September 2015

Definitions of “vegan” and “vegetarian”

in accordance with the EU Food Information Regulation

A. Need for reliable labelling

Societal and market development

The number of vegans, vegetarians and people who turn to more plant-based lifestyles is
steadily increasing. While there are currently no EU-wide data on nutritional behaviour, national
inquiries do give a good indication of trends. In Germany, for instance, there are roughly
7.8 million vegetarians (around 10 per cent of the population) and 900,000 vegans (1.1 per cent)
(IfD, YouGov). The number of vegetarians in Germany has more than doubled since 2006.
Furthermore, there is an even larger number of people who are making the conscious decision
to eat little meat or who would like to reduce their meat consumption.

The market for vegetarian and vegan products is developing accordingly. These are growing out
of their niches and are no longer being offered solely in health and wholefood shops. An
assortment of meat- and animal product-free foods can now be found in every discount
supermarket.

Vegetarian and vegan products are recording notable increases in turnover:

+ 51 per cent per year 2011-2013: alternatives to dairy, UK (Mintel)
+ 43 per cent in 2014: soy yogurt, Germany (GfK)
+ 36 per cent in 2014: vegetarian semi-ready meals, Germany (IRI)
+ 20 per cent in 2014: Alpro (alternatives to dairy), Europe-wide (Alpro)

The gastronomy sector is also increasingly catering to the demand for vegan and vegetarian
offers. Currently, there are about 122 vegan- and 296 vegetarian-only restaurants in Germany.
This represents respective increases of 38 and 63 per cent since 2013.

Uncertainty for producers and consumers

Food producers, food trading companies and caterers have recognised the signs of the times and
are increasingly bringing to the market vegetarian and vegan products that are directly
recognisable as such for the consumer. For instance, commercial chains have begun to label
own-brand products, in some cases with self-developed logos (Fig. 1).
2/4

In principle, the labelling of vegetarian

and vegan products by manufacturers
and traders is to be welcomed very
much, as it accommodates the
increasing demand and facilitates
instant and informed decision-making
by consumers. It is unclear, however,
what precisely the terms “vegan” and
“vegetarian” stand for. At neither the
national nor European levels do legal
definitions for the food sector exist.
This leads to confusion on the part of Fig. 1 Examples of the labelling of products as vegan and vegetarian
producers and traders as well as on
the part of consumers. The EVU member organisations notice this uncertainty in the form of
sharp increases in consultations. Companies would like to offer vegan and vegetarian products
but do not know how foods are to be designed so that they can be labelled accordingly.

For the example labels depicted in Figure 1, the trading companies had to develop their own
criteria for vegan and vegetarian products. These can, however, differ from company to
company. If they want to play it safe, consumers have to obtain information from the respective
producer or trader.

Clarity by means of V-label

Directly visible and reliable clarity is currently offered only by the

V-label of the EVU (Fig. 2), which labels both vegan and vegetarian
products. Its criteria are accepted by international vegan and
vegetarian organisations.

The increasing dissemination of the V-label testifies both to the trust

consumers put in it and to the advantages that traders and producers
gain from its deployment.

More than 400 firms in Europe currently use the V label on thousands
of products. Notable licensing partners include Aldi, Alpro, Coop,
FrieslandCampina, Griesson de Beukelaer, Migros, Spar and Unilever. Fig. 2 V-label, variant for
vegan products

B. Legal and political situation

The absence of legally binding definitions of the terms “vegan” and “vegetarian” in food labelling
has also been identified as a problem by the European legislator. Thus, the EU Food Information
Regulation stipulated that the European Commission is to issue an implementing act defining
requirements for “information related to suitability of a food for vegetarians or vegans”
(Article 36(3)(b) Regulation (EU) No 1169/2011). This signifies an obligation to decree a legal
3/4

definition of the terms “vegan” and “vegetarian” for the labelling of foods. Unfortunately, the
Commission has failed to act upon this responsibility in the past four years and seems unlikely to
meet its obligation of its own accord any time soon.

There is also an interest in the timely adoption of a legally binding definition on the parts of
consumer protection agencies and the food industry.

