Challenges of vegan food manufacturing and claim substantiation

The term "Vegan" is widely used and fairly easy to describe, however surprisingly there remains no legal definition of the term in the UK or Europe


This can understandably introduce challenges when labelling products. This becomes a very important issue, especially when consumers use vegan claims on packaging as an allergy guide.


RSSL Food Safety and Quality Consultant Barbara Hirst talks through these issues and offers solutions as to the best way to overcome them.


Explore RSSL's vegan manufacturing services


Video transcript


OK, so just to introduce myself, I'm Barbara Hirst, and I work as a Senior Consultant within the food safety and quality team in RSSL and what we're going to talk about today is the rise of vegan labeled products, what challenges those bring and how best really to overcome them, and also the support that we offer as a business to both manufacturers and retailers in this arena. So, I'm going to start off first of all to think about what does that term 'vegan' mean? I mean, I think we all think we understand it don't we? It means products that don't contain any either animal products directly or ingredients or anything derived from animals. However, there are no legal definitions either in the UK or in Europe as to what the term actually means. Now, we understand, you'll know about the Vegan Society, for example, set up to bring about, you know, an ethical revolution in how food might be eaten if you're going to term it to be 'vegan' and they have a very simple stance - it's all about the ethics, it's all about do not use any animal ingredients or animal derived ingredients in products that you're going to label as 'vegan'. That's very clear. But they don't really engage with the 'what about things that might be there accidentally?' So unintentional presence / cross-contamination / 'may contain' and because we don't have a legal definition for 'vegan' what's happened is different manufacturers and different retailers interpret that phrase differently. So some would stipulate that 'vegan' means you're absolutely not allowed to have clearly any animal ingredients in, but also no 'may contain' - in other words you're not allowed to say 'may contain egg' or 'milk' or 'fish' with it. But some retailers and manufacturers do in fact allow you to use 'may contain' - for example egg, milk or fish, and this has led to, I think, some confusion really, particularly not necessarily for people who are choosing to eat vegan for a lifestyle choice, but the thing we have to also consider is we have people with true food allergies.


People are truly allergic to maybe egg or milk or fish or crustaceans or molluscs and, on a very simple level, if you were allergic to milk and you saw a product labeled as 'vegan', I don't think it's unreasonable that you might think that that would be completely safe for you because clearly it can't have milk in it, so why would you not be able to eat it safely? So some retailers and manufacturers will allow 'may contain' and some will not. So the ones who do not allow it in, other words they expect it to be manufactured to the same standards as something that would be labeled as 'free from', so not allowed 'may contain' milk therefore it's equivalent to a milk free product. So we're in this challenge now where we've got a risk, potentially, to some allergic consumers either not reading the label carefully because they just make an assumption and that has led to some incidents and some recalls that we've seen in the marketplace. So quite a challenge all around.


So, some retailers and manufacturers have started to use other claims, so not just using the word 'vegan', but you also see products labeled as things like 'vegan friendly' or 'plant-based' or 'suitable for a vegan diet' and I think the ethos behind that is that they feel that's a slightly softer term than just using the word 'vegan' and therefore it might prompt people perhaps who have allergies to read and see if there is any cross-contamination risk. So more likely to read to see if there is a 'may contain' and therefore maybe they shouldn't purchase it and consume it. So that's the first thing we have to think about is 'what does that term 'vegan' mean?', because it matters a lot, you have to be very clear with consumers about what that means and then you have to think about if the term is a definite one, I have to be able to substantiate that in terms of how I'm going to produce that food, which ingredients I'm going to use, and so on.


So, let's move on then to think about the supply chain. So products that are manufactured to a vegan recipe clearly don't have animal ingredients in them or animal derived ingredients, so it might be that manufacturers who are making those kinds of products are having to source quite a wide variety of ingredients that perhaps they're not so familiar with. So they need to engage with suppliers to make sure that if they're buying in, just as one example, pea protein, that it's not coming in with anything that wouldn't be allowed in a vegan product. And they might be buying, as i say, from suppliers whom they don't normally deal with, so they have to make sure they're asking the right questions about whether it might come in with any unintentional presence of any ingredients that are not allowed under that term 'vegan'. Asking about the cross-contamination risks, asking how are those suppliers managing any of the risks that might be present, so if the manufacturer of pea protein perhaps is also handling milk within that manufacturing site, how is the pea protein supplier ensuring that they're not supplying pea protein with a 'may contain' milk label, just as an example.


