/ Food & Drink

What do you think ‘plant-based food’ means?

How would you define ‘plant-based’? Our guest, Claire Milne of the Consumer & Public Interest Network, is requesting your input into the open public consultation.

This is a guest post by Claire Milne. All views expressed are Claire’s own and not necessarily shared by Which?. 

There’s no two ways about it – food labelling can be downright confusing sometimes. 

Some terminology is well-established – vegetarian (no meat or fish) or vegan (no animal products at all) for example.

But there’s a whole load of other verbiage that falls in a grey zone. One person’s interpretation of ‘sustainably sourced’ for example, might be entirely different to another’s.

One term that’s becoming increasingly common in the food world is ‘plant-based’ – aimed, perhaps, at those of us who want to live healthier, more sustainable lifestyles, rather than those who want to define themselves as ‘vegan’.

The recent Which? Conversation on plant-based milk provoked much debate, and showed that a lot of people are interested in incorporating more plant-based foods into their or their family’s diets. 

Well aware of this trend, the food industry is gearing up to meet growing demand, and Upfield (which makes Flora margarine) is sponsoring a new British Standard which aims to define plant-based food; its stated goal being to ‘bring clarity to the market place’. 

Is it ok for plant-based food to contain animal products?

One of the thorny topics up for debate is what, exactly, does plant-based mean? The Consumer & Public Interest Network (CPIN), which is speaking up for consumers in the standard, needs your input.

We would love to know what Conversation readers understand by this term, and what you think it ought to mean in the new standard.

Should a food labelled ‘plant-based’ entirely exclude ingredients derived from animals? Or is it OK if it contains a small percentage of ingredients that would be acceptable to vegetarians, though not vegans, such as eggs, milk or honey (and if so, what percentage would you pick)? 

Should it be different from ‘vegan’ or ‘vegetarian’, and if so, in what way?

Would it be helpful to have two levels in the standard, ‘100% plant-based’ with no animal-derived ingredients and ‘plant-based’ which might have a small percentage of animal-derived ingredients?

This new British Standard will influence the way in which many food manufacturers label their food in the future, so let us know your thoughts on these questions.

Your thoughts will be fed (pun intended) into the current open public consultation.

This was a guest post by Claire Milne. All views expressed were Claire’s own and not necessarily shared by Which?. 


It seems clear to me that plant-based foods should contain no ingredients derived from animals, but what about bacterial and fungal polysaccharides such as xanthan, which is widely used as a thickening agent and stabiliser in foods? I would be grateful if Claire could comment on this.

Hi Claire,
How is plant-based supposed to be different from vegan?

So what is the market for something with a little animal content added to it and isn’t quite vegan?

What is Flora if not margarine? I thought margarine was a plant-based product [being made from vegetable oil].

Or do the manufacturers need to differentiate between a slimy spread and stiff slab of fat?

Are other less-pure vegan products trying to squeeze into Flora’s market so the manufaturers [sic] need a strict definition to keep them out?

I think it is the other way round John and Flora’s market is squeezing into the dairy-free market.

Until recently, apart from a few dairy-free specialists like Pure, Tomor and Koko, the majority of margarines and vegetable spreads have contained dairy. The regulars here will know my husband is allergic to cow’s milk and he has never been able to eat Flora.

Flora are actually rather naughty as they are selling Flora Original. It can’t be original because it no longer contains dairy.

Their plant based oils are sunflower, palm, linseed and rapeseed which are oils typical in a great many products, so I think this is nothing more than a marketing ploy as these spreads are vegan but may contain traces of dairy as they are not produced in a vegan environment.

Thanks, Alfa. I find it all very confusing. Are Flora saying that their product is now vegan and wish to have a British Standard for plant-based foods, as a discriminator, in order to protect the market they are now occupying? Is their objective to reposition themselves as vegan because that is a growth market [especially with the rising generation of consumers] so they wish to keep the sub-vegan products out of their new territory? I could see some sense in that commercially because more clarity could dispel dishonesty, but I don’t think a negative standard is the right way to go about it. I don’t think British Standards should be used to promote commercial interests – they exist to protect consumers.

Luckily our family doesn’t have to worry too much about these products but I feel it is sensible to keep a clear distinction between vegan and non-vegan foods by informative means through clear and consistent labelling. If the boundaries are becoming blurred by marketing muscle then that is not in the interests of consumers in my opinion. Having an intermediate category of plant-based foods which are semi-vegan or para-vegan seems to me to be deceptive. People with allergies or intolerances of animal or dairy products, as well as those with philosophical objections to eating animal inclusive foods, need to have certainty over what they are buying.

