Food Law News - UK - 2004
FSA News Item, 11 November 2004
LABELLING - Advice to be drafted on vegetarian and vegan labelling
The Agency is to draft best practice advice on vegetarian and vegan labelling that will include advisory definitions of these terms. The draft advice will be sent out for a full public consultation in the summer of 2005.
The Agency has been aware of consumer concerns relating to food being labelled as suitable for vegetarians and vegans, and held a stakeholder meeting to discuss vegetarian and vegan labelling on 12 October 2004 . Notes of the meeting are given below.
The Chair explained that this stakeholder meeting on vegetarian and vegan labelling was being held so stakeholders could inform the Food Standards Agency of their views and the rationale for them. There would be no attempt at the meeting to achieve a consensus view on issues.
Prior to the meeting the Agency had circulated a background paper that included information on the legal position with respect to vegetarian and vegan labelling and on definitions used by different stakeholders. Alette Addison gave an introductory talk which:
- described the current legal position
- the broad approaches taken by various stakeholders
- the progress made by Codex
- the difficulty of achieving a legal definition within the EU
- the options available to the Agency
The background paper and the presentation informed the subsequent discussion. The following points emerged in discussion.
- Stakeholders recognised the differing definitions of vegetarian in current use and the range of issues such as animal welfare and environmental concerns that can dominate this area.
- There was general recognition that any definitions should be drafted in terms of exclusions, rather than by listing permitted foods.
- There was general recognition that a definition should exclude food from red meat, poultry, game, fish, shellfish, crustacea, amphibians, molluscs and insects, by-products of these (e.g. animal fats and blood), and products made from all of these (e.g. stocks, cochineal).
- There was general recognition that processing aids produced from animals and animal products listed above should be not used in the production of vegetarian food, even if no trace of them remains in the final product.
- There was less of a consensus over products from living animals. Some thought that milk and dairy products, eggs, honey and other aparian products, shellac, and lanolin were appropriate for vegetarians, as were processing aids made from them. However, of the foods in this list, only milk and dairy products are permitted for Hindus.
- The presence of eggs or egg products would be revealed in the ingredients list.
- The vaccination of animals is not an issue with regard to a definition of vegetarian food.
- There was general recognition that because vegan food excluded all food made from animals or animal products, it was easier to define than vegetarian.
- It was suggested that foods that are labelled as vegetarian or vegan ought to satisfy higher standards of healthiness than other foods. Others thought that this was not something that was appropriate for the Agency to address.
- It was recognised that the integrity of vegetarian and vegan food could be compromised by cross-contamination with other food during production, preparation and sale, using the same tongs for different food in shops, and using the same oil to fry different foods.
- It was thought that there might be scope for a due diligence option in the definition.
- Experience on allergen handling might be brought to bear.
- The Vegan Society had proposed that a maximum level of cross-contamination might be set at one part in 10,000.
- While it was clearly recognised that this was an important problem for vegetarians and vegans, the argument was presented that it was not appropriate to address this in definitions.
The criteria for use of vegetarian and vegan related logos and trademarks incorporated other criteria related to the manner of food production. There was general recognition that there was a clear distinction between criteria for use of these, which were in part commercial matters, and the narrower definitions of vegetarian and vegan foods. It followed that these other criteria should not be part of any definitions.
After the discussion, the Chair said that the Agency would produce a note of the meeting and circulate it to those present. He thanked everyone for an extremely useful, clear and illuminating discussion. The Agency would consider all of the points made, and decide what were the appropriate next steps. Stakeholders would be informed in due course.
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