Consumer eating habits are changing. As meat-reducing or -eliminating diets become more common, the need to ensure adequate sources of alternative protein becomes more apparent.
These alternative proteins come either through wholefoods (e.g. beans, legumes, cereals, grains, seeds, nuts, etc.); or via processed foods, such as tofu, tempeh, seitan, texturized vegetable protein (TVP), etc; or by using “other” or “novel” protein sources, such as spirulina, mycoproteins, insects, etc.
It’s a relatively new market, at least on a large scale. It’s also growing and changing fast as improvements in technology and food science result in improved flavour and texture.
New product segments tend to mean that regulation is low and a large amount of misinformation and marketing hype exists around these products. With low regulation also comes the risks of labelling and allergen issues, contamination and food fraud rise.
Managing the risks we know about
With any growing market, new risks are continually emerging. But, we can categorise those we know about into four groups:
- Microbiological risks could include –
- Pathogen risks.
These are particularly likely to occur where the items often contain more than one ingredient, or where it requires very specific methods of cooking/preparation to kill off unfriendly bacteria
- Risks relating to additives.
There is a need for greater clarity around antimicrobial additives used in the manufacture of plant-based proteins. This includes more certainty around the rigour of control in place to ensure quality.
- Pathogen risks.
- Chemical risks might cover –
- Toxic residues of pesticides on raw materials, or the need for toxic RNA removal, as well as the potential for concentration, contamination or allergens to sneak into the production line.
- Fortification risks, such as –
- Modern malnutrition occurs where the consumer opts for a socially or environmentally conscious diet, but fails to properly substitute the nutrients from animal protein or dairy. To avoid this, vitamin B12, iron, minerals and calcium are often added to alternative proteins. However, this adds another layer of complexity to production – some of these additional ingredients can have toxic components, some degrade rapidly within the foodstuff, some leave a taint, and some may not be totally vegan or allergen free.
- Risk of food fraud or malicious tampering –
- Cases of food fraud often rise when demand begins to outstrip supply. As the alternative proteins market is growing rapidly to meet consumer demand, it can be assumed that the market is particularly vulnerable to these risks at present.
Categorising the risks in this way provides a framework for producers to work through so that each may be addressed.
What it means to get it wrong
Rather than setting out strict definitions and rules to follow, the law (in the UK at least), simply requires that manufacturers do not deliberately mislead their customers when using the terms “vegan” or “vegetarian”.
As they are not operating within a rigid framework of standard, alternative protein manufacturers do not have the protection of adhering to it. Therefore, getting it wrong could not only have a strong effect on your client’s brand, but they could potentially also face in the UK:
- A claim under the Consumer Rights Act or the Sale of Goods Act for misdescription;
- An investigation by Trading Standards in relation to any descriptions applied to product packaging;
- An investigation by the Food Standards Agency or the Department for Environment, Food & Rural Affairs in respect of the food products themselves;
An investigation by the Advertising Standards Agency in relation to any promotional material used to promote the product(s).
Any or all of which could require payment of a financial penalty or of damages/compensation. Further, a particularly unfavourable result could necessitate an expensive product recall and/or the redesign of marketing materials/packaging, plus loss of consumer confidence.
Food production is one of the most complex infrastructure systems in the world. Navigating and managing risks in growing markets is fraught with complications, making the production process open to error.
Where the alternative protein market is concerned, we must first remember that not all protein is the same and measuring protein within foods in inconstant and not always reliable. To avoid issues such as modern malnutrition, manufacturers must ensure that protein levels in non-meat/non-dairy products are at acceptable levels. This adds another layer of complexity as recipes change and materials are added to fortify the product. However this, in turn, has its own complications – do the additives have a long-enough shelf life to reach the consumer intact? Are the additives 100 percent meat free? Etc. ?
We may not know the answers to those questions, but we do know that the consequences of getting it wrong can be severe – both in terms of brand reputation, financial penalties and expensive recall operations.