As more information about allergens in food and drink is uncovered, a greater level of responsibility has been passed onto manufacturers. Anyone involved in the production of food and drink needs to be aware of the potential challenges associated with allergen labelling and the language that is used on product packaging.
Current UK regulations stipulate that all food and drink products must list their ingredients clearly on the label, with any of the 14 (major) allergens highlighted separately.
Alongside this, many firms use precautionary allergen labelling (PAL), which involves the addition of ‘may contain’ statements designed to add an additional warning to those with serious allergies about any further risk of contamination that may have occurred during production or elsewhere within the supply chain.
Despite the voluntary and compulsory measures in place, incidences of allergic reactions persist.
State of play with vegan labelling
One area of particular concern for allergen activists relates to vegan food and drink statements that can lead to confusion.
For example, of the 14 allergens, crustaceans, eggs, fish, milk and molluscs are not considered part of a vegan diet, which could lead a consumer to consider a vegan label on a product’s packaging as an assurance that the product does not contain any of these ingredients.
The Vegan Society, a UK-based educational charity, established the Vegan Trademark accreditation in 1990 as part of its bid to support people following a vegan diet and manufacturers developing vegan products. This trademark has since been awarded to more than 65,000 cosmetic, clothing, food and drink products around the world, with the purpose of giving “brands the confidence to shout about their vegan credentials”.
Asked by Food Manufacture whether the Vegan Trademark promises consumers that a product is entirely free from allergens such as crustaceans, eggs, fish, milk and molluscs, Claire Ogley, head of campaigns, policy and research at the Vegan Society, and Katharina Eist, the society’s head of commercial services, said that trademark does not serve as a guarantee.
“Some people confuse the label vegan with meaning free from allergens such as milk or egg,” the society explained.
“This is a potential danger for people with severe allergies to animal products. The Vegan Trademark denotes products are vegan to our rigorous standards as far as is practical and possible. We put strict yet achievable standards in place for brands to meet when registering items with the Vegan Trademark, to ensure consumers can trust that efforts have been made to avoid cross contamination within food services.
“This is not the same as being guaranteed entirely free from allergens.”
The pair added that if the Vegan Society’s accreditation process could only operate in instances where there was “absolutely no chance of cross contamination at all”, far fewer vegan products would be available.
“This would likely only be applicable to products made in entirely vegan premises which would drastically reduce the provision for vegans,” Ogley and Eist continued.
“More consumer education is needed to help consumers understand that ‘vegan’ does not necessarily mean the same thing as free-from and people with allergies should always check the allergen labelling on products before consuming them.”
In 2017, Celia Marsh died after consuming a vegan wrap from Pret a Manger that she believed would be free from milk. Marsh suffered from a severe cow’s milk allergy but believed the product was safe to eat due to it being labelled as vegan.
At the inquest, it was revealed that the yoghurt used in the wrap was the potential source of the contamination, with a chemist stating that “it would be reasonable to deduce there was milk in the sandwich”.
Such an example shows how consumers in a retail or foodservice setting could be confused by the claims made on a product label. This should give food and drink manufacturers pause when considering how they label their products and drive them to look more closely at the claims made by suppliers about the nature of certain ingredients.
Vegan labelling ‘false hope’ for food hypersensitive consumers
According to a 2023 study published in the journal Food Control, more than half of the product recall notices issued in the UK between 2016 and 2021 were related to allergens. With the possibility of cross contamination so persistent, Caroline Benjamin deems the current system of vegan labelling insufficient.
Benjamin, who founded HASUK in collaboration with Jacqui McPeake, offers forensic allergen audits and training to foodservice and food manufacturing businesses, and believes that the growing number of vegan products on the market has offered “false hope to FHS customers”.
“Many vegan foods can be labelled with a ‘may contain’ statement,” Benjamin explained.
“In some case it is because allergens such as egg or milk are prepared in the same factory or on the same lines as the food labelled as vegan, or because the manufacturer or supplier has not carried out a full risk assessment to understand the risks and what actual cross-contact could potentially have taken place.