Another possible angle is that Flora don’t wish to be too closely identified with veganism as for some consumers in their target market that is an unattractive proposition so they are looking for official validation of their not-quite-vegan position based on a plant-based identity that will appeal to a much wider market. In other words, they want to push vegan food further into a niche category with necessity-driven demand rather than a philosophical approach because the economics of mass food production make that a cheaper solution [i.e. having to guarantee full vegan compliance will be too expensive and erode their margins against competing brands in the vegetable spreads category]; is that the idea?

I am still not sure I can get my head around this one and I have possibly completely misunderstood the situation.

I think you have hit the nail squarely on the head John but there is a bigger picture going on here.

Has anyone heard of Upfield? Sounds like one of the made-up Bluebell Farm products that supermarkets sell.

According to Wikipedia Upfield was founded 2 years ago:
Upfield is a global company owning multiple brands of margarine and other food spreads, including Flora, Blue Band, Stork, Becel, Country Crock and I Can’t Believe It’s Not Butter!. It is the largest plant-based consumer packaged goods company in the world, operating in 95 countries. Upfield was spun off from Unilever and purchased by investment firm KKR in 2018.

KKR & Co. Inc. (formerly known as Kohlberg Kravis Roberts & Co. and KKR & Co. L.P.) is an American global investment company that manages multiple alternative asset classes, including private equity, energy, infrastructure, real estate, credit, and, through its strategic partners, hedge funds. The firm has completed more than 280 private equity investments in portfolio companies with approximately $545 billion of total enterprise value as of June 30, 2017. As of September 30, 2017, Assets Under Management (“AUM”) and Fee Paying Assets Under Management (“FPAUM”) were $153 billion and $114 billion, respectively.

So let’s face it, this is all about money and profit and cashing in on the current bandwagon.

I think you are correct when you say full vegan compliance will be too expensive and they are looking to create a niche that will give them profit before ethics. Plant-based would mean they wouldn’t have to use special equipment that hasn’t been in contact with meat and dairy like vegan products. So yes it is deceptive and dishonest.

Will it hurt the current vegan and vegetarian markets many of who are small businesses? To stay in competition with Upfield, they might have to create complete new packaging at great cost. These mega-corps can easily weather losses until they have squashed or bought out the competition.

Hi Claire – Thanks very much for this information.

What I would like to see is full information about what is in our food, including the source of ingredients where this can vary. For example, some polysaccharides can be sourced from plants or could be microbial in origin. I have no objection, within reason, to what goes into food and many years ago I did some research and consultancy work funded by a food company. Nevertheless, I believe that we should be entitled to know what we are buying.

I followed the research and development of Quorn with interest but was disgusted by the misleading advertising by Marlow Foods of the product as being of mushroom origin, when it is based on a mould or filamentous fungus. It took many years and considerable pressure to force the manufacturer to be honest about their description.

This is particularly important in the case of allergens and the number of alerts published by the Food Standards Agency provides evidence that the industry needs to be more careful. Those who buy bakery products in supermarkets or shops or alcoholic drinks are usually denied information about their ingredients. There is currently no requirement to declare ‘processing aids’ including enzymes in food, never mind their source.

If a product is described as ‘plant-based’ I would expect it to contain only ingredients derived from plant sources or others to be clearly identified on the pack.

Like others, I am not sure about the benefit of having a British Standard. These are not readily available for the public to read, so it would do nothing to help us know what we are buying and eating.

Further to what I said about Quorn, this provides an excellent example of why we should know exactly what we are buying and eating: https://www.independent.co.uk/life-style/food-and-drink/quorn-labelling-changes-mould-main-ingredient-vegetarian-mycoprotein-a7935791.html

“Reveals it is made from mould” is a typical newspaper tactic to arouse an emotive, rather than a rational, response ( just in my view).

I’ve never found the need to eat a meat substitute. Natural meat suits me very well

Quorn is made using a mould, also known as a filamentous fungus. It was originally classified as Fusarium graminearum but has since been reclassified as Fusarium venenatum. This information is readily available, for example on Wikipedia.

The number of people who have suffered severe allergy to Quorn I very small but those who suffer allergies must know what their food contains. I am not affected by Quorn but years ago I had an allergy to certain moulds in food, which caused intense itching and swelling of my throat. I carried an injection for use in emergency. My allergy to moulds in food gradually subsided but it gave me first hand experience of why those who suffer allergies and intolerances need to know what they are buying and eating.