C. Legally binding definition

Requirements

The aim of a definition as seen from the perspective of the EVU is to enable informed and self-
determined decisions about consumption. The fundamental or situational choice in favour of
plant-based products needs to be made easier for consumers.

To achieve this goal, a definition must steer a middle course. On the one hand, it must be
(a) sufficiently narrow so that the terms “vegan” and “vegetarian” guide interested consumers
in their expectations. On the other hand, it must be (b) sufficiently pragmatic and realistic so
that the range of products to be labelled “vegan” and “vegetarian” is not unnecessarily restricted,
which would artificially complicate plant-based lifestyles.

These considerations lead to the following concrete requirements:

a) The deliberate use of non-vegan or non-vegetarian substances must be ruled out. This
applies to all substances, independent of the amount used, and also to all of their
preliminary stages and components. The presence or effect in the final product is not
decisive, meaning that, for example, processing aids have to be covered by the definition as
well.

Fruit juice clarified with gelatine or bread produced with flour that has been treated with
animal-based cysteine thus cannot be considered vegetarian. The background of this
demand is that, while there are various motivations for plant-based lifestyles (health,
ecology, etc.), the ethical aspect according to which animals are not to be killed or exploited
is prevalent. Since animal substances that are deliberately utilised are produced and
acquired specifically for this purpose, the consumer would, through their purchase,
contribute to the exploitation of animals. This poses an ethical problem from the vegan-
vegetarian perspective.

b) The (potential) presence of inadvertent traces of non-vegan or non-vegetarian substances

should not be an obstacle to labelling a product as vegan or vegetarian, provided that such
contamination takes place despite a careful production process that complies with best
practices and the state of the art.

The joint production of vegetarian and non-vegetarian foods in a production facility and
4/4

with the same machines should be possible as long as reasonable measures are taken to
prevent contamination. The purchase of vegan or vegetarian foods that have been
contaminated with animal substances does not contribute to the increased use of animals.
Therefore, impurities do not pose an ethical problem from the vegan-vegetarian
perspective. The current regulations about allergen labelling ensure that those affected can
inform themselves about this aspect of a food.

These requirements are supported by the EVU and its member organisations from all over
Europe. What’s more, producers and traders of vegan and vegetarian products comply with the
principles set out. Last but not least, they meet the practical requirements of vegans, vegetarians
and the many people who eat an increasingly plant-based diet. This is ultimately decisive, as
according to the European Food Information Regulation, the “suitability of a food for vegetarians
or vegans” is at stake – and who could judge this better than they themselves?

Proposed definition as a basis for discussion

The following definition is based on a proposal from the political sphere. The EVU has inserted
some amendments. The EVU sees the requirements depicted above as implemented in this
formulation but is open for discussion about the wording.

(1) vegetarian
Foods that are not products of animal origin, and in the manufacture, preparation, or
treatment of which no ingredients (including additives, carriers, flavourings, enzymes and
substances that are not additives but used in the same way and with the same purpose as
processing aids) or processing aids of animal origin (processed or unprocessed) have been
added or used intentionally, with the exception of milk, colostrum, birds’ eggs, beeswax,
honey and propolis, their constituents and products derived from them.

(2) vegan
Foods that are not products of animal origin, and in the manufacture, preparation, or
treatment of which no ingredients (including additives, carriers, flavourings, enzymes and
substances that are not additives but used in the same way and with the same purpose as
processing aids) or processing aids of animal origin (processed or unprocessed) have been
added or used intentionally.

(3) In the manufacture, preparation, treatment or placing on the market of foods that are
labelled as vegetarian or vegan, appropriate precautions must be taken, to avoid cross-
contamination with products that do not comply with the requirements of paragraphs 1
and 2. However, the presence of these cross-contaminations shall be allowed in foods that
are labelled as vegetarian or vegan, provided that despite appropriate precautions such
presence is technically unavoidable under good hygiene practice.

(4) If indications or symbols are used on foods that are likely to have the same meaning for
the consumer as vegetarian or vegan, paragraphs 1 to 3 shall apply accordingly.