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Allergen Statement for Vegan Products


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#1 Ciegel

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Posted 05 November 2019 - 08:28 AM

Hi everyone, 
 
Our factory is a milk-derived factory. One of our customers requested vegan products, so we had to replace our milk protein with vegetable protein.
If we analyze milk allergen residues in our products and the results are negative, can we not write a warning about milk allergens in our products?
 
What we need to do to meet the FSSC requirements?
 
Many thanks


#2 GMO

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Posted 05 November 2019 - 08:35 AM

You cannot test something safe (nor vegan).

 

What I'd do is risk assess it.  Is there a risk of getting milk in your product?  Can it be reduced?  What are the risks of any mitigation measures going wrong?  If there is a risk, even if from sampling you don't find it, then "may contain" labelling is sensible, albeit it's no protection from prosecution.  Remember it's not just vegans but people allergic to milk who could be impacted.  For vegans it's *just* the disgust factor, for allergenic consumers it could be death.

 

Effectively though vegan is a "free from" claim not just a marketing thing so rather than "can I get away without a may contains for FSSC..." IMO you should be thinking "can I make this safely?"



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#3 Charles.C

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Posted 05 November 2019 - 11:23 AM

 

Hi everyone, 
 
Our factory is a milk-derived factory. One of our customers requested vegan products, so we had to replace our milk protein with vegetable protein.
If we analyze milk allergen residues in our products and the results are negative, can we not write a warning about milk allergens in our products?
 
What we need to do to meet the FSSC requirements?
 
Many thanks

 

 

I deduce the above means that the objective is to only state "Vegan" on the label notwithstanding the possibility of (undetectable) dairy allergens.

 

From a Vegan (official)  POV the objective seems (perhaps) to not be mandatory. At least in UK. (OP Location is unknown). The first link below implies (at least in UK/2015) that this issue is(was?) "contentious" (in various ways).

 

https://www.foodsmat...free-04-15.html

(apparently issued in 2015)

 

https://www.vegansoc...gen-labelling-0

 

https://veganfooduk....y-contain-milk/

 

https://itsahealthyl...gg-is-it-vegan/

 

 

And yes, I appreciate that the interpretation of "cross-contamination" might be relevant also.


Edited by Charles.C, 05 November 2019 - 01:33 PM.
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Kind Regards,

 

Charles.C


#4 pHruit

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Posted 05 November 2019 - 01:55 PM

I discussed the current UK regulatory interpretation of exactly what "vegan" means with Trading Standards a few months ago, largely in response to increasingly daft / optimistic requests from customers.

Broadly their view is similar to that espoused in the declaration that the Vegan Society mentioned in at least one of the links provided by Charles: "we confirm our company strives diligently to minimise cross-contamination from animal substances used in other (non-vegan) products as far as is reasonably practicable".

There is therefore no real expectation of an allergen-style "free from" position being necessary, as long as reasonable precautions are taken and controls are in place.

 

I think GMO's suggestion is very valid - IMO you should be looking at proper risk-based controls and validation of these for the allergen aspect as the primary objective here.
Additionally you may want to discuss with whoever the applicable regulatory body is to understand the implications / interpretation around the vegan claim if there is an unavoidable requirement for "may contain milk" labelling. As you're packing for a customer, I'd also recommend discussing their requirements to make sure that you understand what their expectation is, and they understand what is achievable. IMEX customer's own vegan requirements can be far more detailed (tending towards outright absurd) than the Vegan Society ones.



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