Source of Truth – The Contradiction

Last week, we wrote about a vitamin D3 ingredient sold as vegan that carries animal testing data. The most common response we had was a version of the same question: Is that actually a breach, or is it simply awkward?

It is a breach, and the reason is worth setting out properly, because it changes what a vegan logo on a pack is supposed to mean.

What the schemes require.

People tend to assume a vegan certification is a composition standard. No animal-derived material in the product, no animal-derived processing aid, and the test is passed. Composition is certainly part of it. It has never been the whole of it.

Recognised vegan certification schemes also prohibit animal testing. The specific wording differs between schemes, and so does the scope, with some extending the prohibition to testing commissioned by third parties on the certified party’s behalf and some setting a cut-off date. What does not differ is the principle. Animal testing is incompatible with vegan certification, and a certified party is required to confirm that none has taken place in connection with the certified product.

That is not an accident of drafting. Veganism as a consumer proposition has never been only about what is in the jar. It is about what was done to get it there. A scheme that certified composition alone while ignoring testing would be certifying something its own customers would not recognise as vegan.

Why this makes the vitamin D3 situation a contradiction.

Once you accept that testing is a condition rather than a bonus, the position becomes very simple. An ingredient with published animal testing data cannot simultaneously satisfy the terms of a vegan certification. If it holds one, something has gone wrong with the other, and there are only three possibilities.

• The testing was not disclosed at the point of certification, which means the certificate was issued on incomplete information.
• It was disclosed and the certification was issued anyway, which means the scheme is not being enforced.
• It sits just outside the scope that particular scheme happens to cover, which means the certificate is technically valid and still does not mean what the consumer reading the logo believes it means.

Each of those is a problem for the brand buying the ingredient, and they are problems of a different kind. The difficulty is that the certificate looks identical in all three cases. A brand cannot tell them apart from the paperwork alone.

Plant-source, vegan and cruelty-free are one claim, not three.

There is a habit in our industry of treating them as three boxes on a specification, each ticked by a different document. It is convenient, and it is wrong.

A consumer buying a vegan product is buying one idea. Nothing from animals, and nothing done to animals. They do not separate the claims, because from where they are standing the claims were never separate. If one of the three fails, all three fail, and it does not matter which box was ticked or which document supported it.

This is the part that catches brands out. A company can be scrupulous about composition, hold every certificate correctly, and still find the promise on its pack does not survive contact with the supply chain behind it.

What a certificate can and cannot tell you.

A certificate tells you that a policy exists and that a submission was made against it. That is genuine evidence and we are not suggesting otherwise. What it cannot tell you is what was in the submission, what sat outside its scope, or what has happened since it was issued.

Closing that gap does not require a compliance department. It requires asking the supplier directly for two things.

• A written statement, at company level, that no animal testing has been conducted or commissioned on the ingredient.
• Documentation of the origin and processing route, so that the statement can be placed against something concrete.

A supplier with nothing to hide sends both without hesitation. How quickly they arrive tells you most of what you need to know.

Where does this leave the category?

It is worth remembering who is at the end of this chain. Vitamin D is the one supplement public health advice actively tells people to take through the winter, because between October and early March, the sun at this latitude carries too little UVB for the body to make its own. NHS guidance is a daily 10 micrograms for everyone aged one and over across those months, and the national survey data behind it shows why, with 18 per cent of adults aged 19 to 64 below 25 nmol/L.

So the person buying a vegan vitamin D3 product in November is not making an indulgent purchase. They are following the advice, and they have chosen the vegan version deliberately. Both of those things make the accuracy of the claim matter more, not less.

Vitamin D3 is entering the quarter that matters most to it, and the brands selling it are the ones most exposed if a sourcing question surfaces mid-season. The useful response is not alarm. It is a short list of questions, asked once, answered in writing, and then not worried about again.

Next week we set out where genuine plant-source vitamin D3 actually comes from, and give you those questions in full.

To discuss plant-source Vitamin D3V® for your next formulation, or to request our written animal testing policy, speak to the ProTec Nutra team.