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  • Writer's pictureMeyrick Consulting

Is your vegan meal really vegan?

How can you be confident that cross contamination hasn’t occurred?

With many people making the decision to eat less meat, manufacturers are shifting their production to include more plant based or meat free alternatives. This is exciting and has certainly made following a vegan diet much easier than it used to be. However, can we really afford to rely on this without checking the labelling carefully to give us an animal derivative free experience? The rise of vegan products has definitely thrown up some specific challenges. It is worth thinking about those and what can be done to manage them.

Do we know what the definition of Vegan really is?

I think we would all hazard a guess at a definition basically running along the lines of: products that don’t contain any animal products or derivatives. Basically nothing should be derived from animals. That might be meat, bone marrow, gelatine, eggs, crustaceans, fish, shellfish, milk, cheese, honey and so on.

Photo: Foodism360

Where is the legal definition of Vegan?

However, I am not sure if everyone is aware that actually there is no legal definition of the term Vegan, either in Europe or the UK. The Vegan Society, for example, was set up to bring about an ethical revolution. Therefore these ethics surround the whole environment in which Vegan food is grown, transported and manufactured. One thing I am not sure of is whether the packaging in which these foods are wrapped is also wholly ethical within this specific context. It requires more research

What about the packaging? Should we check that too?

Yet, there are some manufacturers who have been working to make packaging to special requirements including Halal and vegan packaging. This ensures that products can be certified as 100 per cent free of raw materials that are of animal origin and/or include alcohol. Gabriel-Chemie, a plastic fabrication company based in Kent, makes use of the globally recognised HQC or Halal Quality Control’s Halal certificate. Also they use a V-label and have been doing this since 2018. It looks like this is yet another thing consumers will need to check.

Photo: Bekky Bekks

The 'may contain' clause

However, this lack of clarity means that different manufacturers and retailers will inevitably interpret that ‘vegan’ phrase in the way that works for the. This is not ideal. What happens is that although there will be no direct animal products within a vegan foodstuff it’s possible the label could say: ‘may contain milk’. Some might stipulate that there will be absolutely no animal products and others may even say ‘may contain, egg, milk or fish.’ Those cutting down on meat or dairy may not be bothered, particularly, however those with serious food allergies might be in for a very nasty shock if they are relying on vegan products as being a safety gauge in a ‘must be Vegan so it has to be ok’ approach.

Are standards tight and clear enough?

The problem is that if you have an allergy to molluscs, crustaceans, fish, eggs or milk you would expect a vegan product to be completely free of any of these ingredients. However, to assume, as we all know, makes an ass of you and me. Therefore it is still up to each one of us to check labels assiduously, regardless of what the title might suggest. We would expect the same standards in vegan food as the ‘free from’ range for example. This is definitely not the case at this moment in time. Photo: Storiès

The responsibility to check everything relies solely on the consumer right now

This situation has actually become a risk and there have been product recalls and incidents after severe allergic reactions. Some manufacturers use the phrase ‘vegan friendly’, ‘plant based’ or ‘suitable for a vegan diet’ as a softer way of selling their wares. This may well be a good thing but the onus is left on the consumer to read every single ingredient on the back of a packet to be absolutely sure regarding what a product’s constituents. Therefore we can see from this how much we must define the term ‘vegan’ soon.

Of course the issues are not just sited in the manufacturing process. What about the supply chain?

If something is manufactured to a vegan recipe it should not have animal products or animal derived ingredients inside. Some manufacturers are using unfamiliar ingredients, like pea protein and are having to source these from suppliers with whom they have had no previous dealings. Are they actually asking the right questions of their supply chain? These might be something like:

  • Is there any likelihood of the pea protein being at risk of any unintentional presence during the storage or transportation?

  • Are there any opportunities for cross contamination risks?

  • How are the suppliers managing any potential risks?

  • If original pea protein factories handling milk or any other ‘toxic’ product?

  • If this is the case how are the processes managed to avoid cross contamination?

Photo: OSG Containers

In addition, Covid has made it more difficult to audit or physically visit new suppliers. Doing all of this remotely has been a definite challenge alongside actually getting deliveries over borders, out of countries as well as bringing in harvests and having a sufficient covid free workforce.

Risk management is vital

If a producer manages to buy in all the required ingredients with the appropriate assurances what happens next? The production of Vegan food falls into two main categories: those that are dedicated vegan factories and those that handle animal derived products and clear the line to manufacture a plant based item. In a Vegan factory the only risks are the ingredients you source and bring in and the people who work in the factory. However, people can cause issues. Therefore excellent hand washing, overall/ protective clothing changes and ensuring anything they have eaten from outside the environment do not cross contaminate in any way is essential.

Every single risk needs to be managed

Yet because veganism is such a huge trend, that is growing exponentially, many non-dedicated facilities are making vegan alternatives but within an animal derived production setting. It can be done of course, but the company has to undertake a first class risk assessment to understand just how animal derived might accidentally find its way into products labelled as vegan. The challenges surrounding the supply process affects the actual production itself, the people or the environment. Controls need to be in place to manage every individual risk. These must be identified first then managed to avoid any cross contamination. Photo: Jordana

These controls should then be validated to explore

This is to ensure they are actually effective in managing risk and reducing it to an easily manageable level. This is not new as factories will be familiar with cleaning validations for example. At the moment, though, if products are made using milk on one production line which then swaps to a non-milk production line then all milk traces must be removed entirely. This will include animal testing to ensure milk is removed from the line and it's very easy to understand. However, the controls do not end there. For example, other checks and balances need to be in place within warehouse space. If and when materials are picked up in weigh-in areas, who ensures the right ingredients are in the appropriate weighing area? It is a control that needs to be validated. Someone needs to check and provide evidence that systems and people get all processes right 100% of the time.

Analytical testing processes are a challenge when it comes to vegan production

However, there are terms and definitions that do cover vegan production. In fact, there are specific tests to detect the presence of meat. It can show up as evidence of backbone material. The only issue here is that we are vertebrates ourselves; we have a backbone. Therefore testers have to ensure that the sensitive tests do not throw up a false positive result when showing DNA that’s actually from a human. There are also milk and egg protein based Elisa tests that will check for allergens. No doubt more will follow.

Honey is another issue for vegans

As it is made from bees it is not allowed in vegan labels products but a test for the presence of honey is still quite difficult. Therefore without a very specific definition the responsibility for allergen safety is down to the consumer. Do not take anything for granted.

Photo: Art Rachen

Opportunities for change and innovation are enormous

On the other hand with the stricter guidelines in developing and manufacturing vegan and plant based foods there will be considerable opportunities for new roles that food and ingredients manufacturers will need to consider. It’s a period of rapid innovation and exciting developments but there are risks. These need to be managed and companies should have the right artificial intelligence and highly trained staff to ensure ethics and safety.


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