“Plant based” suggests to me a product that is largely, but not exclusively, based on plant material. A list of ingredients should give the information needed to those who are particularly concerned. In my view the plant content should be stated clearly (by % weight perhaps in the final product) and a minimum value on this % should be required for the description to be used.

I don’t know what the term “plant based” is meant to convey, or what purpose it is meant to serve. We have products for vegetarians and vegans, so what gap does this fill? It suggests the majority of the ingredients come from plants, so >50% would technically cover that. I’d be happier to see the proportions of different ingredients listed so we can see what we are being sold. There are plants we might like, and plants we might not, more important to my mind.

I would prefer there not to be a British Standard created for this description. It is too vague and attempts to define it precisely will leave room for argument however well-meaning – where would it end? Animal-based food, fish-based food. Just set out the ingredients and let the customer decide.

I would expect over 50% of a plant-based food to be made from non-animal material – but there will no doubt be advocates of higher values so there could be grades of “plant-based” which would need to be declared.

Since, generally, we don’t eat meat from carnivores but grazing animals it could be claimed that meat is plant-based. I can see it taking ages to agree on an acceptable definition of “plant-based”.

To me, “plant-based food” means food that has been altered, reformed, or otherwise interfered with. Something has been added or something else has been taken out.

We already have vegetarian and vegan foods as clear unambiguous definitions.

So what could “plant-based food” usefully add here?

I suspect there’s an even bigger problem. The work of Albert-László Barabási at Harvard Medical School, among others, indicates that whether foods have animal or vegetable ingredients in them is only a miniscule aspect of the bigger picture.

As an example, Garlic has more than two and a half thousand compounds with almost six hundred of these known to have potential health effects. In fact, we appear to know next to nothing about 99.5% of the foods we eat. And that’s before we take into account the added complication that cooking transforms chemical components into others, sometimes with health implications. When sugars and amino acids react at high temperatures, the result is new molecules that make roasted and grilled food delicious, but the reactions also produce the compound acrylamide, which is a probable human carcinogen.

So until we learn a great deal more about the food we’re currently eating I wonder if debating whether it ought to be labelled as vegetarian, vegan or
‘plant based’ is really that important.

We may not know all the minutiae of what natural foods contain or how they react to cooking, for example, but we have centuries of accumulated experience to help us. I don’t think I am going to worry too much about the diet I choose – a mixture of mainly healthy and a small dose of naughty foods – as I seem to have done reasonably well on it.

John, I agree about the “British Standard”. I don’t see this as an appropriate vehicle to define a food term. There is presumably EU legislation for food descriptions, such as “free range”, and this seems the place for “plant based” to sit, if we really must have yet another term. We can embody it then in UK regulations.

Why all the fuss about “plant based” anyway? Many food terms do not describe what I think the man (or woman or…) in the street would assume was meant. I’d rather we had a campaign (probably futile) to clean up the whole vocabulary and require a description to mean what it says.

Fruit flavour or fruit flavoured?

Veganism has picked up a fair amount of negativity over the years so I see the term plant-based as a new way to say vegan. It seems to be a band-wagon aimed at the younger generations who will save the planet if they embrace plant-based foods and demonise meat and dairy farming.

I do not see the need to define the term as a British Standard and Upfield are just jumping on the band-wagon to be leaders in supplying vegan foods. I see they have removed the milk ingredients from Flora and are yet another company claiming they use sustainable palm oil (they can’t all be telling the truth).

You have to ask if plant-based labelling would harm British farmers.

Tim Cook says:
24 July 2020

I have not eaten meat for a couple of years now as the quality of vegan/vegetarian foods on offer have grown from the usual dried offerings. However, I have been thinking recently, just because it’s meat free, how do I know it’s actually a healthy good option? Is there a list somewhere that spells this out. For example I like the Naked Range and Beyond in Tesco, but are they actually good or rull of rubbish?
Any ideas?

But not all packaging shows traffic light symbols since it is not compulsory.

There is the added problem that the servings or portion sizes are not consistent across brands.

There is no independent standard for the ‘recommended daily allowance’ – and it frequently varies from the illustration on the packaging which is usually referred to as a “serving suggestion” – a meaningless phrase in the context of healthy eating.

I’d rather see us educated in food and diet, and how to prepare nutritious balanced meals, than have generations grow up with manufactured foods, ready meals, reliant – if anyone really looks, which for the majority I doubt – upon traffic lights, and dubious classifications. I’d suggest the evidence that is not good is in the growth, literally, of obese people (I exclude those who have reasons why they are obese).

