There's no federal definition of "vegan" for food labels: FDA's 2025 draft guidance on plant-based foods says plainly that its regulations don't define "vegan" or "vegetarian", and uses the common meaning, that a vegan food contains no animal-derived products, no dairy, eggs, honey or anything else from an animal. So a vegan claim follows the general rule for every label: it has to be truthful and not misleading. The same draft guidance, which isn't final, recommends how plant-based foods should be named. Don't use "vegan" alone as the product's name, because it doesn't say what the food is made of; name the plant source, and when the name borrows a standardized food, like cheddar, qualify it by the plant source, as in "cashew-based cheddar", in bold on the front panel. "Vegan" is welcome as a claim beside it. Two practical checks sit under the claim: ingredients that can be animal-derived, like natural flavors, cultures, lactic acid or cane sugar filtered with bone char, need a supplier's statement, and plant ingredients still carry their own allergen declarations, tree nuts by the specific nut. In the example below, a plant-based cheese maker renames two products. Below are the rules, the checks, the example, and a free ingredient check.
The short version
- FDA regulations don't define "vegan"; the common meaning is no animal-derived products.
- A vegan claim has to be truthful and not misleading, like any label statement.
- FDA's 2025 draft guidance: don't use "vegan" alone as the product's name.
- Name the plant source; qualify a standardized name, like "cashew-based cheddar".
- The name goes in bold on the front panel.
- Natural flavors, cultures, lactic acid and cane sugar can be animal-derived: ask the supplier.
- Allergens still apply: "Contains: cashew", by the specific nut.
- TaroStack keeps each ingredient lot's supplier statement with the lot. More below.
The rules
| Rule | Where |
|---|---|
| Definition | FDA regulations don't define vegetarian or vegan; vegan is commonly used to mean no animal-derived products (FDA draft guidance, January 2025) |
| Truthful | A label false or misleading in any particular misbrands the food (21 U.S.C. 343(a)) |
| The name | Not "vegan" alone; identify the plant source (draft guidance) |
| Standardized names | A standardized food's name, like cheddar, qualified by the plant source (draft guidance) |
| Where | The statement of identity in bold on the principal display panel (draft guidance, citing 21 CFR 101.3(d)) |
| Allergens | Major food allergens declared; tree nuts by the specific type of nut (21 U.S.C. 343(w)) |
The draft guidance is FDA's current thinking, not a binding rule. How allergens are declared is in food allergen labeling requirements, and the front panel in principal display panel requirements. This is general information, not legal advice.
What to check
| Ingredient | Can come from | Check |
|---|---|---|
| Casein, whey, lactose, butter | Milk | Not vegan |
| Egg, albumin | Eggs | Not vegan |
| Gelatin | Animal bones and skin | Not vegan |
| Honey | Bees | Not vegan by the common meaning |
| Carmine, shellac, confectioner's glaze | Insects | Not vegan |
| Natural flavor | Plants or animals | Supplier statement |
| Cultures | Can be grown on dairy | Supplier statement |
| Lactic acid, stearic acid, mono- and diglycerides | Plants or animals | Supplier statement |
| Vitamin D3 | Lanolin or lichen | Supplier statement |
| Cane sugar | Can be filtered with bone char | Supplier statement |
A kitchen that also handles milk or eggs has an allergen question as well as a vegan one; how a precautionary line works is in may contain label.
An example: a Burlington plant-based cheese maker
Mill Pond Cashew Co., a made-up plant-based cheese maker in Burlington, Vermont, I use in these examples, redesigned its labels for a co-op chain and checked its three products:
| Old name | Problem | New name, in bold | Vegan check |
|---|---|---|---|
| Vegan Cheddar | "Vegan" alone, no plant source | Cashew-Based Cheddar | Lactic acid and cultures: plant, statements on file |
| Plant-Based Feta | No plant source | Almond-Based Feta | Natural flavor: waiting on the supplier |
| Cashew Chive Spread | None | Cashew Chive Spread | Nothing to check |
"Vegan" goes on the cheddar and the spread as a claim beside the name; the feta waits for its flavor supplier's statement before the word goes on. The allergen lines read "Contains: cashew" and "Contains: almond", by the specific nut. The kitchen handles no dairy, so there's no cross-contact line to add. What a recipe's ingredients are in label order is in ingredient list order.
Get the checker
Download the vegan label check. Two sheets: a watch list of ingredients that are animal-derived or can be, which you can add to, and your products, each ingredient looked up against it and marked not vegan, waiting on the supplier, or OK, with a verdict for each product. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A supplier's statement covers the lot it came with. When the flavor house changes its formula, or you switch to a cheaper culture, the statement on file belongs to the old one.
How TaroStack does it
TaroStack keeps each ingredient lot with its supplier, and fields of your own on the lot for its statement.
Suppliers and lots. Each delivery is received from its supplier with its lot, and fields of your own on the lot can hold "vegan statement on file" and its date.
Recipes with versions. Each product is a recipe by weight, and recipes keep their versions, so a switch to a new culture or flavor is on record.
Batches record their lots. Each batch records the ingredient lots it used, so the cultures in a given run of cheddar, and their supplier, are on record when a buyer asks.
| The job | Folder | In TaroStack |
|---|---|---|
| A supplier's vegan statement | A folder | A field on the lot |
| When the recipe changed | Memory | Recipe versions |
| Which culture lot went into a run | Not recorded | Lots on the batch |
| A new supplier's first delivery | An invoice | Its own lot, from its supplier |
Receiving, lots, recipes with versions, batches and your own fields are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.