Name: Achim Stößer Permalink: https://tierrechtsforen.de/6/2238/2279
Datum: 23.12.08 00:18
The Vegan Trademark
Plamil and the Vegan Society Trademark, September 2008
Plamil was the first company to proudly label products with the Vegan Trademark. The Trademark has historically been the flagship symbol for vegans, indicating a product has been made to vegan standards ‘as far as is reasonably practicable’.
In the Vegan Society’s Autumn 2008 magazine, the Society printed its new ‘Animal Free Trademark criteria’, which explains the Society’s new criteria for using the Vegan Trademark Logo.
The Vegan Society’s new criteria now allows ‘may contain milk/eggs/fish’ statement to be used alongside the Vegan Trademark!
One vegan has written to us “I thought the logo was for the benefit of the vegan consumer so that we could confidently buy and consume/use a product displaying the logo without having to read the preamble of ingredients and disclosure statements”. Well apparently that is no longer the situation.
We at Plamil think that the Vegan Society’s new criteria must change and are campaigning to get the Vegan Society to revert to the historical vegan definition ‘as far as is reasonably practicable’.
The Vegan Society has missed an ideal opportunity to incorporate the European labelling laws (2000/13/EC and 2006/142/EC) and then amend the regulation’s 14 allergenic ingredients, which includes milk/eggs/fish to all animal ingredients. In doing so the Vegan Trademark would have remained the vegan flagship and continued to adhere to Society’s own stated aims ‘as far as is reasonably practicable’.
Other societies (which promote requirements for allergy sufferers, such as the Anaphylaxis Campaign) do publish and set higher standards of ingredient segregation in their criteria to explain EC regulations.
By not using either EC regulations or FSA guidance the Vegan Society are now openly accepting ‘contaminated’ food and sadly the VS Trademark will no longer mean what most vegans think it means. Those with allergies now enjoy greater assurance from ‘allergy information’ on labels than the Vegan Trademark will give vegans.
The Vegan Society’s Trademark criteria highlights the issues that surround chocolate production. Vegans can be assured that Plamil will never ‘water down’ our vegan standards and we will always manufacture our chocolate to the highest standards possible at our own vegan factory, where there is ‘zero cross contamination from animal ingredients’. It is commonly known that chocolate that is not made entirely on dedicated production lines can be contaminated to such an extent with ingredients such as milk that ‘it should almost be listed as an ingredient’ said one expert.
The Vegan Trademark Questions & Answers
What to know more about the issue?
Whilst agreeing in principle with us about the Vegan Society Trademark, some people suggested we explain some issues a little more, so here we try to do our best to give information in a question/answer format.
1. Has the Vegan Society changed the Trademark criteria?
All societies from time to time need to amend and update the criteria with which any Trademarks work to. This is usually in line with government regulatory laws, or after widespread consultation from many different interested parties and experts. Criteria to use the VS Trademark was published in the Autumn '08 issue of the Vegan magazine, and is different from previous criteria set by the Vegan Society, and does not incorporate either FSA guidelines or EC regulations.
2. If a product has the Vegan Society (VS) Trademark, whose responsibility is it that the information on the label is correct, the Vegan Society or the producer/manufacturer?
3. The Vegan Society indicates that they will now accept statements such as 'May contain traces of milk...' and indicate that it's purely because of machinery and the risk of very low (trace) accidental level of contamination. What's wrong with that?
A. This is a misunderstanding of the provision of the use of the term 'may contain'. This 'may contain' statement means different things to different people, but it is only the use within the EC regulations that is considered by producer/manufacturers.
B. Producer/manufacturers undertake very complex assessments of their individual products, which can include amongst other things ingredient assessment, manufacturing methods and cleaning processes, testing and inspections and other criteria. These can be quite detailed, depending on the different situations.
C. The EC Regulations are about the presence of (listed in the Regulations) ingredients for whatever reason, that are not in the ingredients declaration, but may have allergenic effect on the consumer. The frequency of presence can range from the possibility, to sporadic, to continuous.
4. When would a producer/manufacturer's product label need to carry other information apart from the ingredient listing, such as the 'may contain' information?
A. After the process of assessment, if the producer can satisfy themselves that there is no chance of a presence of an EC listed ingredient, they have done 'as far as reasonably practicable' and they do not need to give more information.
B. After this process of assessment, if the producer cannot satisfy themselves that there is no chance of milk/eggs/fish presence, they need to provide this information to the consumer, usually in the format of 'may contain' information.
