Seems Canada is slightly more stringent than the US definitions of Vegan, which is to say FDA is aware "vegan" is a thing and they want no part in regulating it. If you're going to go as far as throwing that word on your packaging, I'd make sure you have a program in place that truly verifies the ingredients aren't in any way involved in the slaughter of animals as someone batting for that team will eventually want to claim you didn't do enough to check your ingredients: some random side ingredient having gelatin from pork skin or something obscure could bite you in the rear if you're not careful.
Food composition and quality claims - Canadian Food Inspection Agency (canada.ca)
Vegetarian and vegan claims
For vegetarians, in addition to plant foods such as fruits, vegetables, grains and nuts, their diet may include animal products not derived from slaughter, such as eggs, milk and cheese. Animal products resulting from slaughter, such as animal/fish flesh, bone, stock, fats and gelatin, are not, by definition, included in a vegetarian or vegan diet.
The CFIA would not object to the general term "vegetarian" to describe foods that are suitable for any one of the types of vegetarian diets.
For example:
- lacto-ovo (or ovo-lacto)-vegetarian - permits plant foods plus dairy and egg
- lacto-vegetarian - permits plant foods plus dairy, no eggs
- ovo-vegetarian - permits plant foods plus eggs, no dairy
If any of the vegetarian claims above or other type of vegetarian claims are being made on a food, the food is expected to contain only ingredients derived from the sources included in that type of diet.
While a vegan diet or foods are made from only plant-based ingredients, it is also recognized that several definitions of "vegan" exist. When making claims on a food, companies can apply additional criteria or standards that take account of other factors in addition to the ingredients of the food.
Take this definition from one of the Trademarked Vegan certifiers as an example of what people "expect" when they read "vegan" on a label:
Best Vegan Certification Trademark. ISO Accredited. V-Logo apply. (beveg.com)
Vegan means no animal ingredients or by-products used in the manufacturing process before packaging of the proposed Vegan product, and confirms that the processing aids used and process applied to making the final BeVeg certified Vegan product is also Vegan. BeVeg asks for disclosures for all “incidental” and “insignificant” ingredients, including natural flavorings and natural colorings. Likewise, source ingredient manufacturers to listed parent ingredients are also investigated to ensure Vegan integrity is maintained. For example, if sugar is used, proof that the manufacturer uses zero bone char (often disguised as “natural charcoal”) is required.
