By Reed Mangels, PhD, RD

The Vegetarian Resource Group was recently contacted and asked this question, “Here’s a weird one: a product labeled as vegan, with no obvious non-vegan ingredients (that I see), but 15 mg cholesterol. Is the vegan label wrong? Am I misreading one of the ingredients? … What’s this all about?”

     A product that is truly vegan should not contain on the label any cholesterol, a substance produced by animals. Grains, legumes, nuts, fruits, vegetables, and vegetable oils do not have cholesterol or only contain insignificant amounts (more on this in a future blog posting). In order to address this puzzle, we need to consider where the nutrient amounts on nutrition labels come from.

     According to the FDA, the government agency responsible for food labeling, food manufacturers should have a laboratory analyze the nutritional content of the company’s product using specific tests. If the manufacturer of the product did this and determined that the product contained cholesterol, it could be due to contamination during production or it could be that the product contains small amounts of an animal ingredient that contains cholesterol and that the products should not be labeled as vegan.

     In place of costly laboratory analysis, manufacturers may choose to use existing nutritional data bases and programs to calculate the nutritional content of their food product. If a company use a nutritional data base to calculate the nutritional content, they input all the ingredients and amounts, and a program calculates the amounts of different nutrients in a serving of food. The manufacturer is responsible for the accuracy of the information on the nutrition label on their products so FDA states that calculated nutrient content should be validated by laboratory analyses (1).

     FDA discourages companies from merely copying a competitor’s label with the assumption that the products are similar. If FDA checked and found that a product’s composition did not agree with its nutritional label, the firm could not claim that it acted in good faith and should not be penalized if it copied information from a competitor (1).

     Misleading information can be generated when nutrient databases are used. Most programs provide users with a choice of ingredients when recipes are being inputted. An example of the kind of error that could be introduced – if an ingredient in a vegan product is pasta, and the person inputting the recipe into the program chooses a pasta that contains eggs instead of a vegan pasta as the ingredient, the recipe analysis would indicate that there is cholesterol in the product. If the company neglected to verify this information with laboratory analysis, incorrect label information could result. So, one possibility for there apparently being cholesterol in a product labeled as vegan is incorrect input of ingredients into a nutritional analysis program.

     The FDA does compliance checks in which they analyze food samples that have been randomly collected from lots of a food – a lot could be one day’s production. FDA takes 12 subsamples, combines them into one sample and analyzes the nutrient content of this composite. To be in compliance with FDA’s labeling regulations for cholesterol, the amount of cholesterol determined to be in the sample by lab analysis should be no more than 20% higher than what the label indicates is in the product. Having an analyzed amount of cholesterol below what is stated on the label, is “usually considered acceptable by the agency within good manufacturing practices (2).”

     Contacting the company may be helpful in determining the cause of the apparently incorrect label information and may alert the company to the need to correct either the “vegan” label or the amount of cholesterol shown on the label.

1. FDA. A Food Labeling Guide. Guidance for Industry. January, 2013. https://www.fda.gov/files/food/published/Food-Labeling-Guide-%28PDF%29.pdf

2. FDA. Guidance for Industry: Guide for Developing and Using Data Bases for Nutrition Labeling. 1998. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-guide-developing-and-using-data-bases-nutrition-labeling#Chapter_1

For more food labeling information see: https://www.vrg.org/ingredients/index.php

The contents of this posting, website, and our other publications, including Vegetarian Journal, are not intended to provide personal medical advice. Medical advice should be obtained from a qualified health professional. We often depend on product and ingredient information from company statements. It is impossible to be 100% sure about a statement, info can change, people have different views, and mistakes can be made. Please use your best judgment about whether a product is suitable for you. To be sure, do further research or confirmation on your own.