Labeling Plant-Based Dairy 1/28/19

The FDA has extended a public comment period titled “Use of the Names of Dairy Foods in the Labeling of Plant-Based Products.” If you are wondering what that means, I’m positive you’re not alone. I’ll go into the details here.

Dairy foods include things like yogurt, milk, cheese, and kefir. Basically anything that is commonly made with cow’s milk, although milk from other animals may be used. Plant-based dairy products are non-dairy alternatives like almond milk, coconut kefir, and vegan cheese that are made to resemble their dairy counterparts.

There has been a large expansion of these plant-based products in recent years. They are often sold in similar packaging to dairy products and in the same aisles or coolers. They’re also new enough that the FDA has not created standards of identity for them yet. These standards establish common names, define the nature of a product, and mandate ingredients. Before creating them, the FDA wants to address concerned that these products may differ in performance and nutrition enough that they aren’t really suitable substitutes for dairy. This may effect how they will be labeled in the future and whether their nutritional content will have to be changed.

As you can guess, there are some heavy incentives that divide the industry on this topic. Dairy producers would love it if alternative products could not use the terms “milk” or “yogurt.” On the other hand, producers of these plant-based alternatives definitely want to use these terms. Looking further ahead, the way these products are treated will have implications for plant-based products that are being developed and sold in other categories like veggie burgers or vegan eggs.

The current standards of identity for dairy products such as yogurt, cultured milk, and cheese require the use of milk. The FDA may decide that the plant-based dairy products can continue to be called things like “almond milk,” “coconut kefir,” or “vegan cheese” as long as they have the clarifier. But they might also decide that the current standard will have to be followed to a T and labels will have to be changed to “almond juice,” “cultured coconut drink,” or “vegan spread.” Disclosure: I do not work in Marketing for any of these products, and I’m sure someone could think of more appealing names.

Now this comment period will help the FDA make this decision as well as draft regulations and standards of identity. They are looking for the following information:

  • (A) Current market conditions and labeling costs
  • (B) Consumer understanding, perception, purchase, and consumption
    • Why do consumers purchase and consume these types of plant-based products?
    • Do consumers perceive these plant-based products to be more nutritious, as nutritious, or less nutritious than their dairy counterparts?
    • Do consumers perceive or expect these plant-based products to perform in the same manner as their dairy counterparts?
    • Do consumers perceive plant-based beverages to be different if the term “milk” is used instead of “beverage” or “drink”?
  • (C) Consumer understanding regarding the basic nature, characteristics, and properties
    • What do consumers believe are the main ingredients of plant-based products?
    • What is consumers’ understanding of the amount or proportion of plant-based ingredient(s) relative to other ingredients in plant-based products?
  • (D) Consumer understanding of nutritional content 
    • Do consumers expect certain nutrients to be present in both plant-based products and their dairy counterparts? Do these expectations change depending on the terms included in the names of plant-based products?
    •  Do parents and caregivers who purchase these plant-based products for young children or other family members believe that these plant-based products are nutritionally equivalent to their dairy counterparts and can replace them as a food choice?
  • (E) The role of plant-based products and dairy foods in meeting the recommendations in the Dietary Guidelines
    • Do consumers understand that certain plant-based products might have a nutritional content that is not adequate to place them in the dairy group?
    • Do consumers who purchase or consume plant-based products instead of dairy foods believe that these plant-based products meet the dairy group recommendation described in the Dietary Guidelines?

It’s a long list, but I’ve already cut it down to the most relevant questions for general consumers and highlighted the REALLY important ones. You can, of course, take a look at the full list by following the first link in the article. If you’d like to submit a comment, and I hope you do, go to this page and click on the “Comment Now!” button. Comments will be accepted until January 28th.

Until next time!

Image by: Mariana Medvedeva

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