And of course, in the world that we live in in 2020, Covid has made this even more challenging because, probably before, lots of these suppliers you could go and physically visit, you could go and physically audit, but, of course, that's made much harder in Covid. So, having to do all of that remotely of course has made it just a little bit harder. We've also had challenges with the supply chain in general - of course you know Covid is a pandemic, has affected the whole world - so there are some challenges getting products out of certain countries, there are challenges with borders, there are challenges with workforces, with harvest, so again made it just a little bit harder. Then we think about if you buy all the ingredients in and you've got assurances that none of them are coming in with ingredients that are not allowed within vegan production, you've then got to make the products of course. Now when you think about manufacturing environments they fall into two categories when you're thinking about vegan production. They're either going to be made in what we would call 'dedicated' factories - in other words, factories where they don't have any ingredients or any products at all that are either made from / or contain / or derived from any animal ingredients. If you're working in a dedicated production environment then really your only risk is the ingredients that you're bringing in and also the people that you have in your workforce. So you have to make sure that the people aren't then going to cause any issues with actual product that you're making. So you've got to have good controls in place, hand washing, and all of those good things, and changing overalls, and so on and so forth, so anything they've eaten perhaps in their lunch, they're not going to bring into the production environment.


But those things are relatively easy to manage. So if you're in dedicated production your main issues are thinking about supply chain and the people. However, most vegan production, because of the rise and the popularity of it, are now made in what we're going to call 'non-dedicated' manufacturing. So, in other words, a factory that's making products labeled as 'vegan' and also products that do contain animal derived products. In those kinds of situations, a factory has to do a really good risk assessment to understand where the risks are, from how material that's derived from animals could accidentally and unintentionally get into products that you're then going to be labeling as vegan. At each and every one of those points, now whether it's due to supply, or process, or production, people or environment, that factory will have controls in place to manage each individual risk. So they have to identify the risks first of all, then they have to identify controls in place in order to manage that risk so that those ingredients do not get in there unintentionally. Now each of those controls also needs to be validated to provide evidence that they are effective at managing that risk and reducing the risk down to an unlikely level. This is something that we particularly help a lot of factories with in manufacturing, both in helping them to identify risks, and also particularly in the validation of those controls. Now when we think about validating controls every factory will understand what 'cleaning validation' means, in other words, if cleaning is your control between making a product that, let's say, contains milk and then making a vegan product that clearly doesn't contain milk, your cleaning has to be effective to make sure that all of the milk is removed from the line before you make your vegan product. Quite clear to understand, and that cleaning validation exercise will involve analytical testing to make sure the milk has been removed from the line. That's an easy one really to understand.


When we're thinking about other controls, for example, in a warehouse where you've got ingredients that contain milk and ingredients that don't, you have to be very confident that when they're picking materials to come into production, into weigh up areas for example, how can they be confident that always the right ingredients are brought into the weighing areas? Now that's a control, that also needs to be validated. Now that won't involve any analytical testing - it's about checking and providing evidence of the systems and the people who are doing those tasks get it right 100% of the time. Another area that we can help businesses with. I touched on the analytical testing part it's quite a challenge for vegan because there aren't tests available that cover that term, that single term, 'vegan'. So we're very clear - 'vegan' is not allowed to contain meat, there are tests that you can use to detect the presence of meat and there are tests that you can use to detect, for example, vertebrates (so anything with a backbone). Just as an example though, be careful, because of course we as humans are vertebrates, we have a backbone, so if you're using a vertebrate test you want to make sure it's not so sensitive that it doesn't pick up DNA, for example, from a human and give you a false positive result.


Other things that are clearly not allowed in vegan - we've touched on milk and egg. You would use a protein-based ELISA test, the kind of test that you use to look for allergens. We're very aware milk and egg clearly are allergens. So those are the kinds of tests you'd use for them. Fish, crustaceans, molluscs - again, there are both some DNA tests and also some protein-based tests for those kinds of things. It starts to get a little bit trickier when you think about ingredients such as honey. Honey of course is from bees, but it is something that is not allowed in a vegan labelled product. But a test just simply to say 'is honey present?' is actually quite difficult. So I guess it's just to be aware - some testing is quite straightforward, some is really quite difficult - and when we think right back to where we started in this conversation about what the Vegan Society, it's all about ethics. Clearly, there's no analytical test for 'is something vegan?', 'is it ethically vegan?' Just doesn't happen, so just be careful there is quite some challenges there. So where we can help certainly is we do a lot of work with helping businesses understand what that vegan claim might mean to them and making sure they can substantiate it. We work very much in the food allergen world, where we're looking at helping manufacturers get all of the areas around managing food allergens, which clearly has an impact on vegan. We've done a lot of work with businesses on helping them with supply chain and making sure they're doing the right kind of things with their supply chain, making sure they're asking the right questions and they're interpreting the right answers. We spend a lot of time in food manufacturing, helping people do both the risk analysis, the risk assessment (sorry) piece, and also the risk management piece, and clearly we have a whole testing facility within RSSL that we can help support and advise you on the right type of testing to do if you're making vegan claims and you need to be able to substantiate them.

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