While this recognition strengthens the normative weight of veganism, it remains disconnected from the technical food law framework, which continues to operate without a harmonised understanding of the term “vegan.” The following section explores this regulatory gap in more detail. III. LEGAL FRAMEWORK AND CONCEPTUAL UNCERTAINTY REGARDING VEGANISM IN EU LAW Although veganism enjoys increasing cultural and societal recognition across Europe, its legal status within the framework of EU food law remains underdeveloped. In contrast to regulated designations such as “organic” or “gluten-free,” the term “vegan” currently lacks a harmonised legal definition at the EU level. This definitional gap generates concrete regulatory implications for both consumers and food business operators, especially in the gastronomy sector, where expectations associated with the label often diverge considerably. The absence of a definition in binding secondary legislation, including Regulation (EU) No 1169/2011 on the provision of food information to consumers (FIC Regulation11), has led to divergent interpretations across Member States and within private certification schemes. Among the most prominent is the V-Label, administered by the European Vegetarian Union, which defines vegan products as free from animal-derived ingredients while allowing for minimal cross-contamination “as far as possible and reasonable.” While this approach offers a pragmatic standard for producers, it may fall short of the expectations of ethical vegans or individuals with strict dietary restrictions.12 This regulatory fragmentation creates legal uncertainty for businesses seeking compliance and for consumers who rely on the term “vegan” to reflect varying underlying motivations, whether ethical, religious, environmental, or medical. In such cases, the same designation may carry different semantic and normative weight.13 Furthermore, even where the term is used voluntarily, it is subject to the general prohibition of misleading practices under the Unfair Commercial 11 Regulation (EU) No 1169/2011 of the European Parliament and of the Council on the provision of food information to consumers [2011] OJ L304/18. 12 V-Label, Criteria for the V-Label (2024) https://www.v-label.com/criteria/ accessed 13 June 2025. 13 Cf. Aryan Jaiswal and Tripti Shrivastava, ‘The Ethics of Veganism’ (2024) https://www.ncbi.nlm.nih.gov/pmc/ articles/PMC11016330/ accessed 6 June 2025. 170 KATJA ŠTEMBERGER BRIZANI
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