The Food Standards Agency, prompted mainly by the food and drinks industry, seeks to categorize sectors in the now diverse and spreading market. From a niche into a rut and now back into a dendritic mesh of more niches; or an enterprising, stimulating, and innovative injection into a costive food industry. We talk standards, science, and consumerism with the FSA, from which the veggie-style needs more appreciation.
re: Public Written Consultation Draft Guidance on the Use of the Terms ‘Vegetarian’ and ‘Vegan’ in Food Labelling
We trace our pedigree to the founding of the Vegetarian Nutrition Council (VNRC) at the end of WW2 through the launch and editing of Plant Foods for Human Nutrition, a scientific journal, a few years later. We launched in 1976 a Green Plan for farming, food, health and the land, accompanied and exemplified by a Campaign for Real Bread. We can claim success in these initiatives and the sequels, in some of which we are still heavily involved. True to our Trust Deed we aim at an educative exposition of vegetarian ideals to the general public, as well as to established vegetarians. Labelling and standards are important in these endeavours. We provided advice to the defendants in the McLibel case and acted as expert witnesses. In the adjudication the judge stated that we had brought forward evidence powerful enough to condemn McDonalds as guilty of “culpable cruelty to animals”.
We are a registered charitable Trust, independent of any commercial involvements (such as leasing logos, sales of symbols, approvals, and approbation; we lack the resources to monitor and police any such agents and we descry no enthusiasm for such duties in the FSA. We think it should be more active in this regard).
1. The words vegetarian, vegan, vegetalian, fruitarian, and even freegan are used loosely at present in common parlance. They do not promise the customer the pleasure of, say, “going Indian”, or even as an advertisement in a recent vegetarian magazine claimed, “pure Indian vegetarian”. Single words are inadequate, like the unmodified word Christian, to describe the broad church in the vegetarian purview. An expression of modern scientifically-based vegetarianism would run something like this:
A vegetarian strives to avoid any exploitation of animals in the production of food, drink, or feed stuffs or for any purpose (e.g. for household goods, clothing, footwear, recreation, pharmaceuticals, supplements, toiletries, and cosmetics, and requisites for the purposes of gardening and allotments). Respect for wildlife and the environment and for the use of natural resources and for the dignity of human labor is implicit in such expressions of kindness and companionship and freedom from cruelty. The quest for the common good for inoffensive alternatives must be fostered appropriately.
2. Caution should be taken in vegetarian-style labelling and claims to avoid clashes when words such as suitable for vegetarians appear near health warnings and criticisms. We have examples of claims, approbations, symbols, and listings on products such as veggieburgers and black chocolate that carry adjacent warnings that they contain milk; or they attract contempt from reviews in the press or consumer magazines. Products made in dedicated or uncontaminated factories avoid these difficulties. We have found truly vegetarian Marmite sold in Jewish areas, while the “approved” Marmite was being manufactured in factories also making beef-extracts. Jews and vegetarians share many interests and facilities in the service industries. The word parve is a useful guide in this context for dairy-free. However, kosher (and halal) meats are especially offensive to vegetarians: they have invited calls from the FAWC for banning. It follows that meat, dairy-products, and eggs should be rigorously labelled, as the FAWC has requested, with information for potential vegetarians – or backsliders.
3. Restoring the unequivocal definition of vegetarianism obviates the need for separations and neologisms with, if anything, a forbidding impression on the customer, and it creates barriers hampering enterprise and competition by manufacturers and retailers. Use of modern IT, labelling, and marketing, as Body Shop has done with beauty-without-cruelty cosmetics and toiletries, asserting a cruelty-free status, must be achieved in other markets. In our debates with manufacturers the trend to “free from” or “wheat free” styles seem popular, particularly in a discriminating population of meat reducers and dairy-frees edging in a well-informed way to cruelty-free food. Some definition of, say, cruelty-free would be required. in discussions with producers, retailers, and animal welfarists, and with health warnings on cigarets and the FSA’s threatened identification of “junk” foods in mind, we have mooted with little demur from the industry application of welfare warnings (“Production of these eggs entails cruelty to the birds”) or, in the manner of Meat Hygiene Service’s HAS scores and scoring of filth on animals on farms or presented for slaughter, grades based on the Farm Animals Welfare Council’s Five Freedoms.
