UK Food Labelling and Allergen Rules for Microgreens (GB Guide)

Category: Microgreens  |  Region: UK  |  Topic: Labelling & Packaging

This is one of those topics that gets made needlessly confusing because people mix up three different things: how the food is packed, where it is packed, and when the customer makes their choice. Once you classify that properly, the label requirements mostly fall into place.

This guide is written for small microgreens producers selling in Great Britain (England, Wales, Scotland). Food labelling and allergen rules in GB are largely based on retained Regulation (EU) No 1169/2011 and the Food Information Regulations 2014. (Legislation.gov.uk) :contentReference[oaicite:0]{index=0}

If you are selling in Northern Ireland, exporting, or making nutrition or health claims, treat this as a starting point and confirm details with your local authority because the edge cases matter.

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1) Start here: what type of sale is it?

Before we talk about label content, we need to classify the sale. This is the bit that drives everything else.

A. What counts as “prepacked” food?

Food is prepacked when it is put into packaging before being offered for sale and the packaging encloses it so the contents cannot be changed without opening or changing the packaging. That definition comes from the food information rules. (Legislation.gov.uk) :contentReference[oaicite:1]{index=1}

In microgreens terms, this is typically:

• sealed punnets or clamshells packed ahead of time
• bags packed for retail shelves, wholesale, or delivery
• anything packed and then put into a fridge/display for customers to pick up

Prepacked foods normally need the full set of mandatory particulars (the “full label”).

B. What counts as PPDS (Prepacked for Direct Sale)?

PPDS is where food is packed on the same premises where it is sold, and it is packed before the customer selects it. The key thing is that it is still “prepacked”, but it is made up for direct sale from that site. :contentReference[oaicite:2]{index=2}

From 1 October 2021, PPDS food must be labelled with the name of the food and a full ingredients list, with allergenic ingredients emphasised (Natasha’s Law). (Food Standards Agency) :contentReference[oaicite:3]{index=3}

Microgreens examples that often fall into PPDS:

• you pack punnets in the back room of your farm shop and put them in the chiller for customers to grab
• you pack bags at your market stall before customers choose them (this can be PPDS depending on the setup and how “premises” is interpreted locally, so ask your EHO if you trade this way regularly)

C. What counts as non-prepacked (loose or packed to order)?

This is food sold loose, or packed after the customer orders or selects it (for example, you fill a bag from a tray when someone asks, or you cut a live tray to order).

You still must provide allergen information, but it can often be given verbally or via clear written/signposted information, as long as it is accurate and genuinely accessible to customers.

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2) What must be on a full label?

For prepacked food, Regulation 1169/2011 sets out the mandatory particulars. The familiar list most small producers use comes from Article 9. (Legislation.gov.uk) :contentReference[oaicite:5]{index=5}

For microgreens, the practical “baseline” is usually:

Name of the food

Use a clear, non-misleading name. If it is a specific variety, say so.

Ingredients list (only if more than one ingredient)

Ingredients are listed in descending order by weight at the time of packing. If it is genuinely single-ingredient microgreens, you often do not need an ingredients list.

Net quantity

For example, “30 g”. This is one of the most commonly missed basics for punnets and bags.

Date marking: best before or use by

Which one is correct depends on whether the food is considered highly perishable from a safety point of view. Microgreens are often marked with best before in practice, but you should confirm your approach with your local authority if you are unsure, because date marking is about safety and consumer protection, not preference. Article 9 includes date of minimum durability/use by as a mandatory particular where applicable. (Legislation.gov.uk) :contentReference[oaicite:6]{index=6}

Storage conditions

If you need refrigeration to keep it safe or in good condition, say so (for example “Keep refrigerated 0–5°C”).

Name and address of the food business operator

This must be a real postal address (not just an Instagram handle). (Legislation.gov.uk) :contentReference[oaicite:7]{index=7}

Origin/provenance (only if required)

Country of origin is only mandatory in certain situations, especially where leaving it out would mislead. If you are trading on “grown in the UK”, it is usually smart to state “Grown in the UK” or “Grown in [County]” consistently.

Lot/batch identification (traceability)

Even when not printed as “LOT”, you need a way to trace what was packed when, and what seed batch it came from. In real life, a simple batch code you understand is enough, as long as it is consistent.

Language

Mandatory information must be in English in GB.

What many microgreens products do not need (unless you trigger it)

Most plain microgreens sold as a simple food, with no nutrition or health claims, do not automatically require nutrition labelling. That changes if you start making claims (for example “high in vitamin C”) or if you produce something that falls into a category where nutrition becomes mandatory.

