Allergen labelling

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Is it vegan?

Allergen labelling has caused confusion over whether some products can be classed as vegan. There are currently fourteen allergens that must be labelled on foods and these include crustaceans, fish, milk, eggs and molluscs. Under food-safety regulations companies are required to conduct a risk assessment to determine whether the foods they produce may contain any of the known allergens. If they establish that there is a risk and that risk cannot be eliminated then they must include a ‘may contain…’ label on the pack.

Packet of Biscuits

The ingredients list provides details of substances that have been deliberately added while the ‘may contain’ list gives details of allergens that could be present at a low level due to cross-contamination. We have to accept that some accidental contamination from animal substances is likely in many situations. Insect remains may occur in foods such as fruit, vegetables, flour and spices. Even after thorough cleaning some cross-contamination may occur on production lines that are not dedicated to vegan products.

Chocolate production is a particular problem since production lines are not cleaned with detergent and water in between different products. Instead some of the next product is used to flush out the previous product and then discarded. This means that low levels of dairy contamination are likely if a vegan chocolate is manufactured after a milk chocolate. The only way to avoid this is to operate a completely vegan production area. Even then manufacturers could not claim their product contains zero animal cross-contamination. To make such a claim would require the manufacturer to test every batch of every ingredient for animal contamination. A further problem is that the detection levels for the test methods do not go as low as zero. For example the detection limit for lactose is 70 parts per million (ppm) and so if this test produces a negative result a manufacturer can claim only that the product is known to contain less than 70 ppm of lactose.

What about trademark products?

The Vegan Society does not claim that trademarked products are suitable for people with allergies; that will depend on the standards achieved by individual manufacturers. To encourage manufacturers to give a serious commitment to avoiding animal cross-contamination the following statement has been added to the Trademark licence agreement:

"I confirm that our company strives diligently to minimise cross-contamination from animal substances used in other (non-vegan) products as far as is reasonably practicable."

However we accept that some trademarked products may also carry warning labels such as ‘may contain milk’ because this refers to accidental low-level cross-contamination. We live in an imperfect world and if we made the Trademark criteria any more stringent we could have very few products labelled vegan. We aim at encouraging manufacturers to produce more foods that do not contain deliberately added animal ingredients and so reduce the exploitation of animals. If our demands are unrealistic many manufacturers will ignore us. As the demand for vegan products grows we will be in a stronger position to request dedicated vegan production lines and then purely vegan factories.

Comment from the Food Standards Agency:

“As you are aware there is no legal definition of the term vegan, but the Agency's voluntary guidance on use of the terms vegetarian and vegan in food labelling advises that foods labelled as vegan should not contain milk and contains some advice on cross contamination.

Although the Agency advice suggests that  "Manufacturers, retailers and caterers should be able to demonstrate that foods presented as 'vegetarian' or 'vegan' have not been contaminated with non-vegetarian or non-vegan foods during storage, preparation, cooking or display." we would not be against a food that is labelled as vegan carrying a warning on the label that it is produced in a factory or on a line where certain dairy products or allergenic foods are also handled and used. We would also not be against a 'may contain....' warning. In fact we would consider it to be advantageous.  It is important for safety reasons for consumers to know that possible allergens may be present.”