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Plant-Based & Vegan Claims Verification Checklist
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Substantiate plant-based and vegan claims, covering ingredient verification, animal-derived processing aids, cross-contact controls, and truthful non-misleading labeling.
21 CFR 101FTC Guides
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Claim Definition & Substantiation
- Is the intended claim (vegan, plant-based, 100% plant-based) clearly defined and substantiated? *
- Is the claim truthful and not misleading to consumers? *
- Is documentation retained to support the claim if challenged? *
Ingredient Verification
- Are all ingredients confirmed to be free of meat, dairy, egg, fish, and other animal-derived components? *
- Are hidden animal-derived ingredients (gelatin, casein, whey, carmine, honey, shellac) screened out? *
- Are supplier statements obtained confirming vegan or plant-based status of each ingredient? *
Processing Aids & Fortification
- Are processing aids (e.g., animal-derived enzymes, isinglass, bone char sugar) evaluated for animal origin? *
- Are added vitamins (e.g., vitamin D3, B12) verified as plant or synthetic in origin where a vegan claim is made? *
- Are fermentation-derived or precision-fermentation ingredients disclosed appropriately?
Cross-Contact Controls
- Are production controls in place to prevent contact with animal-derived materials on shared lines? *
- Is equipment cleaned and, where needed, verified between animal-containing and vegan production? *
- Is any shared-equipment advisory statement used truthfully?
Labeling Compliance
- Does the label comply with standard of identity and naming requirements for plant-based analogs? *
- Are nutrient content and comparative claims accurate and substantiated? *
- Are third-party vegan certification marks used only when certification is current?
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