4. Longstanding difficulties arise in shortcomings in general labelling that fail vegetarians and other interests (we note that vegetarians are a group who scrutinize labels with the greatest curiosity). Beverages such as beers, wines, spirits, fruit drinks, juices, and cordials etc. are still inadequately labelled and illustrate the omission of processing aids, such as finings, from descriptions on containers. Further, there are examples here where water is used in the process (as in brewing and for bakery products) or as a diluent (e.g. for fruit concentrates and, possibly, some beers). Some consumers, not necessarily vegetarian-minded, take a keen interest in fluoridation and the use of other halides. We urge the FSA to reinforce our efforts at achieving greater cooperation from manufacturers and retailers. Similar disclosures apply also in the use of disinfectants and their residues in foods and beverages and in animal-derived milks: use of iodine-containing washes and dips to clean the muck on cows’ teats must be monitored to ensure that consumers do not unwittingly receive excessive doses of this element. We would welcome help from the FSA to persuade manufacturers to clarify both the beverages and the consumers’ general interests. Unrefined and cloudy beers are now on sale widely and some brewers, e.g. Samuel Smiths, sell bottled beers fined with alginates derived from seaweeds (and therefore unexceptionable for vegetarians).
5. Further difficulties have been imposed on us by European requirements, favouring the dairy industry, on descriptions of dairy products on origin rather than form or purpose. We and a maker of vegetarian foods (Plamil) overcame MAFF’s objections by proving that terms such as peanut butter, and nut creams and milks were established commercial comestibles in the UK from before WW2. However, MAFF subsequently capitulated to the EU and the insistence that milk should be a single word to imply the mammary secretion in emulsion form of an animal (mainly a cow in commercial contexts) and be applied generically to the range of derivatives (however, peanut butter remained an exception) was applied. Trying to impose on a single short word such significance has been ridiculous: in nutritional and medical contexts the restricted meaning should surely apply to the most important food that is underused but at least has a defining adjunct: breast milk. Manufacturers have overcome some of these obstacles by resorting to brand names, well advertised (if they have the resources) for plant milks.
6. Vegetarian cheese is another bad description. Any self-respecting vegetarian cannot approve of any derivative of cow’s milk snatched from a probably colostrum-deficient frail calf particularly susceptible to disease and therefore likely to be heavily dosed with drugs and treated with vaccines. Is this a free-range cow or a zero-grazed herbivore? The Vegetarian Society’s approvals for vegetarian cheese pleased the supporters of GM, relieved manufacturers of enterprise in developing unexceptionable alternatives, and flouted animal welfarists’ reforms in the evil but heavily-subsidized live/deadstock industry and its tally of products, co-products, and by-products, which have needed all the value adding they can get. Vegetarian cheese and whey represent a great betrayal of animal welfare.
7. Serious observance of animal welfare also attends the use of colourings in foods for cosmetic purposes or for tinting to achieve uniformity of products (e.g. of spirits sold in plain glass bottles, cola and other drinks and beer and many foods and meals served in restaurants). While vegetarians have to regret the use of the animal experimentation on which nutrition and food technology depend, expression of the 3Rs (reproduction, refinement, and replacement) must be applied on items rated suitable for vegetarians, which means banning the use of these cosmetic ingredients. Some are coal tar derivatives and chemicalized caramels with other objection, of Sudan Red. Vegetarian researchers are also taking a hard look at the EU’s REACH initiative (Registration, Evaluation, and Authorization of Chemicals), which has a wide purview and involves experiments and test on animals in dubious assessments of human safety. If we had more opportunity for discussion, we could inform the FSA more fully on these matters in policies and authenticity of foodstuffs and other commodities suitable for well-informed vegetarians.
8. We take regard to responsible labelling of foods and supplements in the interests of consumers on restrictive diets in food and catering that is unsympathetic and unsupportive. Vegetarians are among groups such as diabetics, celiacs, and people with aversions due to allergies or religious observances. For vegetarians vigilance is needed over some B-vitamins, vitamin D (D2 or D3), iron, and iodine and the bioavailability of these essentials. At the moment there is special concern over certain long chain fatty acids and fish oils – and of eggs, milk etc. from animals fed on artificial diets, which would probably include fish meal. We are involved with the European Lipgene project in this and can discuss it further with the FSA, if required. These considerations apply in other respects, e.g. to GM feedstuffs routinely fed to cows producing organic milk and milk “suitable” for opponents of GM (which may include vegetarian-style people). Further embarrassments arise over vegetables such as mushrooms grown on chicken manure from units and systems that animal welfarists and veggie-style consumers abhor. The Vegetarian Society is so rash as to include free-range eggs in its approvals. The British Veterinary Association’s Animal Welfare Foundation has to publish special guidance to vets on the compromised situation to which the birds are subjected in these ridiculously-named systems. And what now, as avian flu threatens seriously?
9. Your list includes many dubious products in the vegetarian cupboard. At a glance we note some omissions: lactose, lactic acid, lanolin (and thus vitamin D, for instance), and citric acid (which may or may not be GM). Lactic acid may be of animal, mineral, or vegetable provenance. We have recommended the industry to append AMV descriptors appropriately. Support from the FSA – or other advice – would be welcome.
10. We offer the foregoing abbreviated comments (owing to so many other commitments at the moment) in the hope of serving consumers and manufacturers with sound scientific advice for a lively and innovative market in the vegetarian-style. Eat and smile, veggie style!