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Vegan products

Plant-based product surge: manufacturing requirements and pitfalls

The surging consumer interest in vegan and vegetarian products presents many challenges for the food industry, especially in manufacturing practices. Here are some excellent guidelines and advice from FACTS SA, the Food, Allergy Consulting & Testing Services consultancy in Stellenbosch.

The addition of animal materials to foodstuff (whether deliberate or unintentional) can lead to two major problems for producers of plant-based products: the presence of undeclared animal species; and more specifically, foodstuff claimed to be suitable for vegetarians containing containing animal substances.

To address these problems as separate entities and mitigate the different risks involved, it is necessary to take a step back and gain perspective on how everything fits together.


The increase in consumer interest in vegetarian/vegan products is expected to grow steadily in the foreseeable future – it’s clear that this is not a temporary fad and is becoming a widely accepted part of mainstream lifestyles.

The increased demand and and production of vegan products presents many challenges in manufacturing practices. The current list of food safety and quality requirements already seems endless. Adding another layer of control to this complicated and demanding mix might seem like a recipe for disaster, especially in the absence of proper regulatory guidance.

RECAP: Species control and the presence of undeclared species

Species control includes the identification and control of animal substances, to prevent the presence of undeclared animal species in foodstuff at every stage of the manufacturing process, from harvesting through to packaging and retailing.

There has been heightened food-industry awareness around meat species since the horsemeat scandal of 2013, in which foods advertised as containing beef were found to contain undeclared or improperly declared horse meat.

The addition of undeclared meat species to food and meat products is not an uncommon phenomenon. In South Africa in recent years, multiple incidences of species substitution and mislabelling of meat and fish products have been recorded. These occurrences not only constitute consumer fraud, violate religious faiths and raise ethical concerns, but can result in food safety risks. They may be deliberate or unintentional.

Intentional presence of undeclared species

Due to their high cost, food products such as meat are highly prone to substitution or adulteration, and such practices are often relatively simple to get away with. The flesh of many meat species differs only subtly in appearance and texture, making it difficult to identify the species used by visual inspection only.

Another type of substitution of meat ingredients involves the use of cheaper ingredients from the same declared species, but from different body parts (typically offal, connective tissue or blood); or the substitutes may be non-meat ingredients (eg from plant or dairy sources). The fisheries and aquaculture sector is also considered particularly vulnerable to food fraud.

As a result of the rising number of incidences of food fraud, VACCP (vulnerability assessment and critical control points) and TACCP (threat assessment and critical control points) -based risk assessments of food ingredients have become GFSI requirements (FSSC 22000 and BRC Standards), in addition to HACCP (hazard analysis critical control points).

Unintentional presence of undeclared species

The unintentional addition or substitution of species may be due to a lack of expertise, management and/or control. A significant concern is the potential for meat products to be contaminated by undeclared species during processing. Cross-contamination can arise when poorly cleaned equipment or utensils are used for processing meat from two or more different meat species.

To date, South Africa has not set any threshold levels for undeclared species. The UK’s Food Standards Authority (FSA) and Department for Environment, Food & Rural Affairs (DAFRA) recommend that a threshold level of 0.1% undeclared meat species be set for comminuted (processed) meat; this would indicate an absence of carry-over, and that good manufacturing practices were followed.

Studies have shown that a proper cleaning regime is the key to mitigating cross-contamination, and that deep cleaning can be effective in preventing the carry-over of meat species.
For more information on meat species in terms of regulatory requirements and analysis, please view our news item on Meat Species – Regulations and Analysis.

The problem at hand: Plant-based products & the addition of animal substances

A further serious concern is the potential for plant-based foodstuffs suitable for vegans and vegetarians to contain animal substances.
The vegetarian and vegan lifestyle focuses primarily on the impact of the cultivation and production of food, and aims to exclude all forms of cruelty to and exploitation of animals, as far as possible.
With the current shift towards plant-based diets, there has been notable consumer (and consequently, food industry) attentiveness towards vegan-related food products. This has brought to light potential gaps in the industry’s understanding of the requirements for this type of product, especially in terms of processing and labelling.

Products labelled and marketed as suitable for vegans and vegetarians have been found to contain traces of animal substances, originating from shared production lines and equipment during the manufacturing process or a contaminated product in the supply chain.
Similarly to meat products, vegan and vegetarian products are also subject to adulteration, and may therefore contain deliberately added undeclared animal derivatives or ingredients.

Regulatory stipulations

Directly applicable regulations:

The Regulations Relating to the Labelling and Advertising of Foodstuffs (R.146/2010, as amended) state the following:


‘Vegetarian’ means a diet which (i) consists of ingredients of multi-cellular plant, fungal, algal and bacterial origin; (ii) may include honey, dairy foods produced without any slaughter by-products, and/or unfertilised eggs obtained from live animals; and (iii) excludes all animal flesh and products obtained from the slaughter of an animal, such as gelatine, animal fats, caviar and roe.
‘Strict vegetarian diet’ means a diet which excludes all ingredients and additives derived from animal origin, and the expression ‘vegan diet’ has the same meaning.


Vegetarian claims:
48. (1) Claims that a foodstuff is suitable for vegetarians shall specify the category of vegetarian by adding one or a combination of the following prefixes to the word ‘vegetarian’:
(a) ‘Lacto (milk)’ – means milk and milk products are included, but products in which animal rennet is used during preparation are excluded.
(b) ‘Ovo (egg)’ – means unfertilised eggs (preferably free-range) and egg products are included.
(c) ‘Honey’ – means honey is included.
(d) ‘Strict vegetarian’ or ‘vegan’ means ingredients of multicellular plant, fungal, algal and bacterial origin are included, but all ingredients and additives derived from animal origin are excluded.
(2) When a foodstuff is manufactured for the ‘strict vegetarian’ or ‘vegan’ market and a claim in respect of ‘strict vegetarian’ or ‘vegan’ is made on the label, and it is not possible to conclude from the name of the ingredient or additive that they are derived from non-vegetarian origin, any additive (refer to Annexure 1) or ingredient (refer to Guideline 9) derived from non-vegetarian origin which is added to the foodstuff shall be declared as ‘non-vegetarian origin’ or in words that specify the source in parenthesis after the name of the additive or ingredient.

Indirectly applicable regulations:

The Foodstuffs, Cosmetics and Disinfectants Act (Act No. 54 of 1972) prohibits the sale, manufacture or import for sale of any foodstuff which contains or has been treated with a substance not present in any such foodstuff when it is in a normal, pure and sound condition; or to which any substance has been added so as to increase the mass or volume of such foodstuff with the object to deceive.

The Consumer Protection Act (Act 68 of 2008) (CPA) was enacted (among other reasons) to protect consumers from hazards to their well-being and safety, and to set out consumers’ rights to safe, good-quality goods. The CPA also prohibits direct or indirect marketing to the consumer of goods if the marketing implies a false, misleading or deceptive misrepresentation concerning a material fact.

Regulatory exclusions and pitfalls

The current R.146 labelling regulations, and the guideline accompanying the regulations, do not address potential cross-contamination from non-vegetarian products to vegetarian products, animal material processing aids, management or controls of manufacturing processes, and most importantly, allergen precautionary labelling on vegetarian products.

A comprehensive regulatory framework results in a situation in which the supply chain comprehends that it must comply; and consumers can then trust the products provided.
The current lack of criteria for the use of vegetarian-related terms in food labelling and manufacturing may result in complications, including – but not limited to – the following….

FACTS SA: Read the full article here

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