August 31, 2023

Interpretive Summary: Dairy groups comment on the FDA’s draft guidelines for plant milk-alternative labeling

Dairy groups comment on the FDA’s draft guidelines for plant milk-alternative labeling 

By: Sydney Sheffield

The National Milk Producers Federation (NMPF) and the International Dairy Foods Association (IDFA) have submitted public comments on the United States Food and Drug Administration’s (FDA’s) draft guidance for plant milk-alternative labeling. 

“For far too long, plant-based beverage manufacturers have blurred well-defined standards of identity to inappropriately and unfairly capitalize on dairy’s nutritional benefits while the FDA has ignored its enforcement obligations,” said Jim Mulhern, NMPF president and CEO. “FDA’s draft guidance is an encouraging first step toward promoting labeling transparency in the marketplace, but it’s not enough. Our comments outline a solution to the misleading labeling practices existing in the marketplace today, and provide clear, truthful labeling options for marketers of plant-based beverages.”

The FDA guidance provides the FDA’s current view on the naming of plant-based foods that are marketed and sold as alternatives for milk and includes the FDA’s recommendations on the use of voluntary nutrient statements. According to the FDA, the industry’s use of voluntary nutrient statements would provide consumers with additional nutrition information to help them understand certain nutritional differences between these products and milk and make informed dietary choices. 

“IDFA recommends that the FDA continue and even enhance its efforts to educate consumers on how to use the nutrition facts panel (NFP). This will serve to improve the nutrition literacy of consumers and help them make more informed decisions based on their consumption preferences and individual dietary needs,” said IDFA in the comments. 

While both groups believe the FDA is taking the proper first steps at addressing the key differences in milk and plant milk alternatives, further action is needed. IDFA recommends the FDA suggest the inclusion of a disclaimer, such as “This product is nutritionally different than milk,” positioned in close proximity to the NFP to provide additional nutrition-related information to consumers. As a result, the disclaimer would hopefully prompt consumers who want to compare the nutritional value of milk and plant milk alternatives to use information that is already available on the NFP, which is where consumers are accustomed to looking for nutrition-related information on the foods they consider for purchase.

“In the absence of a full resolution of this issue that is focused on standards of identity – which NMPF will continue to work for via the DAIRY PRIDE Act and other vehicles – NMPF urges that any legally sound guidance, if such a thing is even possible, be focused on addressing consumer confusion and be forcefully implemented by the agency and taken seriously by the plant-based beverage community, so that we may at least improve consumers’ understanding in the marketplace,” said NMPF in the comments. 

Read NMPF and IDFA comments to the FDA.