Allergen vs Vegan Labelling

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Products suitable for vegans aren’t always suitable for people who suffer with allergies so it’s important to know the difference. The Vegan Society appreciates the need for clear and informative clarification on product packaging or food menu items. There are key distinctions between the criteria for “vegan” products and “allergen-free” products. We explain more in this blog post.

Vegan labelling

Clear labelling was the main reason we created the Vegan Trademark in 1990. We wanted to help provide clarity for vegans looking for products without memorising ingredient lists or spending time emailing companies for verification. The great news is that the Vegan Trademark has robust and achievable standards to certify a vegan product. In summary, The Vegan Society ask that any product wishing to carry the Vegan Trademark contains no animal ingredients, has not been tested on animals (at the initiative of the company or on its behalf, or by parties over whom the company has effective control), and that cross-contamination is minimised as far as possible.

We’ve gone into extra detail about the cross-contamination checks we carry out as part of menu item registration because we know that it’s essential that we’re transparent regarding the verification we do, and what that means when choosing products. However, our checks do not address products to an allergen standard, and any vegan claims should not be considered automatically safe for people with food allergies.

Allergen labelling and ‘may contain’

You may notice that alongside many of the products registered with the trademark, statements such as ‘may contain’ or certain items that appear in bold in the ingredient list. It is part of General Food Law (Regulation (EC) No 178/2002) for companies to highlight the 14 leading allergens on their products. If there is a risk of cross-contamination, they should also outline that the product ‘may contain’ that allergen so that companies do not mislead consumers. The risk of cross-contamination can include the allergen simply being in the same facility as the product, even if the areas for preparation or cooking are separate.

The allergens identified include some that are suitable for vegans, such as mustard, soy, gluten, nuts, peanuts, celery, sesame, lupin and sulphur, and non-vegan items, such as milk, eggs, fish, molluscs and crustaceans.

This guidance was introduced in the UK by the Food and Drink Federation (FDF) alongside the British Retail Consortium (BRC) in 2015 and applies only to these common allergens. Other countries will have their own guidance which are similar to what we at The Vegan Society have based our cross-contamination standards on. Please check with your country’s Food Safety Agency for more details. 

As of October 2021 in the UK, businesses will need to follow the new guidelines on labelling allergens on pre-packaged food for direct sale (PPDS) because of Natasha’s Law. This is for food made on the same premises from which they are sold and packaged before sale. Businesses will be required to clearly label what the product is and include ingredients with highlighted allergens on pack. More information about Natasha’s Law can be found here.

Anyone who does suffer from one or more of the 14 leading allergens should not solely rely on vegan claims (including our trademark) as a suitable way to manage their safety because there could be an unintentional cross-contact with allergens in the manufacturing or preparation process. In 2020, in consultation with our trademark team the FDF also provided guidance on the difference between vegan and allergen labelling, which you can read more about here.

Products labelled “free-from” or “allergen-free” generally make these claims because the manufacturers of these products have opted to reduce the risk of cross-contamination by using entirely separate facilities for that product's development and manufacture, which are regularly tested. This is certainly manageable for businesses who specialise in only producing “free-from” product ranges. However, for many brands who have well-established products, entirely separating their facilities or using additional sites for vegan options could increase their costs, resulting in this being passed to the consumer and thus reducing the accessibility of vegan options. and therefore the product’s cost exponentially, and requires more business resources, land, development teams and testing.

For this reason, many products that are suitable for vegans may be made or prepared in the same facility as non-vegan allergens, providing that any cross-contamination is thoroughly managed.

The Vegan Trademark standards require brands to minimise cross-contamination as far as possible. Still, we do not request completely separate facilities, which means a slight risk from the shared space. This is why many products include precautionary statements such as “may contain milk” while also being labelled as ‘vegan’. The Vegan Society does not claim that products registered with the Vegan Trademark are suitable for people with allergies to animal products; this depends on the standards achieved by individual manufacturers.

As noted in the guidance by the FDF:

“The 2018 European Vegetarian Union (EVU) guidance, supported by FoodDrinkEurope, states that ‘the (potential) presence of inadvertent traces of non-vegan or non-vegetarian substances should not be an obstacle to labelling a product as vegan or vegetarian…as long as reasonable measures are taken to prevent contamination. The Vegan Society’s Vegan Trademark can also be applied to foods carrying a ‘may contain’ statement providing that there is robust evidence to show the risk of cross-contamination has been effectively managed.”

Vegan products may carry warnings about allergens from animal sources, and anyone concerned about these allergens should contact the company directly before purchasing.

LiberEat

LiberEat is a free UK product search, recipe and shopping app that was developed by a nurse who wanted an easy way to find products based on dietary restrictions or preferences. The app now offers product scanning, product and menu filtering and recipes based on profiles built for vegans, as well as those with the 14 leading allergens. The team receive funding from the Scottish government to continue their work and developed the app alongside the Aberdeen University Rowett Institute and Robert Gordon University. The Vegan Trademark will show against any registered products, making the app a great resource for those following a vegan lifestyle with allergens.

By Vegan Society Business Development Marketing Manager, Ericka Durgahee.

 

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