It started with a tweet from Carly (@GfreeB) about a Montezuma’s label reading ‘free from … gluten’, an expression not permitted under labelling law. The words have to be ‘gluten free’, although many companies slip up, most recently Saclá, with their ‘free from wheat, gluten and dairy’-fronted new pestos.
Also catching my eye was a ‘may contain dairy traces’ warning sitting brazenly alongside the word ‘vegan’. Although there is no legal definition of ‘vegan’ (or ‘vegetarian’), this would appear to flout 2006 guidelines from the FSA. (See clause 17.)
Thursday evening’s #allergyhour was underway, so I asked whether dairy allergics ever took a ‘vegan’ label to infer safety – ie dairy-freeness. You can see the responses in the long Twitter thread here, but essentially we fell into two camps: those who’d assumed ‘vegan’ implied dairy free (including me), and those who thought (or knew, as it turned out) otherwise.
Sceptical at the time, I contacted the Vegan Society. Sam Calvert, their Media Manager, who I’d recently met at the NOPE Show (a great showcase for free-from, incidentally), answered generously.
She told me: “The Vegan Society does not claim trademarked products are suitable for people with allergies e.g. dairy. That will depend on the standards achieved by individual manufacturers”.
She said a statement has been added to the Trademark licence agreement to encourage manufacturers to commit to avoiding cross-contamination. It reads: ‘I confirm our company strives diligently to minimise cross-contamination from animal substances used in other (non-vegan) products as far as is reasonably practicable.’
Sam added: “We accept some trademarked products may carry warning labels such as ‘may contain milk’ because this refers to accidental low-level cross-contamination … Low levels of dairy contamination are likely if a vegan chocolate is manufactured after a milk chocolate.”
Although vegan production areas would potentially resolve low levels of cross-contamination, detection limits mean zero parts per million cannot yet be proven. For instance, the limit is 3-5ppm for gluten and 70ppm for lactose (lactose being a far smaller molecule than gliadin). So zero cross-contamination can’t be demonstrated, and in the absence of a threshold level as we have with gluten, the term ‘dairy free’ is not yet clearly defined.
The Vegan Society’s definition of veganism is here. In allergy terms, there are I guess parallels to NGCI (no gluten containing ingredients) messaging – but it’s not equivalent to dairy-free and/or egg-free, as they confirmed some days later.
May Contain Fish?
Fish / shellfish are also allergens. Could a product be VS-registered and yet bear the term ‘may contain traces of fish’?
I expected a no, but was surprised to be told yes, theoretically – although Sam confirmed no such products are trademarked. She pointed out that: “Accidental contamination from animal substances is likely in many situations … insect remains may occur in fruit, vegetables, flour, spices …”
I write for Vegetarian Living magazine, and their policy is stricter: anything with ‘may contain traces of fish’ would be excluded from its pages. And such products are out there. See here and here for examples posted on Twitter, and I seem to remember seeing the warning on The Bay Tree products. Plamil’s views on dairy, shared on Twitter, are below – and I would fear to ask them their thoughts on ‘may contain fish’.
Anyway, I respect the Vegan Society, and I don’t think any less of them for their pragmatism. Vegans live in a non-vegan world and are exposed to animal compounds in the context of everyday living – sharing a home with non-vegans, say. Similarly, coeliacs live in a gluten-y world and are exposed to gluten – in the atmosphere at a supermarket where baking takes place, say.
As Sam argues, it’s about choice: some vegans cook animal foods for others, some won’t; some find ‘may contain dairy’ acceptable, others don’t; most shop at meat-trading supermarkets, a minority won’t.
She says: “Veganism is about attempting to live a certain way. It seeks to exclude certain products. Sadly this isn’t always possible.”
And removing all trace of any allergen isn’t always possible – or measurable – either.
Can we separate ‘vegan’ from ‘free from’?
In a sense, while there are certain ‘minimum standards’, beyond them, there appears to be a spectrum of veganism; and it is not necessarily as strict as I’d assumed. Some have suggested, I think partly because of this, that allergy and free-from should be kept somehow separate from vegetarianism and veganism, despite clear overlap.
I recall a previous blog inspired by @lykarar, who had stated that vegan food doesn’t belong in the ‘free from’ aisle. At the time I disagreed, but all this has given me cause to rethink.
There is, too, a spectrum of food sensitivity severity, though. For some, ‘traces’ are a no-go, but for those with lactose intolerance or non-coeliac gluten sensitivity, traces may be shrug-worthy. A few vegans are as strict as many of those with food allergies need to be – but some clearly are not.
Further, some companies clearly see themselves as both ‘free from’ and vegan – I cite Plamil, again, who operate a nuts-free environment.
And what about Alpro? They started as an ethical company producing for vegans and vegetarians. That its products turned out to be suitable for many people with food allergy was a bonus. The uproar, more recently eclipsed by the Tesco brouhaha, against Alpro’s ‘may contain nut’ labelling, was essentially a protest against Alpro’s apparent disregard for the ‘free from’ community members it had amassed as customers.
And for me, this case is the clincher. I don’t think one can logically rationalise holding a view that veganism and ‘free from’ should be kept apart and yet also criticise Alpro for turning their back on the very free-frommers who effectively drew them into the allergy community in the first place. We can’t be selective on when veganism can and can’t sit with or within ‘free from’: surely veganism is a version of ‘free from’.
Instead, we need to advocate the clearly necessary message that vegan does not necessarily imply ‘egg/dairy free’ and, besides that, generally stick together.
* Huge thanks to Sam and the team at the Vegan Society. Check out their new Love Vegan campaign here.
* Since drafting this post, free-from blogger Sarah of Sugarpuffish has shared her thoughts on this subject too.
Brands which are both Vegan AND Dairy Free
Coyo – coconut-based yogurts (UK)
Goody Good Stuff – confectionary (UK & US)
Moo Free – chocolate products for children (UK & US)
Orgran – baking mixes, pastas, crackers, flours, sweet products (worldwide)
Plamil – chocolate products and egg-free mayonnaises (UK & US)
You may find some other brands in this article – Allergen Free Food – although note that some brands listed here, while avoiding eggs and milk, may use other animal products such as honey.