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Vegan claims on products produced on non-dedicated vegan production lines

Vegan claims BRC

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#1 Takidoshido

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Posted 28 May 2020 - 06:07 PM

Hi everyone, here's a question.

We have a client, who would like to add to the packaging of a ready meal, that its suitable for vegans

The meal is totally vegetable based & all ingredients are vegan friendly.

But, we produced meals which have animal origin. we would find it very difficult to produce this meal first run of the day & its quite costly to conduct rapid analysis swabs after the non vegan meal, before production of the vegan meal.Also the down time waiting for the results of the cleaning verification is worrying as well

 

According to the Food information to consumer regs (EC 1169/2011), ," Article 7 Fair information practices 1. Food information shall not be misleading, particularly: (a) as to the characteristics of the food and, in particular, as to its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of manufacture or production;"

 

Therefore am I correct in saying that if we do not substantiate by testing that the said meal does not contain any animal matter (from cross contamination) we are in deed breaking the law.

 

Also would it be fair to say, that a BRC auditor would expect us to provide evidence that the "vegan "meal was in fact animal matter free, as this is a "claim"

 

Any help would be much appreciated



#2 SQFconsultant

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Posted 28 May 2020 - 06:26 PM

Evidence of this "claim" would be required.

 

If you can't back-it-up... well, you know.


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#3 olenazh

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Posted 28 May 2020 - 06:30 PM

We manufacture dairy products and non-dairy at the same plant. We've established a non-dairy management program, including regular (annually) milk allergen testing to verify a vegan claim. The customer whom we make non-dairy for is completely satisfied, and we didn't have any objections from CFIA or GFSI auditors.



#4 pHruit

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Posted 28 May 2020 - 07:22 PM

I'd have a chat with your local Trading Standards department as to how they interpret the claim, as IMEX they (entirely reasonably) don't treat this in the same way as a "free from" allergen-style claim. Validation is also an interesting question, as there are potentially animal derivatives that wouldn't necessarily leave a trace that would be easily analytically detectable.

There is also a draft ISO standard in the works (23662) that takes a similar approach, i.e. you're taking "all reasonable" measures to avoid using animal ingredients, and not expected to ensure an absolute total absence. FWIW my experience has been that the Vegan Society also takes a similarly pragmatic view.

Perhaps also worth consider whether your cleaning process is e.g. already validated for allergen control, as this would arguably be more than sufficient.

 

Nonetheless I'd also recommend asking your client what their definition/expectations are, as this may differ and require some specific considerations.

 

In any case it will most likely be necessary to confirm the status of the ingredient with your suppliers, particularly those with potential "hidden" animal derivatives (e.g. shellac wax on the skins of citrus fruit from which oils are extracted to make a flavouring), and word your questions carefully as you may find that not all countries/regions have quite the same idea about what veganism entails ;)



#5 Takidoshido

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Posted 28 May 2020 - 07:23 PM

Glen, would this back up, be required for every production run?? or would periodic testing be sufficient as olenazh is suggesting??

 

thanks 



#6 pHruit

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Posted 29 May 2020 - 07:36 AM

Glen, would this back up, be required for every production run?? or would periodic testing be sufficient as olenazh is suggesting??

 

thanks 

 

As I've indicated above, testing is likely to only be one part (if any) of the substantiation of your claim - whilst cross-contamination is an entirely valid consideration, the claim itself is primarily about what you are (or indeed, aren't) intentionally putting in the product - I'd suggest this is not necessary for every batch, as it can be undertaken on a periodic basis provided that it is sufficiently robust. You'd therefore require some sort of declaration from your raw material suppliers as to whether any animal ingredient are present (intentionally or otherwise) in the product, and that they will advise you in advance if this is subject to change. The exact form this takes may depend on the nature of the raw materials, your own requirements, and those of your customer - for example some expect to see a full allergen-style risk assessment of not just what is in the ingredient, but what is in the supply chain, what else is on site, what the potential for cross-contamination is etc.

 

Your own testing frequency is then potentially going to depend on the specific risk you determine to be present on site, and given that you're BRC certified, you can be nigh-on certain that they'll expect to see a risk assessment to substantiate the testing frequency ;)

Whether this necessitates downtime is in some senses a business risk - there is nothing to stop you starting vegan production before the results of the swabs are back, but this would only be a sensible approach if you know your cleaning controls are thoroughly validated as effective, as if the result comes back and it's not the one you want then you're going to have to scrap the entire production, which is never a fun discussion ;)

 

These types of consideration, along with some of the retailers approaching vegan as being very nearly directly analogous to a "nut free" style claim, is a significant driver for the trend in the UK for some of the larger manufacturers to start setting up dedicated "plant-based" sites, to avoid the testing/control headaches, although that has only relatively recently become financially viable due to the rapid growth of this sector of the market. As someone who has been a vegetarian for over twenty years, I can confirm that this definitely wasn't the case even relatively recently!



#7 zanorias

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Posted 29 May 2020 - 09:10 AM

It can be done, I used to QA for a manufacturer that did meat products and began doing several vegan lines. BRC and retail customers were happy with the controls. Unfortunately I can't help you much with the specifics because I wasn't involved with the risk assessment, QMS etc; I was a factory QA at the time but I do know that between meat and vegan production a full clean down of the equipment was done with ATP swabs with a max RLU of 14 had to pass on every piece of equipment before vegan production could start.



#8 Takidoshido

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Posted 29 May 2020 - 05:49 PM

Many thanks to you all. It has been most enlightening & confirmed my thoughts







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