Updated October 21, 2019. | Picture the following scenario. You’re shopping for vegan groceries and you pick up a bar of dark chocolate. Before adding it to your cart, you flip it over and scan the ingredients — it seems to be free from animal ingredients, except for one thing. The label says “May contain traces of milk.” Does this mean that it’s not vegan?
What Does ‘May Contain Traces Of’ Mean?
Reading ingredient labels is a habit for anyone with dietary restrictions, from gluten-free to Kosher, the peanut-allergic, and so on. Some keep a careful eye out for warnings that say “may contain traces of” or “processed in a facility that manufactures milk/egg/peanut products.” Other variations include “made on shared equipment with” and “made in a factory that also handles.”
These warnings do not mean that milk was added as an ingredient. But, both mean that the product may have come into contact with a small amount of said ingredient. Many manufacturers use one facility to make multiple products. That chocolate bar might have been made on shared equipment with a non-vegan product. It can also come from workers’ gloves or other by other means, like being stored in the same building. Even with cleaning and sanitizing, traces of an allergen may be enough to spark a reaction in certain people.
How Many Animal Ingredients Do These Products Contain?
It’s not possible to determine how much of a certain ingredient a product has, even with a “may contain” label. Labeling also varies by country.
The UK’s Food Standards Agency (FSA) states “precautionary allergen labelling should only be used after a thorough risk assessment. It should only be used if the risk of allergen cross-contamination is real and cannot be removed.”
Products that actually contain allergens like egg, fish, milk, and shellfish will have the ingredient featured in bold print. “Free from” labels mean that rigorous efforts have been taken to ensure that the final product is completely free of a specific allergen. “This includes checking that all ingredients and packing materials do not contain this allergen and that cross-contamination from other foods made on site is prevented,” says the FSA.
In the US, disclosing allergens has been a requirement since January 2006, when the FDA (Food and Drug Administration) passed the Food Allergen and Consumer Protection Act (FALCPA). This applies to the top eight allergens — fish, shellfish, wheat, soy, peanuts, tree nuts, milk, and eggs. But “may contain” is a different story.
“The ‘may contain’ statements are not required under FALCPA. It’s completely voluntary,” Emily Melby, RDN, at Allergy Associates of La Crosse, told Allergy Choices.
Some companies still add a “may contain traces of” warning for legal reasons in the event that someone has an allergic reaction. If a product actually contains an allergen, the label will indicate it in bold print at the end of the ingredients list. At this moment, there is no legal definition for what constitutes a “vegan” product in the US or the UK. But, the UK has the Vegan Trademark from the Vegan Society.
Are Products That ‘May Contain’ Animal Products Vegan?
Technically, if you buy a product that “may contain traces of milk,” there is a chance that you might be eating an animal product. But, keep in mind that the amount is very small. Some vegans might choose to avoid these or argue that one should spend their money on 100 percent vegan brands instead. But for others, eating those products is still in line with their ethics. According to the Vegan Society, the oldest organization of its kind, the definition of veganism “is a 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.”
As the non-vegan materials in “may contain” products are present accidentally, purchasing them is not increasing the demand for animal-based food, and are therefore vegan. Additionally, the contamination is often no worse than could occur in a kitchen that is shared with non-vegans.
For instance, eating your soy ice cream in a bowl that once held dairy or cooking in a skillet that a housemate made chicken in. Some might choose to have their own, but it all boils down to personal preference.
If you choose to avoid products that “may contain” animal products and support only vegan brands, that’s valid. If you’d rather have that chocolate bar that might have been made on shared equipment, that’s valid, too. There are several conversations that many vegans are split on, like avoiding the Impossible Burger or buying from plant-based brands owned by non-vegan companies. Not everything is black and white. But, as the Vegan Society states, being vegan is about excluding animal products by as much as you practically can. So, go ahead and enjoy that (fair trade) vegan chocolate bar that “may contain” milk.
