Proposed Restrictions on the Use of Terms Such as “Burger” and “Sausage” for Plant Based Foods
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Adrian Ramsay MP co-signed this cross-party letter initiated by the Vegetarian Society.
LETTER TO MEMBERS OF THE EUROPEAN COMMISSION
From Members of Parliament of the United Kingdom
Re: Proposed Restrictions on the Use of Terms Such as “Burger” and “Sausage” for Plant Based Foods
06/12/2025
Dear Commissioners,
We write as members of the UK Parliament to express our deep concern regarding the proposed ban on the use of everyday, well-understood food terms, such as ‘burger’, ‘sausage’, and similar descriptors, when used for plant-based products. Although the United Kingdom is no longer a member of the European Union, our markets, companies, consumers, and regulatory conversations remain closely intertwined. Decisions taken at EU level continue to influence global norms, international trade, and the direction of sustainable food innovation.
We urge you not to adopt these restrictions, as we are deeply concerned about the significant global impact they could have. The evidence is clear: existing legislation already protects consumers; consumers themselves overwhelmingly understand and support current naming conventions; and new restrictions would undermine economic growth, sustainability goals, and the EU’s own simplification agenda.
1. Current legislation already ensures consumer protection
The Food Information to Consumers (FIC) Regulation provides extensive safeguards against consumer confusion. The European Court of Justice confirmed in Case C-438/23 that the current legislative framework is fully adequate to protect and inform consumers and to address misleading presentation when it arises1.
The Court also reiterated that existing rules already mandate transparency when expected ingredients are substituted - requirements that plant-based producers consistently follow.
This position has also been acknowledged at multiple points by the European Commission (see 2020 response2, 2022 response3 and 2024 response4).
2. Most consumers are not confused, however, a ban could increase confusion
1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:62023CJ0438
2 https://www.europarl.europa.eu/doceo/document/E-9-2020-004966-ASW_EN.html 3 https://www.europarl.europa.eu/doceo/document/E-9-2022-002681-ASW_EN.html 4 https://www.europarl.europa.eu/doceo/document/E-10-2024-002312-ASW_EN.html
Research consistently shows that consumers intentionally choose plant-based alternatives and do not confuse them with animal meat.
The Advocate-General’s Opinion (Capeta, 2024) explicitly warns that banning familiar food terms could increase confusion, not reduce it5. Empirical studies reinforce this finding:
• BEUC study (2020): ~80% support use of terms like ‘veggie burger’6 • Smart Protein (2023): Only 9% of consumers do not recognise plant-based meat alternatives7
• Germany (2022): 92% identify plant-based alternatives correctly8
• Spain (2021): Only 13% oppose plant-based use of traditional terms9 • Portugal (2021): >95% understand that plant-based alternatives contain no animal meat10
• Greece (2024): ~82% do not oppose current naming11
• Empirical study on label clarity (Gleckel, 2020)12
These findings show an overwhelming pattern; most European consumers understand the terminology for plant-based foods well.
3. The proposed ban undermines competitiveness, innovation, and the single market
Introducing a denomination ban would run counter to the EU’s commitments on simplification and competitiveness. It would create administrative burdens, force companies to redesign packaging, and generate inconsistencies across languages and Member States.
This is particularly problematic given the rapid growth of the plant-based market: • Europe remains the world’s largest consumer market for plant-based alternatives13
5
https://curia.europa.eu/juris/document/document.jsf?text=&docid=289831&pageIndex=0&doclang=en&mo de=req
6 https://www.beuc.eu/sites/default/files/publications/beuc-x-2020-
042_consumers_and_the_transition_to_sustainable_food.pdf
7 https://smartproteinproject.eu/wp-content/uploads/Smart-Protein-European-Consumer-Survey_2023.pdf 8 https://www.vzbv.de/sites/default/files/2022-
04/220307_IFH%20K%C3%96LN_Verbraucherzentrale_Kennzeichnung%20von%20Ersatzprodukten_final.p df9 https://proveg.com/es/wp-content/uploads/sites/2/2021/02/Resultados-estudio-nomenclatura-alimentos vegetales.pdf
10 https://www.atrevia.com/wp-content/uploads/2021/03/Relatorio_Upfield_FINAL_UCP.pdf 11 https://hellasveg.gr/wp-content/uploads/2025/05/survey-2024-final_EN.pdf
12https://ssrn.com/abstract=3727710
13 https://gfi.org/resource/plant-based-meat-eggs-and-dairy-state-of-the-industry-report
• The EU market grew 21% between 2020 and 202214
• Consumer trends show rising flexitarianism and reduced meat consumption15 • 31% of Europeans are reducing meat intake16
• Economic modelling demonstrates substantial opportunities: Plant-based dietary shifts could increase farm incomes by up to 71%17
• Alternative proteins could create 83 million jobs globally by 205018 • This sector is also a major opportunity for European farmers, with most crops used in plant-based dairy grown inside the EU (ProVeg International, 2022).
4. Plant-based foods support climate goals and European food security
Alternative proteins offer some of the highest emissions-reduction returns per euro invested, outperforming investments in electric vehicles and green building initiatives19.
They are also identified as one of the key ‘super-leverage points’ that can accelerate transitions across multiple sectors. Meldrum et al. (2023): The Breakthrough Effect.
Greater cultivation of pulses and legumes improves soil fertility and reduces fertiliser dependency, lowering production costs20,21. All of this shows that expanding plant-based options is aligned with environmental, economic, and food-security goals.
Conclusion
We recognise the importance of protecting consumers and ensuring clarity in food labelling. However, the evidence is unequivocal:
• Current EU law already provides full protection
• Consumers overwhelmingly understand and support the existing naming system • The proposed restrictions could damage competitiveness, innovation, and climate progress.
Clear labelling, not unnecessary terminology bans, is the best approach for consumers, producers, and the future of sustainable European food systems.
14 https://gfieurope.org/market-insights-on-european-plant-based-sales-2020-2022/ 15 https://smartproteinproject.eu/market-research/
16 https://europa.eu/eurobarometer/surveys/detail/2954
17 https://doi.org/10.1111/1477-9552.12530
18 https://www.climateworks.org/ginas-methane/
19 https://www.bcg.com/publications/2022/combating-climate-crisis-with-alternative-protein 20 https://doi.org/10.1016/j.ecolecon.2016.03.024
21 https://doi.org/10.1002/fes3.175
We therefore urge the Commission to reject these restrictions and maintain the current, proportionate, effective regulatory framework, which we firmly believe sets the global standard for best practice.
Yours sincerely,
Members of Parliament of the United Kingdom
Siân Berry MP
Irene Campbell MP
Jeremy Corbyn MP
Carla Denyer MP
Kerry McCarthy MP
Navendu Mishra MP
Adrian Ramsay MP
Alex Sobel MP
Also supported by:
The McCartney Family
