Vegan cheese does not exist: legislation and food reality

Cheese is made from milk, cream or buttermilk, all of which are products of animal origin; otherwise, it is not cheese. Vegan cheese is a falsehood.

1. What is cheese, really?

According to the quality standard for cheese (RD 1113/2006¹), cheese is:

…a fresh or ripened product, solid or semi-solid, obtained from milk, whether whole or partially skimmed, from cream, buttermilk, or a mixture of some or all of these products, coagulated wholly or partially by the action of rennet or other appropriate coagulants, before whey drainage or after partial removal of the aqueous part, with or without prior hydrolysis of lactose, provided that the ratio of casein to whey proteins is equal to or greater than that of milk.

It is not legal to call “cheese” any product manufactured in Spain that does not comply with this quality standard, except for cheeses with PDO (Protected Designation of Origin) or PGI (Protected Geographical Indication), none of which are vegan.

2. What does cheese contain?

Only the ingredients permitted in the quality standard may be used:

2.1. Essential ingredients of cheese

• milk (which may be totally or partially dehydrated)
• cream
• buttermilk
• rennet
• lactic ferments
• molds, yeasts and microbial cultures

2.2. Optional ingredients of cheese

The following may also be added:

• salt
• flavorings
• spices and condiments (up to 30% by weight)
• sucrose (table sugar) and glucose (only in fresh and pasteurized white cheeses, up to 17% by weight)
• gelatin (up to 5 grams per kilogram)
• milk powder (up to 5% by weight)
• other dairy-derived products

Authorized additives are also permitted (those listed in Regulation 1333/2008²).

3. Cheese rind

Any other food product may be added, but only as part of the rind.

4. Prohibitions

The cheese quality standard expressly prohibits:

• The presence of fats, proteins, or both, other than those derived from milk itself
• The sale of cheeses with a milk dry extract lower than 15%

It is therefore clear that cheese is made from milk (or certain derivatives). But what is milk, legally speaking?

5. What is milk, really?

According to Regulation (EC) No 853/2004³, raw milk is:

…produced by the secretion of the mammary gland of farmed animals, which has not been heated above 40°C nor subjected to any treatment with an equivalent effect.

In other words, milk is not made from soy, lupins or other plant-based ingredients; it is a secretion of the mammary gland of animals.

6. Consumer deception

According to Regulation (EU) 1169/2011⁴, Article 7(1), the information provided to the consumer must not be misleading:

…as to the characteristics of the food, and in particular its nature, identity, properties, composition, quantity, durability, country of origin or place of provenance, and method of manufacture or production…

Products incorrectly labeled as “vegan cheese” do not have the regulatory nature, qualities or composition of cheese.

It must also not mislead:

…by suggesting, through appearance, description or pictorial representations, the presence of a particular food or ingredient, when in reality a component naturally present or normally used has been replaced by another…

So-called “vegan cheeses” do not contain the main ingredients of cheese (milk, cream or buttermilk), which are replaced by other substances (soy, lupin, etc.).

Therefore, no product can legally be called “vegan cheese”, because it misleads the consumer.

7. Conclusions

• Cheese is made from milk and dairy derivatives
• The so-called “vegan cheese” misleads consumers
• It is not legal to label any food product manufactured and sold in Spain as “vegan cheese”

8. References

https://www.boe.es/buscar/act.php?id=BOE-A-2006-17436
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R1333-20240423
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0853-20230215
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02011R1169-20180101