and Finland’s Supreme Administrative Court (February 2024)19 upheld the use of “burger patty” in plant-based product marketing. These evolving national responses, however, do not eliminate the legal uncertainty faced by food business operators in practice. The following chapter addresses how this uncertainty translates into specific obligations and potential legal exposure for providers in the food service sector. IV. LEGAL OBLIGATIONS RELATED TO VEGAN LABELLING IN THE FOOD SERVICE SECTOR The rapid growth in demand for vegan meals has outpaced the development of specific legal standards tailored to this segment of the food service industry. Food business operators (FBOs), including restaurants and caterers, must navigate consumer expectations and food law obligations in the absence of a harmonised legal definition of “vegan” at the EU level. While existing food information and safety legislation applies in principle, its application to voluntary vegan claims raises particular challenges, especially in terms of legal accountability for inaccurate labelling, risk of cross-contamination, and consumer expectations based on ethical or dietary concerns. 4.1 Information Duties under EU Food Law The central legal framework governing food information is the FIC Regulation. This regulation requires that all food, including meals served in catering establishments, be safe, not misleading, and properly labelled, with mandatory particulars such as allergen declarations, list of ingredients, and name of the food.20 Voluntary claims, such as “vegan” or “plant-based,” are governed by Article 36, which permits additional information as long as it is not misleading, ambiguous, or confusing for the consumer.21 In practice, this means that when restaurants voluntarily describe a dish as “vegan,” they assume responsibility for the accuracy and clarity of that claim. 19 Supreme Administrative Court of Finland, 13 February 2024 (upholding “burger patty” for plant-based products) – reported in Challenges in naming plant-based alternatives (Food Compliance International) https:// foodcomplianceinternational.com/industry-insight/scholarly-articles/3256-challenges-in-naming-plant-basedalternatives accessed 6 June 2025. 20 FIC Regulation art 6 et seq. 21 Ibid art 36. 172 KATJA ŠTEMBERGER BRIZANI
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