What is important to look at?
1 - The claim itself
Does the name of the claim contain an ingredient that can result in a food allergy or a food intolerance such as milk products or gluten?
If yes, then the claim is strictly regulated by EU law.
2 - The “may contain” statement
Have you ever noticed on packs: “may contain milk”? The ‘may contain’ labeling is used for products that do not have milk as an ingredient but are for example made on lines that also share milk-containing ingredients. It results in unavoidable and involuntary presence of milk allergens due to cross-contact. Despite measures taken, this hazard cannot be prevented, especially not with chocolate where typical wet cleaning regimes are not possible. Barry Callebaut therefore, where needed, labels a precautionary allergen declaration like ‘may contain milk’. Products with a may contain labeling should not be consumed by allergic persons
2 - Vegan
Vegan is not regulated however points to a product made without animal ingredients and without the use of living animals or animal-derived products. Vegan products might have been manufactured in an environment where dairy is also used, vegan products can therefore still have a “may contain” labeling when there is an allergen that can occur through cross-contact in the production environment. Hence they are not safe for dairy allergy sufferers.
As there is no legal framework for the vegan claim food manufacturers have 2 options:
- design their own vegan logo to communicate about their product being vegan
- have their products certified by one of the 17 international vegan labels (http://vegan-labels.info/). Products are certified on the condition that all requirements of the label are fulfilled. It might include a maximum dairy cross-contamination, for example EVU requires maximum 1g dairy /kg of end product
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