What counts as PPDS?

PPDS food is food that a business packs before offering it for sale, and then sells directly to the final consumer. It must be sold from one of three places. The first is the same premises where it was packed. The second is the same site, meaning a building complex such as a shopping centre or airport terminal where the business has more than one unit. The third is a moveable or temporary outlet run by the same business, such as its own market stall or food van.

Ask three questions. Was the food in its packaging before the customer ordered or chose it? Is the food enclosed, fully or partly, so that it cannot be altered without opening or changing the packaging? Did the same business pack it and sell it, at one of those three places? If all three answers are yes, the food is PPDS.

These are PPDS: sandwiches and salad boxes made in the morning and put in a chiller. Pots of soup filled ready to sell. Cartons of chips or nuggets placed under a hot lamp before a rush. Wrapped burgers. A cake in cling film. Bread in a paper bag folded or twisted shut. Rolls in a tied plastic bag. Drinks poured and lidded before a rush. Cheese and cooked meats wrapped ready at a deli. Packed lunches made for a school trip without individual orders.

It does not matter whether the customer picks the food up or asks staff for it. It does not matter whether they eat in or take away. Free items count too, so packets of complimentary prawn crackers need labelling.

These are not PPDS: a sandwich wrapped at the counter after the customer orders it. Hot drinks made to order. Unwrapped cakes in a glass display. A burger or pizza slice on an open cardboard tray, because the food can be altered without opening the packaging. An open carton of chips. A self-service salad bar. A cake taken out of its cling film before it goes on display. These are non-prepacked foods, so allergen information rules apply instead.

Food packed by one business and sold by another is not PPDS either. A pork pie packed by business A and sold by business B at a farmers' market is prepacked food, and it needs a full label.

Here is a worked example. A market trader bakes flapjacks at home, wraps them and sells them from her own stall. She packed them, she sells them, and a stall is a temporary outlet. They are PPDS. If she also supplies the same flapjacks to a local café, the café's flapjacks are prepacked, and they need the full label.

Central kitchens need care. Food you pack in one kitchen and sell from a permanent shop somewhere else does not fit any of the three places. Treat it as prepacked, and confirm this with the FSA's labelling decision tool, Food Standards Scotland or your local authority.