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Definitions of vegetarian and vegan (Sweden)

There are neither Swedish nor EU regulations, legal definitions or rules that explicitly concern vegetarian or vegan food. However, vegetarian and vegan foods are subject to the same rules and regulations that apply to all foods. Hence, Article 7.1 of Regulation (EU) No 1169/2011 is applicable stating that food information must not mislead the consumer. For example, the information on the packaging and labelling of a vegetarian or vegan product must be accurate, clear and easy for the consumer to understand and must not mislead the consumer as to the characteris-tics of the food, such as its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, method of manufacture or production. That a vegan diet is completely free of animal ingredients, including animal additives, can be considered established among Swedish consumers. Therefore, when the term ‘vegan’ or similar is used to describe a food product, no fur-ther explanation is deemed required. However, the fact that a product is vegan does not automatically mean that it is free from accidental contamination with or from allergens such as milk, but in such case, the accidental contami-nation would not be considered an ingredient. In Sweden, the term ‘vegetarian’ can have different meanings for different individuals and in relation to different foods. Some consumers associate the term with a diet that is completely free of animal ingredients, while others be-lieve that it is free of meat, poultry, and fish, but may contain, for example, eggs and milk. The Swedish National Food Agency differentiates between two categories of vegetarian diet on its website: lacto-vegetarian and lacto-ovo-vegetarian. The former is defined as a diet that includes vegetables and dairy products, while the latter is a diet that includes vegetables, dairy products, and eggs. Therefore, when the term ‘vegetarian’ is used to describe a food, it may be necessary to add further information to give the consumer a sufficiently clear idea of the nature of the food. The consumer must be able to distinguish it from other goods in relation to which it might be confused (see Ar-ticle 2.2 p and 17 of Regulation (EU) No. 1169/2011). The labels ‘vegan’ and ‘vegetarian’ are voluntary labels for companies to use. However, as mentioned above, it is im-portant to remember that none of these labels are allowed to be misleading. Whether the labels are misleading is a matter of judgement and may vary from case to case. It is thus recommended to carefully review the marketing and packaging of products to ensure that they are not considered misleading to the average consumer.

This is general information rather than legal advice and is current as of 30 May 2024. We recommend you contact a specialised food lawyer for legal advice for your particular circumstances to support commercial decisions which could impact your product or business.


Per Lidman

Sweden
SETTERWALLS