By Lydia Palmese, Copy Group Executive
We’re starting to see ‘vegan’ claims appearing in ads and it can be an area that seems abstruse and hard to define universally. For many, ‘vegan’ means the product doesn’t contain any animal products. Simple, right? Well, not when you start to think about it, which is exactly what we’re doing. For example, a cosmetic product might contain insect shells to produce certain colours, but a clearance exec. or specialist consultant might not expect insects to come under the heading of ‘animal products’, so wouldn’t flag this up. Similarly, we might be on the lookout for this, but won’t know the technical name when we see it.
This whole issue falls under BCAP’s 3.1: Advertisements must not materially mislead or be likely to do so. To help make this easier and to adopt a fair and consistent approach to these claims, we have decided to use the Vegan Society’s definition of ‘vegan’. As an international trademarking company for vegan products, we consider that their definition is reliable.
Click here to read the full definition of what constitutes a vegan product. In a nut shell, here’s the definition we’re working with:
A. ‘animal’ is understood to reference the whole, non-human, animal kingdom, including all vertebrates and all multicellular invertebrates.
B. This product and its ingredients have not been cross contaminated with animal ingredients. Foods have been prepared separately to non-vegan foods.
C. The manufacture and/or development of this product and its ingredients has not involved the use of animal products, by products, or derivatives.
D. The manufacture and/or development of this product and its ingredients has not involved testing on animals in any form by the manufacturing company, on the company’s behalf, by other parties controlled by the company, or outside suppliers not controlled by the company.
E. That any genetically modified organisms have not involved animal genes or animal-derived substances.
To help put this in context, let’s say you have a moisturiser which is claiming both ‘vegan’ and ‘no animal by-products’. You’ve consulted the substantiation (this will probably include, but not be limited to: certificate of analysis, full ingredients, production methods supplied by either the advertiser or the manufacturer) and see that this product has been, or contains ingredients that have been, tested on animals. So, according to our definition from the Vegan Society, the moisturiser cannot claim to be ‘vegan’, but can claim ‘no by-products’.
We’re not suggesting that products get certified before making this claim. Vegan can be quite a lengthy list of do’s and don’ts, so to make sure things don’t get overlooked and help prevent misleading consumers, this is the definition we’re working to.
We’ll now be asking agencies and advertisers making the ‘vegan’ claim to complete a confirmation letter. In some cases, we may ask an independent, specialist, consultant to review the evidence against this checklist. Like any assessment from a consultant, this process may require additional time and substantiation.
You will be able to review this information in our Notes of Guidance (under “3.9 Substantiation” within “3. Misleading”) and the Vegan Society has a detailed website for more information on methods and standards.