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3) Allergens

In GB, the legal “big rule” is simple: if any of the 14 regulated allergens are used as ingredients (or processing aids), customers must be told. The list comes from Annex II of the food information rules. (Legislation.gov.uk) :contentReference[oaicite:8]{index=8}

Those 14 are:

cereals containing gluten, crustaceans, eggs, fish, peanuts, soybeans, milk, nuts, celery, mustard, sesame, sulphur dioxide/sulphites, lupin, molluscs. (Annex II) :contentReference[oaicite:9]{index=9}

How allergens must be shown for prepacked and PPDS

For prepacked and PPDS, allergens must be:

• included within the ingredients list, and
• emphasised so they stand out (bold, capitals, underline, contrasting colour, etc.)

For PPDS specifically, the requirement that the label includes the name of the food plus a full ingredients list with allergens emphasised is exactly the point of the law change. (Food Standards Agency) :contentReference[oaicite:10]{index=10}

Where microgreens usually get caught

Most single-variety microgreens are genuinely single-ingredient foods, so allergen labelling is often straightforward.

The problems start when you do any of the following:

1) Mixed blends

If you sell a “salad mix” microgreens punnet, that is multiple ingredients. You need an ingredients list. If any ingredient is one of the 14 allergens, it must be emphasised. Mustard microgreens and celery microgreens are the two that most often surprise people because they are literally named in the allergen list. (Annex II) :contentReference[oaicite:11]{index=11}

2) Added extras

If you add anything, even “a little” (oil, seasoning, a topper sachet), you are now in multi-ingredient territory. That triggers ingredients list and allergen emphasis requirements for prepacked/PPDS.

3) Cross-contamination expectations

The law is about ingredients, but customers care about cross-contact. If you grow, harvest, or pack celery or mustard microgreens in the same space as non-allergen products, you need a calm, honest approach to cross-contact risk. Do not guess. Build a simple separation and cleaning routine and be able to explain it.

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4) Who enforces this, and who actually helps you?

In practice, enforcement is local.

• Environmental Health typically focuses on hygiene and food safety controls.
• Trading Standards commonly leads on food standards and labelling issues.

Your local authority is also your best reality check. If you are unsure whether your market setup counts as PPDS, or whether your dating is appropriate, ask them. A five-minute clarification now saves you months of stress later.

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5) A label layout that works in the real world

For a single-ingredient microgreens punnet (prepacked)

Front:

• “Pea Shoots Microgreens”
• “30 g”

Side/back:

• “Keep refrigerated 0–5°C”
• “Best before: DD/MM/YYYY”
• “Packed by: [Business name], [Full address]”
• “Batch: PS-0701” (example)

For a blend (prepacked or PPDS)

You do the same, plus:

Ingredients: Pea shoots microgreens, Radish microgreens, Mustard microgreens
(With allergens emphasised as required.) :contentReference[oaicite:12]{index=12}

For live trays and “cut-to-order” formats

Live trays and cut-to-order setups are often non-prepacked, which changes how you deliver allergen information. The point is not to avoid information. The point is to deliver it in the correct form.

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6) Common microgreens labelling mistakes

The patterns that tend to trigger problems are boring but consistent:

• Misclassifying PPDS and relying on “ask us about allergens” signage for PPDS foods (not enough under the PPDS allergen change). (Food Standards Agency) :contentReference[oaicite:13]{index=13}
• Missing the business address.
• No weight.
• Unclear date marking or missing storage instruction when chilled storage is clearly required.
• Inconsistent naming between batches (“microgreens mix” one week, “salad topper” the next) that makes traceability messy.
• No meaningful batch code, so you cannot confidently recall a specific packing run.

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7) A simple compliance check you can actually use

Before you print labels in bulk, ask:

If you can answer those calmly, you are most of the way there.

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References

• Legislation.gov.uk — Food Information Regulations 2014 :contentReference[oaicite:18]{index=18}
• Legislation.gov.uk — Regulation (EU) No 1169/2011 (retained) :contentReference[oaicite:19]{index=19}
• Legislation.gov.uk — Annex II allergens list :contentReference[oaicite:20]{index=20}
• Food Standards Agency — Introduction to allergen labelling changes for PPDS :contentReference[oaicite:21]{index=21}
• Food Standards Agency — PPDS allergen labelling guidance (definitions and requirements) :contentReference[oaicite:22]{index=22}