EU "Suitable for vegetarians" claim
Good afternoon,
I have a little question regarding a commercial claim to be placed on the package. We want to label a product that a supplier bakes to us as "Suitable for vegetarians", all the ingredients are suitable for vegetarians but my TM still says that we cannot use it as our supplier is small and doesnt hold BRC accreditation but the only guidance that I can find is http://webarchive.na...giguidancenotes and doesnt mention anything regarding accreditation.
Could somebody give some guidance as I'm struggling a little bit regarding commercial claims like this one?
thanks everybody!
You certainly don't need BRC accreditation. You would need to be able to demonstrate that it it suitable for vegetarians though. If there's cheese, is it produced with vegetarian rennet, is there gelatin used etc, It can be a bit of a minefield.
Apologies for nitpicking but use of "accreditation" should probably be replaced by "certification"
Thanks for your reply, I found that a bit odd but my TM was insisting on that, there is a lot of confusion with this commercial claims. I have a written statement from the suppliers of our additives that ensures that are not from animal source so I hope this would be enough.
Apology accepted. I tend to misuse the word and get myself confused.
LPali,
That should be sufficient to declare that the product is suitable for vegetarians. It's always worth double checking as not everyone understands vegetarianism. I was once asked why our pesto was not suitable for vegetarians and met with confusion when I mentioned the use of Parmesan cheese!
Thanks for your reply, I found that a bit odd but my TM was insisting on that, there is a lot of confusion with this commercial claims. I have a written statement from the suppliers of our additives that ensures that are not from animal source so I hope this would be enough.
Hi LPali,
I noted yr link is rather antique (2006)
Definitely not my area of expertise but I would have thought further official EU attention might now exist (somewhere). Maybe pass this 'buck" to yr TM ?
IMEX vegetarians can be quite demanding re their intake. Not unreasonable of course.
PS - where will the product be consumed ?
Hi,
a legal definition is still missing in the EU. Acc to Art 36 FIR there is the possiblity to set a legal definition. But the commission has stated that setting a definition for vegan or vegetarian is not a priority.
Proposals for a definition has been refined in the last month e.g. with participation of VEBU. VEBU provides a label (V-lable http://v-label.eu/
Rgds
moskito
What your TM may be concerned with is if the supplier isn't audited to a GFSI standard like BRC then it's likely you will need to audit to substantiate they are being accurate in their claim, their cleaning is effective and their raw materials sourcing and approval is good. For you to comply with some standards you would need to do some mass balance audits to ensure their trace is robust.
But for legal reasons I don't think you need to do anything more than ask your suppliers if they're vegetarian and ensure your process is but for the fact you're making a claim, I would go much further. Remember there are tiny cafes and restaurants capable of declaring a meal is vegetarian perfectly legally in the EU without a team of technical people, whether they sometimes get this wrong? Probably from time to time, especially on cheese.
As already mentioned, there isn't any legal definition of vegetarian in Europe yet.
The definition from vebu given by Moskito is as far as I know the more extensive and with more weight that exists today.
The EU commission does intend to define the terms of vegetarian and vegan in a somewhat close future - probably a few months. They have already something started.
As I see it, the absence of a legal definition causes two major problems for you:
1. You are not sure what your supplier mean when they say their product is suitable for vegetarians.
2. Your customers might not define it the way you do, and even if you are legally safe, a media "war" is pretty common with these kind of associations...
A to the certification of your supplier, it is perfectly acceptable to rely on your supplier risk assessment: If you trust them to sell you a safe product regarding other matters (for ex. Allergens), why wouldn't you trust them on this?
Best regards
Probard
It is well known that in some countries in the EU when asking for a vegetarian meal it will come with animal rennet produced cheeses (e.g. Parmesan) or even ham in it! I would be really clear with your supplier what is and isn't allowed so at least on paper you have evidence that they are not including:
Meat (specify what you mean, e.g. chicken, beef, pork, ham, bacon, game etc)
Fish (specify)
Animal rennet or cheeses produced from it.
Colours produced from animal sources, e.g. carmine
Gelatine
Etc, etc.
And I'd find out what non vegetarian ingredients are present on site but an audit might not go amiss. Often something on paper may look good but in practice looks bad and, if I'm honest, the reverse can often be true too. I've audited suppliers before thinking they must be awful to find out they're actually ok, just need some guidance.