5. The VS do say 'as far as reasonably practicable' so isn't that enough?
A. The VS self-declaration states 'minimise as far as reasonably practicable' which has almost, but not the same, meaning. Using the word minimise actually 'waters down' the 'as far as reasonably practicable'.
B. Producers/manufacturers therefore, in assessing if they can label products with the VS Trademark, do not need to make products 'as far as reasonably practicable', and can conclude that even though their own EC regulation assessment triggers a 'may contain' declaration, they can still use the VS Trademark.
6. Is this just about theoretical small amounts of ingredients that cannot be detected?
No. It is true that detection levels on testing are becoming lower for some ingredients but it is about the manufacturers deciding on the presence of those ingredients using a whole variety of assessment methods. This may be, but not necessarily, a more stringent assessment when considering nut traces, due to those that could suffer Anaphylactic shock from nuts, to a less stringent assessment for milk, as some may assess the possibility of severe reaction to milk as less. (Note: that to those that suffer from milk allergy the risk and effect is still high.) Whilst low detection test levels are useful in assessments it would not be uncommon for producers /manufacturers to be considering much higher levels, even % levels, in their assessments.
7. What's wrong with a VS Trademark where the criteria only deals with deliberately added ingredients?
A. Whilst this maybe acceptable to a few vegans, it does not deal with the presence of ingredients as EC Regulations do. To deliberately ignore known presence is both wrong to vegans and not 'as far as reasonably practicable'.
B. If the VS Trademark accepts that only deliberate ingredients should be considered in the criteria, then a situation will occur that levels of presence accepted by the VS Trademark that trigger the 'may contain' declaration of milk/eggs/fish ingredients could actually be higher than 'normal inclusion or use' of listed VS non vegan ingredients and processing aids. This is illogical. We are sure that vegans would not wish the same situation to happen as has happened with genetically modified ingredients where a level of 0.9% has been set to be the level at which is acceptable to be considered 'non-gmo'.
8. Surely the Vegan Society do some kind of checking of Trademark users with qualified inspectors?
The VS Trademark is a self-declaring documentation with the Vegan Society. It is essential therefore that criteria and guidelines are clear and precise, and it would be advantageous to all if regulatory standards were used.
9. Some products that were once described as suitable for vegans, are no longer. Why is that?
Some producers have, after assessing their products, concluded that additional information is required, for example 'may contain milk'. In a few circumstances milk has actually been added to the ingredient list, as its presence has been felt to be so significant. (Even though the producer is using exactly the same ingredients, formulation and processes as before, when the product was considered suitable for vegans.)
10. The issue is about milk, eggs and fish. What about other animal ingredients?
Basically EC regulations only require allergenic ingredients (including milk/fish/eggs) to be declared. However the regulations set the criteria and specify stated ingredients. The Vegan Society has missed to opportunity to use the criteria of the regulations - which producers/manufacturers already work to - and add a list of animal products and have manufacturers declare that they will work 'as far as reasonably practicable' to those criteria.
11. What's the difference now between the term vegan and the VS Trademark?
A. In product labelling terms the actual description 'vegan' is not allowed to be used alongside a 'may contain milk/eggs/fish' statement by UK Trading Standard officers, who follow FSA guidelines, because they expect manufacturers to undertake 'as far as reasonably practicable'.
B. The VS Trademark, in allowing a 'may contain' declaration, is therefore setting a lower standard than 'as far as reasonably practicable'.
C. Companies can label their products 'suitable for vegans' without using the VS Trademark, but must comply with FSA/Trading Standard guidelines.
12. Why has Plamil highlighted this situation?
We are proud of the VS symbol. We have taken this unusual step in publicising the situation, as we know the Trademark stands as a mark of trust to vegans. To allow that trust to erode over the coming years is bad for all vegans and ultimately the Trademark. Now is the time to ask the Vegan Society to revisit the issue.
13. What should happen now?
A. To some there are different levels of veganism, which we should all respect and encourage any move to veganism. However, we think the VS Trademark should represent the highest achievable standards in a clear, concise and logical manner, for consumers and producers/manufacturers to follow.
B. It is entirely a matter for the Vegan Society, and we will not comment on internal politics of the society. However, from the responses we have received the position is quite clear. The vast majority of vegans believe that the VS Trademark should never be allowed to be used with the 'may contain milk/eggs/fish' label information.
C. You can now register your wish by signing the Plamil petition.
We hope that the issue is resolved as soon as possible and that all vegans can move forward in promoting the vegan way. We would like to continue to hear what people think on this issue, but apologise that we cannot answer all your emails.