“In many situations where testing is not carried out food businesses who manufacture vegan products are using disclaimer statements disproportionately.”
This perspective was echoed by Mike Woods, the founder and chief executive of bakery firm Just Love. The celebration cake manufacturer is focused on developing inclusive products that appeal to everyone, with 13 of the top 14 allergens covered across its range of baked goods.
“Consumers need to make sure they are buying from trusted brands, or rigorously checking the ingredient list, even if a product claims to be allergen free or vegan,” Woods told Food Manufacture.
“Just Love has consistently been working on removing allergens and ‘may contain’ disclaimers on its products and is urging other brands to follow suit.”
Referring to the Vegan Trademark accreditation process analysed above, Benjamin said that while producers are told to use PAL statements on their packaging where necessary, the Vegan Society does not “request that strict protocols are in place to ensure the elimination of animal proteins in their registered members products”.
Another issue that Benjamin has noticed is the increasing use of pulses and legumes in vegan products, a food group that is more commonly being seen as a potential allergen “across the FHS sector, especially among young children”.
“Pea protein is becoming a favourite ingredient in plant-based foods, being added in many processed foods,” she continued.
“Because pea protein is not one of the 14 allergens it can be difficult to obtain ingredient information.”
Taking action to protect FHS people
Both Benjamin and Woods believe that more must be done to keep FHS consumers safe, especially as it relates to vegan labelling.
Benjamin argued that the Food Standards Agency (FSA) should issue new guidance on how the term ‘vegan’ is used on food and drink packaging and then enforce laws that ensure manufacturers and foodservice settings adhere to the advice.
“The Vegan Society need to review their definition of vegan foods vs free from,” she contended.
“We would like to see a two-step accreditation where there is a A* safe for those with allergies and Vegan ‘MC’ where there is a known risk of cross contamination.”
Woods too wants to see key terminology such as free-from and vegan defined with FHS people in mind.
“The use of any claim should be able to be trusted,” he explained.
“There is nothing stopping someone calling a vegetable lasagna a ‘courgette and tomato lasagna’ but adding vegan ahead of the product name creates an opportunity for confusion based on the current lack of clear definition. A vegan claim on packaging would then be safe for milk and egg allergy sufferers.”
In order to ensure his products are safe and match up to the claims made on the packaging, Woods has developed “some of the most rigorous standards in the industry” and a culture where “everyone working at Just Love knows the clear, bold allergen statements that we make and the risks to consumers if we get it wrong”.
The measures Just Love employ include in-house rapid testing which validates that the raw materials entering its kitchen are safe to use.
“We use the same rapid testing allergen strips tests to validate cleaning, and the same rapid tests for each batch of product we make for the allergen we are declaring they are free from,” he said.
“This allows us to, in effect, positively release each batch. Within five minutes of starting the test it produces a positive or negative allergen result.”
Woods believes that allergen safety is “only as good as your weakest point” and rapid testing has helped embed this philosophy within the organisation. It has also allowed Just Love to work with a wider variety of suppliers and informs the cleaning team about whether an area is safe to start work on.
Just Love also uses external laboratory testing where necessary, as it allows the firm to “more confidently avoid using ‘may contain’ statements”.
“This enables us to go to much lower levels of protection than we could five years ago,” Woods concluded.
When asked what food manufacturers can do to improve their processes, Benjamin added: “SME’s and artisan producers need access to more support, guidance and training to ensure they are carrying out safe processes.
“They can also validate their processes when cleaning and preparing on lines – swabbing as appropriate to validate cleaning, and also testing products to ensure they are using the correct labelling and not just alibi labelling. Work with government guidance, label when there is an actual risk to the FHS customer, and avoid alibi labelling.”
It is understandable that food and drink manufacturers may need more support with allergen labelling; however, given the severity of a misstep, it’s equally important that best practice is reviewed, consistently.
And when it comes to vegan claims and allergies, do we need tighter regulations? The vote will undoubtedly be spilt.
In other news, The Sustainable Bottling Co has launched a new aluminium drinks bottling facility near Leicester.
