Open Letter

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).

Most consumers are not confused, however, a ban could increase confusion

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
• 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 costs^20,21.

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.

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 (Sir Paul, Mary and Stella McCartney)

References

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

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.pdf
⁹ 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
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