Navigating the Vegan Logo Endorsement: Key Insights from the Food Safety and Standards (Vegan Foods) Regulations, 2022 and guidance

With the rise of veganism in India, the Food Safety and Standards Authority of India (FSSAI) introduced the Food Safety and Standards (Vegan Foods) Regulations, 2022 to govern the production, packaging, labelling, and sale of vegan foods in India. No food can be manufactured, marketed, sold, imported, or distributed as vegan unless it adheres to these regulations.

Vegan food refers to food or ingredients that do not contain products of animal origin, including additives, flavorings, enzymes, carriers, or processing aids.

Every vegan food package must display the approved Vegan Logo issued by the FSSAI. Below, we highlight essential takeaways which clarifies the endorsement procedures and requirements for businesses seeking vegan certification.

1. Understanding Product Eligibility

• Vegan by Default: Basic agricultural products such as rice, cereals, pulses, and oilseeds, or minimally processed products like wheat flour and oils, do not need a vegan logo.
• Mixed Products: If raw agricultural commodities are mixed without additional ingredients, they are also exempt from endorsement requirements.

2. Application and Payment Guidelines

• Separate Applications for Variants: Products with different flavours (e.g., plant-based drinks in multiple flavours) so also different products from the same manufacturing firm require individual applications for each varian/productst, as they will not be considered under a single application.
• Payment Process: The application fee by Food Business Operators (FBOs) seeking approval for endorsement of “vegan logo”  must be paid online through the e-payment portal provided by the FSSAI. Proof of payment must accompany the application.

3. Packaging and Labelling Flexibility

• The vegan logo is endorsed for the product applied for and a product approval means approval for all package sizes/measures irrespective of packing  materials (e.g., glass bottles, plastic jars).
• Unless the product’s composition or processing methods are change no reapprovals are required.
• Minor changes in ingredient levels, such as adjusting the amount of sugar or salt, do not necessitate re-submission of application, provided the core ingredients and processing methods remain consistent.

4. Manufacturing and Production Requirements

• Multiple Manufacturing Sites: If a retailer or marketer has a product manufactured at different facilities, separate applications must be submitted for each site.
• Shared Production Lines: Vegan products can be manufactured on the same production lines as non-vegan products, but thorough cleaning must be carried out following Good Manufacturing Practices (GMP). In such cases, the product label must clearly state:
  “Processed on the same line where other non-vegan products are processed.”

5. Restrictions and Compliance Standards

• Terminology on Labels: Terms like vegan salami, plant-based egg powder, or vegan bacon are prohibited. The vegan logo endorsement does not allow comparison to meat products in any sensory or functional manner.
• Prohibition on Cheese / Dairy Analogues: Products resembling milk or dairy items (e.g., cheese analogues) are not eligible for endorsement under the vegan regulations. The endorsement applies strictly to items with no animal-derived ingredients, additives, or processing aids, such as gelatin or bone char filters.
• Non-Compliance of CoA: A Certificate of Analysis (CoA) containing non-vegan parameters, like lactose or milk fat, will result in the rejection of the vegan logo endorsement.

6. Application Process and Refund Policy

• Submission Procedure: Applications must be submitted both in hard copy to the FSSAI office and in soft copy via email. Upon receiving the approval letter (Form-B), businesses must forward it to the relevant licensing authority through the FSSAI’s FOSCOS portal for the final endorsement.
• Refund Policy: Application fees are non-refundable, even if the application is closed by the authority.

Conclusion

The FSSAI’s vegan logo endorsement process ensures that only genuine vegan products carry the vegan logo, promoting consumer trust and transparency. These guidelines require businesses to carefully adhere to application protocols, labelling rules, and production standards. As the vegan market continues to grow in India, these regulations will help standardize the industry and ensure compliance.