“Free-from” labels are explicitly concerned with food allergens. They indicate that a product has undergone rigorous controls to ensure an entirely allergen-free environment. To use a “free-from” label, a food business must undergo strict protocols that far surpass regular food safety measures.

Meanwhile, a “vegan” label serves a different purpose. In 1949, Leslie J Cross – founding member of the Vegan Society – proposed the first definition of veganism: “The principle of the emancipation of animals from exploitation by man”. From its inception, veganism has been more than a diet. It is a philosophy, and its cornerstone is eliminating animal exploitation, in any form that may take.

The Vegan Society’s current definition clarifies this further: 

“Veganism is a philosophy and way of living which seeks to exclude — as far as is possible and practicable — all forms of exploitation of, and cruelty to, animals for food, clothing or any other purpose; and by extension, promotes the development and use of animal-free alternatives for the benefit of animals, humans and the environment. In dietary terms it denotes the practice of dispensing with all products derived wholly or partly from animals.”

With this definition in mind, it is clear that veganism seeks to avoid any practices of animal exploitation. A large component of this is diet. Purchasing animal products contributes to their demand, thereby feeding a system of animal exploitation. However, buying a food that contains a trace of animal products through cross-contamination does not contribute to animal product demand. Therefore, generally, vegans still consider this food to be vegan. 

This is why an otherwise vegan product may have a Precautionary Allergen Label (PAL) – that line below the ingredients list that warns consumers it “may contain [milk/egg/etc]”. A PAL indicates that, while a given ingredient is not part of a product’s recipe, an absolute absence of the ingredient is not guaranteed. The product could still contain trace amounts of the ingredient due to cross-contamination somewhere in the production process. 

“Free-from” labels should not be confused with “vegan” ones. Natasha Smith, Deputy Director of Policy at the FSA, said as much in 2023 when the FSA published new guidance for food businesses on the use of PAL. Smith noted that the updated guidance clarifies “the distinction between a ‘vegan’ claim, and a ‘free-from’ claim. A ‘free-from’ allergen claim should guarantee that the specified allergen is absent…  A vegan claim is not about food safety, and our new guidance highlights that a PAL statement… can be used to communicate a risk of [an allergen’s] unintended presence”. So, a vegan label and a PAL can coexist on a single product; a product can be vegan and still contain unintentional trace amounts of milk, egg, or other animal products. It is up to the consumer to take note of the difference. 

This leads us to our key question: for the sake of simplicity and food safety, should a vegan label also guarantee an allergen-free product? 

“Vegan” and “free-from” labels have entirely different purposes. Allergen labels already exist, and placing new demands on vegan products is unnecessary and costly. Meeting a strict allergen standard is expensive. It involves “specific and rigorous controls” designed to ensure that the final product is free from any trace of allergens, including setting up specific allergen-free production and preparation areas, and ensuring that all ingredients and even packaging are free from potential cross-contamination. It is incredibly important that this strict allergen-free standard exists and is respected – but this is entirely different from the purpose of a vegan label.

And the economic strain this would put on vegan businesses cannot be dismissed. For instance, the cost to test a single batch of one food product with Eurofins, a UKAS-accredited laboratory, to undergo animal product allergen testing amounts to £360. For a small food business with only 5 products on the market, laboratory allergen testing would cost £1,800 per batch tested. Assuming a procedure with monthly testing, annual laboratory costs would amount to nearly £22,000. For larger companies that produce dozens of products, costs skyrocket to well over £100,000.

However, these costs only scratch the surface of what a food business would have to invest. For example, they may need to replace equipment, modify their facilities, or implement entirely new production lines – an investment of tens or hundreds of thousands of pounds. Consider that segregation barriers alone (screens used to divide production lines for allergen/hygiene purposes) cost upwards of £700 each.

Additionally, once “free-from” standards have been met, food businesses must update their packaging to include allergen-free claims and meet regulatory requirements. Even assuming only minor changes, redesign and reprinting would cost tens, if not hundreds, of thousands. Food businesses would also have to consider legal and consultancy fees, as they must ensure airtight compliance with food safety and labelling regulations.

Moreover, the substantial costs required for food businesses to adopt allergen-free production standards will likely result in far less vegan food on the market. Businesses will simply be unable to afford the cost of producing vegan foods under added regulations. Notably, these financial barriers would fall disproportionately hard on small innovative companies. And, as less vegan food reaches the shelves, consumer choice dwindles. This scenario is especially concerning when we consider that consumers should be nudged toward vegan options to mitigate the climate crisis – an effort made all the more difficult when vegan options are limited. 

Allergen-safety falls outside the realm of veganism, which is concerned with reducing demand for animal products and all forms of animal exploitation. Put simply, potential cross-contamination with an animal product does not increase demand for that animal product. Moreover, requiring vegan products to abide by strict allergen certifications would be extremely costly – if implemented, some vegan products may never have a chance to reach the supermarket at all. In effect, this type of regulation could stymie innovation in the UK plant-based food sector.

It is extremely important that allergen-safe labels exist and are adhered to. The importance of allergen labels which mean “100% guaranteed free from any trace of [milk/egg/etc]” must be kept paramount, and these must not be confused with vegan labels – by either producers or consumers.

Vegan labels, such as the Vegan Society’s Vegan Trademark, have an important and distinct role, clearly communicating that “this product was not necessarily made to strict allergen-free standards, but its recipe is free from any animal product ingredients”.