it can nonetheless carry legal significance where it compromises the accuracy or credibility of the vegan designation. This may be particularly relevant for consumers who adhere to veganism on ethical grounds and expect complete avoidance of animal contact. There is currently no explicit EU-level requirement obliging FBOs to prevent cross-contamination in relation to vegan claims. Nonetheless, under the general provisions of the FIC Regulation27 and the UCPD,28 voluntary product information must not mislead the average consumer. Where consumers reasonably understand the term “vegan” to exclude even trace amounts of animal-derived substances, undisclosed cross-contamination may give rise to legal concerns. In this context, clear communication and appropriate disclaimers may be necessary to ensure compliance with the principles of transparency and fairness in food labelling. In the absence of binding legislation, many restaurants rely on private certification schemes, such as the V‑Label,29 the Vegan Trademark,30 or national certification systems (e.g. the certification provided by the Slovenian Vegan Society31), to demonstrate due diligence. These schemes define “vegan” in substantive terms, requiring products to be obtained and processed without animal‑derived substances and not subject to animal testing. They typically prescribe criteria for ingredient sourcing, preparation protocols, and prevention of cross‑contact. Although voluntary, such certification can serve as evidence of responsible practice and may mitigate liability risks by demonstrating compliance with consumer expectations in the event of complaints or regulatory inquiry. Some restaurants also include disclaimers such as “prepared in kitchens where animal products are used” to reduce legal exposure. The legal effect of such disclaimers, however, depends on how clearly and prominently they are communicated to the consumer. Disclaimers must not contradict or obscure other claims and must respect the principle of transparency under EU consumer law. 27 FIC Regulation, arts 7(1)(a) and 36(2). 28 UCPD, arts 5(1), 6 and 7. 29 European Vegetarian Union, Criteria for the V-Label (2024) https://www.v-label.com/criteria/ accessed 13 June 2025. 30 The Vegan Society, The Vegan Trademark https://www.vegansociety.com/the-vegan-trademark accessed 13 June 2025. 31 Slovenian Vegan Society, Veganski certifikati https://vegan.si/ziveti-vegansko/veganski-certifikati/ accessed 13 June 2025. 174 KATJA ŠTEMBERGER BRIZANI
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