If I really want a plant based meal I can make it from… plants. As long as manufactured products such as margarine show the ingredients then a basic understanding will tell us whether we want to buy it. I’ve never spread marge on my bread or in my jacket potato; I use butter. I can tell talk from mutter.

Sadly we often don’t know what our food contains, Malcolm. Let’s consider cheddar cheese as an example. This used to be made using rennet from the stomachs of veal calves. Nowadays this is usually replaced with chymosin produced using genetically-manipulated fungi (or bacteria). The ingredient of the cheddar cheese in my fridge is ‘cheddar cheese’ and milk is identified as an allergen, but the only clue about how it is manufactured is the label ‘Vegetarian’.

How are we supposed to learn what our food contains?

Regrettably for many they will need to trust the cheese manufacturer to produce a safe product. I am thinking of the basic ingredients in the food, let us say in a Lancashire hotpot or in tomato ketchup. We have to trust the (many) E numbers etc that are included to be safe by regulation, but we can assess the “food” ingredients, and should have information on possible allergies. I doubt many have the ability to do more than that.

It is, perhaps time, if we are concerned about food content, to encourage people to make their own meals. My kids, for example, use a slow cooker from time to time, put on when they leave for work to make a dinner for when they get home.

This goes beyond food safety. In the case of cheese, some might want to avoid cheese made using animal rennet and others want to avoid cheese made using genetically engineered organisms. My concern is that the public should be entitled to know what they are buying and eating. Is that unreasonable?

The newspaper article that you deemed emotive referred to a case when Quorn made no reference to it being based on a filamentous fungus or mould. Thanks to this and other cases of allergy, those who buy Quorn are now better informed.

My concern is not about food safety but requiring manufacturers to say what goes into the food they sell. As I said before, not all components have to be declared.

I’m very much in favour of home cooking, as I have said in other Convos. Nowadays we have the benefit of fridges and freezers so that we can store our our home-made ready meals. When I was a teenager I munched my way through many packets of biscuits but making them myself made me aware of just how much sugar and fat goes into them.

Having now re-read most of this convo, am I right in thinking that, under this proposed BS, some foods currently marked as “Suitable for Vegetarians” would not actually qualify as “plant-based food” under the new BS?

That seems a reasonable inference, Derek.

Perhaps we need to turn this whole thing on its head. Up to now labelling has been designed to help vegans and vegetarians find what they would like to eat. What might be more important would be to help people with allergies, intolerances, and diet restrictions for medical reasons, to avoid food that they should not eat. This could be done through illustrations, descriptions, analytical information about ingredients, and consistent guidance. Going beyond that, the ‘standards’ that are needed are clear and consistent definitions of the terms vegan and vegetarian explaining (a) what is excluded, and (b), in the form of a warning, what could be included due to the manufacturing environment. Vague phrases like “suitable for vegetarians” should be banned; it would be more helpful to describe some foods as “unsuitable for vegans”. If “plant-based” takes over as the generic description there will remain a need for clarification and confusion will persist.

I don’t suppose the food industry will like being told how to describe its products and it is unlikely that the government will introduce legislation.

If we’re going to support new standards and definitions let’s first be clear about our purposes in each case and adopt the right standards – which might not necessarily be ones that suit the food industry.

Wherever the decisions are made on the approval of a new British Standard, should it come to pass, Which? needs to be involved.

Hopefully Which? will be involved, John.

‘Vegan’ is not just about the source of food but about how it is produced. Claire explained earlier: “…plant-based” refers only to ingredients, not to the manner of production or to animal exploitation (which “proper” vegans care about)…”

I wonder about the real motive of introducing the term ‘plant based’.

I was under the impression the Mediterranean Diet was the fully acclaimed tried and tested diet to follow. ‘Plant based’ is a supposition without any definitive title or accreditation which would indicate a need for more research to ascertain its valid health benefits.

Eating very small amounts of meat and cutting out all dairy produce because it is an animal derivative is a contradiction in terms and equally proportional to it’s pseudo ingenuous title.

Wavechange – i have tried to explore the possible motives for the move by Upfield but it is perplexing.

After further thought, I feel that Which? [which has not authored this Conversation and has stated its usual disclaimer in respect of its contents] owes us a comment on what it considers should be the right policy in this situation and also an assurance that it will seek to be involved in the process for deciding on a British Standard; at the moment I am uncertain where it stands.

