Plant-Based Milk Labeling
Photo credit: Koliesnik

On February 23, 2023, the Food and Drug Administration (FDA) promulgated draft guidance on plant-based milk labeling, “Labeling of Plant-based Milk Alternatives and Voluntary Nutrient Statements: Guidance for Industry”, to provide the FDA’s view on the naming of plant-based food products that are marketed and sold as alternatives to milk (plant-based milk alternatives) and recommendations on the use of voluntary nutrient statements (FDA-2023-D-0451).

What is plant-based milk?

Plant-based milk has become increasingly popular due to its perceived health benefits and ethical considerations. Plant-based milk, also known as non-dairy milk or alternative milk, is a type of milk that is made from plants instead of animal milk.

Plant-based milk is typically consumed by individuals who are lactose intolerant or allergic to dairy products, as well as those who follow a vegan or vegetarian diet. Some common types of plant-based milk include almond milk, soy milk, coconut milk, oat milk, rice milk, and hemp milk.

These types of milk are made by blending the respective plant with water and then straining out the solids, resulting in a liquid with a similar texture and consistency to cow’s milk.

What is the FDA’s role in plant-based milk labeling?

The Food and Drug Administration (FDA) promulgates standards of identity for foods through formal rulemaking. FDA standards of identity establish a common name and content requirements for a food product, defining the composition of food and prescribing mandatory and optional ingredients. FDA can specify the amount of each ingredient the food must contain, fix the relative proportion of each ingredient, or prescribe a specific production method.

For marketing purposes, plant-based foods often use terms associated with animal-based products—for example, “milk” when marketing soymilk. Some dairy product producers claim that using the term may violate existing standards of identity for certain foods. Based on these allegations, these producers claim that dairy and egg product alternatives are misbranded.

What does the 2023 draft guidance on plant-based milk labeling attempt to do?

The 2023 draft guidance regarding plant-based milk would recognize that “soy milk”, “almond milk”, and other non-dairy milk are appropriate terms for plant-based, non-dairy food products. The guidance also proposes minimum vitamin D- and A-level enrichment in plant-based products.

However, the draft guidance recommends that plant-based products include nutritional comparisons between milk and plant-based milk in their nutritional statements.

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