacked for direct sale (PPDS) — food packed on the premises before you order it, such as a sandwich made and wrapped in the shop. Since 1 October 2021 that food must carry its name and a full ingredients list with allergens emphasised. In England the change was made by the Food Information (Amendment) (England) Regulations 2019.
Is vegan food always dairy free and egg free?
Not necessarily from an allergy point of view. The FSA notes that vegan food can still carry a risk of low-level cross-contamination with milk, egg, fish, crustaceans or molluscs, and recommends businesses pair a vegan label with a precautionary statement where that risk exists. A vegan label is about the recipe; a free-from claim is about safety for people with an allergy.
Sources
- Food Standards Agency — Allergen guidance for food businesses.
- Food Standards Agency — Updates to best practice guidance on food allergen labelling (PAL and NGCI).
- Food Standards Agency — Technical guidance consultation: summary of responses.
- GOV.UK — Introduction to allergen labelling for PPDS food.
- legislation.gov.uk — The Food Information (Amendment) (England) Regulations 2019.
- Coeliac UK — Gluten-free law.


