The Food and Drug Administration has issued a notice inviting comments on the labeling of plant-based products with names that include the names of dairy foods such as “milk,” “cultured milk,” “yogurt,” and “cheese."  Think almond or soy milk. The FDA wants to know how consumers use these plant-based products and how they understand terms like “milk”  when included in the name of a plant-based product.  The FDA also wants to know whether consumers understand the differences between the nutritional content of plant-based products and their dairy counterparts. 

The FDA has issued this notice in order to "inform [its] development of an approach to the labeling of plant-based products that consumers may substitute for dairy foods."  It notes that "these products are often packaged in the same kinds of cartons, tubs, or bottles as their dairy counterparts and sometimes are sold in or adjacent to the dairy display in stores. However, these plant-based products may not have the same basic nature, essential characteristics, and characterizing ingredients as their dairy counterparts and may differ in their performance characteristics (e.g., physical properties, flavor characteristics, functional properties, or shelf life) such that they are not suitable substitutes for certain uses. Some plant-based products also may contain less nutrients than their dairy counterparts and may not meet the recommendation for dairy food group intake in the 2015-2020 Dietary Guidelines for Americans."  

As reported in an earlier blog post, this action follows the introduction of the Dairy Pride Act by Wisconsin Senator Baldwin that, if enacted, would "prohibit the sale of any food that uses the market name of a dairy product, is not the milk of a hooved animal, is not derived from such milk, and does not contain such milk as a primary ingredient."

Among the many topics that the FDA would like to see addressed in the comments are: do consumers purchase these plant-based products for use as substitutes for their dairy counterparts or for distinct uses? If consumers use these plant-based products as substitutes for dairy foods (for example plant-based beverages as alternatives to milk), what are their reasons? Do consumers think they are healthier, and if so, why?  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?

Comments are due by November 27, 2018. Instructions are included in the Federal Register Notice.