Wednesday 22nd November 2023
The “Vegan” label is based around an ethical avoidance of animal products, it does not always guarantee the complete absence of animal allergens (1).
Nevertheless, those unlucky few who are sensitive to trace levels of milk or egg may look to vegan and plant-based brands to find products suitable for them.
How might a manufacturer look to provide for this sector?
- Good control over their supply chain and production facilities,
- Robust risk management and quality systems to prevent unintended allergen presence,
- Removal of “May Contain” labelling where the risk can be adequately controlled,
- Use of “egg-free” and “dairy-free” labelling where it can be verified.
While it may require extra effort on behalf of a food manufacturer to go above and beyond general Good Manufacturing Practice and make everything “allergen clean”, it will not only improve the safety of the food for allergen-sensitive consumers, but also bring peace-of-mind to many vegan customers as well. Indeed, it is hard to imagine a scenario where improving risk management is anything but a good thing!
And if as a food manufacturer you already putting in the effort to do all this, maybe consider removing the “May Contain” warning from your product. The FSA presents a checklist as to steps that should be taken before applying an alibi label (2) and recommends using precautionary labelling only when there is an “unavoidable and real risk” to the product.
The overuse of May Contain labelling on otherwise safe food impacts everyone (3). It limits the allergic consumers’ choice by advising them against eating a product while impacting sales by cutting down the customer base. Even the vegan consumer - without an associated health issue - may be put off by the perception that their food may contain animal ingredients.
At the end of the day, if the conscientious manufacturer has put in the time and energy to ensure the safety and integrity of a product, why then tell customers that they shouldn’t buy it?
ALS can help you with your risk management by providing complete testing for dairy, egg, and many other allergens in both food products and environmental samples.
For more information on Precautionary Allergen Labelling, the FSA has produced comprehensive advice (4,5). Or, to use Quantitative Risk Assessment for your precautionary allergen labelling, join us for our webinar in December.
References:
- https://www.fdf.org.uk/globalassets/resources/publications/fdf-guidance-allergen-free-and-vegan-claims.pdf
- Precautionary allergen labelling checklist | Food Standards Agency (https://www.food.gov.uk/business-guidance/precautionary-allergen-labelling-checklist)
- 'May contain...' food allergy warnings are used so much they become meaningless, report warns | The Independent | The Independent (https://www.independent.co.uk/life-style/food-and-drink/news/may-contain-food-allergy-warnings-are-used-so-much-they-become-meaningless-report-warns-10480191.html)
- Precautionary allergen labelling | Food Standards Agency (https://www.food.gov.uk/sites/default/files/media/document/Precautionary%20Allergen%20Labelling%20FBO%20research_0.pdf)
- Food allergen labelling and information requirements technical guidance: Summary | Food Standards Agency (https://www.food.gov.uk/business-guidance/food-allergen-labelling-and-information-requirements-technical-guidance-summary