Draft Guidance for Industry: Labeling of Plant-Based Milk Alternatives and Voluntary Nutrient Statements

The demand for plant-based milk substitutes has been expanding quickly, and a variety of vegan sources have been investigated, including but not limited to soy, almond, cashew, oat, walnut, and peanut. Many of these substitutes don’t have the same nutritional profile as milk, and some don’t contain all the necessary nutrients in the same proportions. The FDA has ordered voluntary statements to be included on the front labels of such products, comparing the availability of their nutritional components with that of milk, in order to help consumers understand their nutritional preferences while purchasing plant-based milk alternatives.

However, the FDA has also decided that plant-based producers may continue to label their products as “milk” as long as they are mentioning their nutritional symmetry with milk, for example, by labeling the product with lines like “contains a lower amount of vitamin D, calcium, or any other nutrient than milk.”

The placement of such lines on the front label, which attracts the customer’s attention first, will eventually cause them to reconsider future purchases of plant-based milk substitutes. Brands would have a very difficult time competing with real milk, which is a lacteal secretion free of colostrum. It is anticipated that the brands will either work to develop blends of milk substitutes sourced from various plants or they will choose to label their products as beverages or drinks rather than milk.

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