I also believe that Which? should oppose the move to seek a new Standard for the descriptiuon “plant-based” unless a full justification, with reasoning and evidence, is given by the promoter in advance of the process.

I feel that the Consumer & Public Interest Network should also oppose the move. It is helpful that Claire Milne has brought this issue to our attention and is carrying out a consultation on its implications and how to make it effective – because that is a potentially useful exercise whatever the outcome – but without knowing the true purpose of the proposition it might be going off at a tangent. Rather than seeking to negotiate, modify or neutralise something that would still be unsuitable, would it not be better to try to block it, but keep the arguments in reserve in case that approach is not successful?

Beryl – I am sure other diets are just as capable of being as healthy as the Mediterranean diet, including the Second World War diet dictated by rationing. I suspect that the UK’s problem is not just the composition of the diet but the volume intake of inappropriate food coupled with other lifestyle bahaviours. We are fast approaching dependency on the trans-Atlantic diet.

I expect that it is entirely because the term “plant based” is “a supposition without any definitive title or accreditation” that the Flora manufacturers are attempting to achieve such accreditation through the medium of a British Standard. I agree with you that there needs to be a full explanation, in the public domain, of why it is necessary, what is the true purpose of the creation of such a standard, and whether there are any health benefits or merely commercial ones, together with supporting scientific and research evidence to demonstrate that it will achive the stated purpose if approved and not further reduce competition.

Given that Upfield [as Alfa postulates, clearly a made-Up name] already appears to have a monopoly of the vegetable oil spreads market with all the major brands in its porfolio [Flora, Blue Band, Stork, I Can’t Believe It’s Not Butter, and others], I am (a) curious to know why it feels so threatened as to need additional protection, and (b) suspicious that it is merely trying to stifle competition in some way and thereby increase its profitability.

As Alfa also tells us, Upfield is now owned by KKR, an aggressive investment vehicle whose only motive is the highest possible return on its acqusition with no regard [unless there is a commercial benefit from it] for the population’s health and well-being.

John – I am very much opposed to any business sponsoring any standard, especially since I can see no benefit to the consumer. We have classifications of ‘vegetarian’ and ‘vegan’ which seem reasonably well understood, but from what Claire has said, I assume that ‘plant-based’ food could blur these boundaries.

Here are brief details of the current consultation on plant-based foods

Comment by: 12th Aug

Thank you for taking the time to review PAS 224:2020, Plant-based foods – Characteristics and composition – Code of practice

“We would very much appreciate:
> Your feedback on the full text of the draft.
>Your feedback on the treatment of animal-derived ingredients in the definition of plant-based food.
>To understand how you see the relationship (if any) between “vegan”, “plant-based” and “vegetarian” foods.”

At present we cannot access the document because it is password protected and there is only two weeks left to submit comments. 🙁

I fully agree that Which? and CPIN should block the introduction of the standard. I’m very grateful to Claire for bringing the proposal to our attention but we need to hear the views of Which? about a proposed standard that could harm the interests of the consumer.

I am also very strongly against standards not being readily available to the general public. Unless you live close to a library that provides access to BSOL (the online version of British Standards) you would have to pay for copies and in some cases they can cost hundreds of pounds. I wonder if I am the only one here who would be prepared to fight for open access to standards that relate to consumer issues.

In my experience it would be unusual for a British Standard to be sponsored by any one organisation. Usually such standards prosper when they represent an agreed consensus view. Achieving such a view usually takes a few years of discussion involving all key stakeholders.

I’ve been following the disquiet over the name of the company and the motives behind the rebranding and one thing does occur to me: the ubiquity of Unilever within Which?

The big, the huge problem Which? has is Which? Ltd. Never heard of it? Not surprising, as it’s rarely mentioned, and yet its power within Which? is immense.

I did a lot of research on W? Ltd some years ago, and it was fascinating to see the number of senior company executives that form the board of this little-known entity. As a brief snapshot in 2016 directors from the following companies were on the board of W? Ltd:

The Independent
The i
London Evening Standard Barclays Capital EMEA

More worryingly, “PVS, Wall, Cameron, Ward and Mullins all held directorships in or were senior managers of a company called Diageo. It’s an odd coincidence that the majority of the Which? Ltd board came from the same company.”

Which?, therefore, is, at its very core, dependent on major companies’ directors and experience.

It is extremely worrying, Ian, but maybe this is best discussed in the Convo about the future of Which? I want to a member of an organisation that is independent as far as possible from commercial influence.

