The popularity of vegan foods continues to grow. Already in 2019, the UK has experienced what is expected to be a record-breaking #Veganuary campaign and been named the global leader in development of new vegan products, toppling Germany from its top spot. It’s a similar picture elsewhere. One in ten new products launched in Europe carried a ‘vegan’ or ‘no animal ingredients’ claim last year1, while global vegan product launches have reportedly doubled over the last five years.
CONFUSHION CAUSED BY CLAIMS
The category clearly has huge scope for further growth, but there remains an underlying concern relating to the current lack of a legal definition for what constitutes a vegan claim. There is also currently very little guidance around the controls that need to be in place in order to be able to substantiate such a claim.
Claims such as ‘vegan’ and ‘vegetarian’ are voluntary, and as such are covered by the Food Information for Consumers Regulation (EU FIC), which stipulates that voluntary claims must not be ambiguous or misleading to the consumer. However it is fairly common to find a ‘vegan’ claim on pack alongside an additional statement advising that the product may contain milk and/or egg.
The Vegan Society grants permission to manufacturers to feature its approved trademark on products that they have reviewed and certified, however this is not guarantee of the complete absence of animal-derived ingredients, only that the product has been made without the deliberate use of animal-derived ingredients. The society allows the use of precautionary statements to warn of possible presence of milk and/or egg in the products.
Confused consumers recently took to social media to share their thoughts about the use of precautionary labelling by retailers on products making vegan claims, most saying they found it to be misleading. However retailers are using these warnings to attempt to clarify to consumers that vegan claims should not be regarded in the same way that ‘milk free’ and ‘egg free’ claims are, as ‘vegan’ claims generally refer only to the fact that the products have been made without the use of animal derived ingredients, not that the products have been made in a controlled environment designed to specifically prevent any cross-contamination from animal derived ingredients (as should be the case for allergen ‘free-from’ claims).
This is the crux of the matter. Consumer perception is that a ‘vegan’ claim on a product is equivalent to an allergen ‘free-from’ claim, but this is not the situation within the food industry, primarily due to the fact that allergen-free claims are about food safety, whereas claims such as ‘vegan’ are a lifestyle choice of the consumer and so are a food quality concern, not a food safety one.
The question must be asked, what should be the driver behind the meaning of and the substantiation of an on-pack claim? Should it be what is widely perceived or understood by the consumer, or what is known by the manufacturer about how the production process has been managed and controlled?
SOME KEY CONSIDERATIONS WHEN MAKING A 'VEGAN' CLAIM:
Regardless of the consumer the product is being marketed at, manufacturers of vegan products need to take every available step to mitigate the risks of cross-contamination with animal derived ingredients. A thorough risk assessment is essential in order to understand how the unintentional presence of animal-derived material could occur. These risks must be assessed and appropriate mitigating controls put in place. Evidence must then be collected to demonstrate the efficacy of these controls.
For this process of risk assessment, much can be learned from allergen management best practice; an area that provides valuable guiding principles. Risk assessment must cover the entire production process, and include suppliers, handling of raw materials, production scheduling and application of the correct packaging.
Cleaning is another important consideration, and this should be a fully validated procedure that can be demonstrated to remove traces of animal-derived material from equipment and lines if these are shared.
Analytical testing should be employed as a tool to collect evidence of cleaning efficacy and to support claims on finished products. Testing for the presence of animal derived materials is not a straightforward process and engaging the right laboratory with the required expertise will be crucial in negotiating this challenging task.
AN EVOLVING SITUATION
The European Commission is starting the process of establishing a legal definition for vegan and vegetarian on-pack descriptors, as part of its ongoing Regulatory Fitness and Performance Programme (REFIT), so there may be much needed clarity for industry coming soon.
In the meantime, there is much that can be done to bring additional rigour to the manufacturing process of vegan products.
See our vegan and vegetarian food services page or find out more about events we are running around this topic.
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For further information or to discuss your vegan and vegetarian manufacturing requirements please contact us on enquiries@rssl.com or call +44 (0) 118 918 4076.