From reading the current document on the BSI website, ‘plant-based’ foods are treated as lying between current vegetarian and vegan requirements.

From the Plant-based foods:
c) should contain a maximum of 5% (w/w) of ingredients in the final product, that are animal-derived or are neither plant nor animal-derived (water, salt and salt substitutes are excluded.)

The more I read the more convinced I am that existing vegetarian and vegan classifications are fine and ‘plant-based’ foods that can contain some animal products just muddies the water.

The involvement of Unilever did ring a bell in my brain but they have divested themselves of the Flora business so we don’t need to worry about that in this particular context. I am not against the participation of major commercial companies in the governance of Which? because I think, if responsibly handled, it can have advantages in both directions.

I am disappointed that access to the draft BS documents is not freely available since, as a number of us have said, it is crucial that we fully understand the purpose of the proposal. I have no knowledge of the inner workings of the BSI but I would hope that an ill-founded application would not progress far, albeit any application has to be addressed through the recognised procedures. I wonder whether there is any way in which the Upfield reasoning and justification statements can be released for consideration in time for responding. Alternatively, could the time limit be extended to give the consumer interests time to make their submissions based on a full understanding?

I agree with Wavechange and Derek’s comments and again urge Which? to let us know as soon as possible where it stands and what action it is going to take. It is interesting that Claire is not aware of whether or not Which? will be making representations.

You can freely access draft BS documents and comment on them. You just need to register with BSI. See my comment below that includes a link.

Apropos JW’s remark
” I am not against the participation of major commercial companies in the governance of Which? because I think, if responsibly handled, it can have advantages in both directions.”

I am astonished that given the history of major companies acting as bad actors that anyone should feel that it is probably OK. I almost amused that there is a caveat ” if responsibly handled “. Do tell how that can be arranged and monitored by the members.

Whilst the collusion of P&G, Unilever, and Henkel to rig prices throughout mainland Europe may have been exposed and two of them duly fined does anyone wonder why Which? never mentioned it. Or pointed to the overwhelming market dominance in the UK of P&G and Unilever and considering the possibility that the rigging had occurred in the UK.

A belief that businessmen do not have their own agendas but become keen consumer champions if running a consumer organisation seems light of supporting evidence.

If P&G and Unilever had been investigated for rigging the UK soap market by the Monopolies Commission and found guilty then the Consumers’ Association did have the powers to seek additional damages for people affected. Of course asking the Commission to investigate in the light of the successful EU case might have been an obvious first step for Which?

Which? has also avoided many consumer versus company cases which rather begs the question of what does the tag “Consumer Champion” mean. For example a company that blatantly denied contracturally offering continuing post-operation care surely deserves full publicity for it’s behaviour and support for the legal action.

Patrick – I don’t want to divert this Conversation from its important topic.

If you would like to re-post your comment in an appropriate Conversation relating to the governance of the Consumers’ Association we could discuss it there.


The proposal is for a Code of Practice, giving guidance and recommendations. BSI are part of an international network who are responsible for preparing standards and will respond to a need where there appears to be a lack. This possible need can be identified by users; sponsoring a proposal, as Upfield have done, does not mean they control the result, as a committee of independent contributors will be involved in preparing the document and issuing it for public comment. This will include the relevant industry, trade associations, as well as any interested experts and individual members of the public. Which? therefore can comment on the draft.

Anyone can register with BSI to view drafts, and comment on them.

It seems the purpose is to place plant based foods in the vegan/vegetarian band, as has been stated above. Vegan contains no ingredients from meat, fish poultry, egg or milk products. Vegetarian can contain egg or milk products. Plant based is proposed to have a maximum 5% ingredients that are not plant derived (100% plant based has none).

Whether this is worth doing is debatable, as many have pointed out. Those who feel it worth making their views known should comment on the draft – PAS 224:2020. You have until 12th August.

Are Which? commenting?

Thanks, Malcolm. That is a helpful comment.

Our [and the BSI’s panel’s] understanding of the need for this measure will depend on how its purpose has been justified by the promoter [Upfield] and the reasoning behind that, so I shall try to access the documents and see what they say.

It will be interesting to discern why 5% has been identified as the tipping point for a ‘plant-based food’ definition. It seems to me to be so marginal as to be unnecessary without some powerful commercial motive.

I think the 5% could be to allow for cross-contamination when products are not produced in an animal-free environment that would likely add to the cost of the product. This would put vegan products at a disadvantage in the marketplace.

It could also be deceiving those who think they are eating an animal-free diet as traces of other products are not going to appear on an ingredient list.

Agreed, Alfa.

So it’s not about putting some animal product in, but about not leaving some out because it’s too costly to ensure total exclusion.

It gives the answer to Beryl’s point: it offers no benefit to health. It’s all about production economies.

I still cannot see a market for such a category as ‘plant-based food’. I just don’t think people are going to look for it as a range of products in its own right. Vegans, obviously, won’t be interested; vegetarians might be interested but will need to know what’s included and what’s not and will be looking for the vegetarian symbol; the remainder [still the majority] will carry on as they do now and won’t make a bee-line for the plant-based foods to the exclusion of their previous selections.

Of course, if we could wean the population off pre-prepared and processed food we wouldn’t have this dilemma.

As Wavechange has explained, now that most homes have freezers, people can make and keep their own ready-meals from ingredients of their choosing; cheaper too.

It would be interesting to know what the Vegan movement thinks about these proposals to push their products into oblivion behind a wall of ‘plant-based’ foods buttressed by heavy marketing and deceptive descriptions.

AJ says:
26 July 2020

I would say ‘Plant-based’ is already pretty solidly defined by now as ‘containing no animal products, i.e. meat, dairy, eggs, fish or shellfish.’

Given animal product industries, as well as the European Parliament and several US state legislatures, are unwilling to allow vegan food companies even to use words like ‘sausage’, ‘milk’ or ‘burger’, to label something ‘plant-based’ as anything other than the definition above would be disingenuous.

That being said, I do think labelling things clearly as ‘vegan’ or ‘vegetarian’ is more useful for the average consumer when scanning shop shelves.

That is an interesting interpretation, AJ.

I see the term ‘Plant-Based’ as not being exclusive of animal products; indeed it explicitly allows for less than 100% vegetable composition. If it meant exclusively vegetable it would be unnecessary since the term ‘Vegan’ means that plus it also means that processing and manufacture must take place in an animal product-free environment which is important for many consumers [and essential for some].

I agree with your final paragraph. The overriding interest should be to inform and protect consumers.

There seems to be three strands to this. The first is the definitions, the second, as Wavechange points out, is the side effects of producing the food, which add ingredients not covered by the food descriptor and thirdly, the consumer who wishes to pursue a particular life style. I suppose there is also a fourth, with the consumer wishing to eat more healthily.
The definitions should all be clear and unequivocal. People should understand exactly what each statement means so those with a moral or religious set of beliefs ( my third category) can know exactly what to buy and what to eschew. “Plant Based Food” is neither fish nor fowl. it is a suggestion that the final product is formed from plant based materials, but anything else can be added to make the food eatable. It doesn’t add any clarity for those looking for it, though it tries to placate the vegetarian by suggesting it is free of animal products without stating the fact. A lie by default rather than by statement.
Dealing with product manufacture, we are really down to minutia when considering the likes of microbes and fungi as being different from the plant growing in the garden that is used as the main product. It would have to be a particularly strict vegan to look in that detail at what they cooked. As with all such folk, I respect them and and let them get on with it.
Food allergies are a different problem and food labelling should be clear on what is in the product. I avoid sugar free, sweetened items as they trigger an asthmatic response.
In the end a vegan or vegetarian must decide what principles they need to apply and adjust purchases accordingly. They must also make a list of what is available, so that shopping becomes easier for them. I believe it is their responsibility to do this, since the supermarkets cater for everyone and a general shopper also needs to wander round shelves easily. He or she doesn’t have the self imposed barrier of the vegan or the vegetarian to cope with and just gets on with living. There is also a need to educate all of us, so we can leave the NHS alone. That is a separate issue, but one that is as important as the ones being discussed here. Especially so if the consumer decides to cut a large quantity of food available from their diet in order to follow a code or a life style choice.

That’s a very good summary of the situation, Vynor.

So as not to divert us from the topic at hand I am taking some additional observations on the points you have made to The Lobby.

It looks like we could be heading in the direction of Flora margarine having to be renamed “Flora with a little bit of Fauna”.

I am curious to see on which side of the line between ‘Plant-Based’ and ‘Vegan’ Upfield wish to park their Flora product, and why.

Barney Laurance says:
27 July 2020

I see “plant based” as simply a rebranding or synonym for vegan foods, and I would generally expect the same rules to apply – the food should not be made from or with animal products.

Of course it’s a little bit odd technically to call something based on water, mushrooms or algae ‘plant based’, since none of them are plants, but I can cope with that.

I am a fan of simplifying things as we are all aware that humans are not very good on detail and that a lot of marketing is based on confusing potential customers.

I think one basic step missing here is identifying products easily and accurately without need to examine packaging in detail. From a consumer point of view mandating highly visible triangles/stars circles/squares could go a large way to helping consumers. Arguably colours are good but I favour black as it can not be easily obscured with exotic patterns on a white background of the same shape.

To simplify matters further all products that contain a mix of things such as possible allergens, animal products etc are unmarked in the black coding system. As this would cover the majority of products disruption should not be huge.

I think most people could learn such a basic system even if expanded to a code of four by including plant-based. As to the idea of plant-based and flexi-veggie I can see some merit but I am cautious as without my suggested labelling I really do think it is a confusion issue looming large.

So far there is not even consistency of practice in the use of the recommended traffic light symbols.

I like the idea of simple geometric symbols if they could be mandated and consistent, but if a product has the word vegan or vegetarian in its title then an additional mark would be superfluous.

It would be necessary to ensure that all food products carried the appropriate symbol otherwise unmarked products would lead to confusion; there would therefore need to be a symbol for products outside the plant-based/vegetarian/vegan categories.

Some imported food products would probably need to be over-labelled.

Unless each ingredient, or extract of, is clearly defined on the product label, how do we know exactly what we are eating? For example, plant based could be a collective term for one or more of the following edible weeds.

Stinging nettles
Lambs quarters
Sheep’s sorrel
Dandelion & Burdock
Grass – not recommended for human digestive systems or for human teeth as it contains silica, an abrasive that wears down human teeth that are not subjected to animal mastication processes.

Although no doubt highly nutritious, the above are not exactly a commercially acceptable or viable food product that discerning consumers would find very appealing.

Plant based is therefore a convenient collective pseudonym used to sell more and increase profit margins. In my restricted knowledge of all things vegan or vegetarian, I would certainly hesitate to buy anything containing either lambs quarters, sheep’s sorrel or duckweed even, and grass, for the above reasons……. a definite no no 🙁

Good points, Beryl. Not an appealing ingredients list so the manufacturers are looking for a way round it and “plant-based” covers a multitude of sins.

Mashed up into a paste and integrated into the product they could make a hum-drum margarine spread a bit further but it could have green veins and taste a bit sour.

This technique used to be called adulteration.

Pretending to be meat!

Lori says:
3 April 2021

I am one who thinks that everyone,company and otherwise should have a telephone number in very large writing on their product so if anyone is in doubt over what,s in their food it can be clarified by them. Also the phone should be answered within a certain time frame and by a knowledgeable human being with all calls taped for any future misunderstandings.As well the phone number should be checked randomly to make sure it is in working order.l for one have tried phoning a company helpline and no one has answered. The problem for me is with declaring what,s in a product on the product is most of the time is that the wording is far too small to read. Especially when there is little space for the written word, the colours used and space when the product is small.
After writing this I,m now thinking well maybe it,s to much to expect everything!

Lori says:
3 April 2021

Also plant based food means exactly that. Core ingredients plant and a free for all after that.

There are certainly some very strange ingredients in plant-based foods. If they were honest, many products would be renamed to take account of their main ingredient which is often pea protein or soya.
Devil’s Kitchen Shiitake Mushroom Burger: Rehydrated Pea Protein 68%, Diced Shiitake Mushrooms 10%

There are also ingredients that don’t have to be declared and if you have concerns, you might find it helpful to contact the Food Standard Agency.

Or go straight to the top (of larger businesses)

The devil is in the marketing as well as in the kitchen. The percentage of ingredients does not have to be declared unless it is mentioned in the name of the product or perhaps alongside.

According to the Food Standards Agency:

“The following ingredients don’t need to be listed:

> Those components of an ingredient that were temporarily isolated during product manufacture but reintroduced in their original proportions, such as egg yolk and egg white used separately in a product but declared as ‘egg’.

> Non-functional carryover additives and enzymes.

> Additives, enzymes and other substances used as processing aids.

> Carriers for additives, enzymes, flavourings and nutrients.

> Water used up in reconstituting concentrated or dried ingredients.

> Water as part of a liquid medium that is not normally consumed.

Some people have to avoid gluten. This is normally present in flour and therefore does not appear in the ingredients list. If gluten was added it would have to be listed. It’s not much fun for those who have to be careful about what they eat.