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Consumers deserve accurate labels for dairy products, according to American Farm Bureau Federation

May 6, 2023

The American Farm Bureau Federation (AFBF) has filed comments with the Food and Drug Administration (FDA), calling on the agency to enforce food labeling standards for dairy substitute products and enforce existing prohibitions on the misleading labeling of nut- and other plant-based beverage products as 'milk'.

FDA requested comments on its draft Labeling of Plant-Based Milk Alternatives and Voluntary Nutrient Statements: Guidance for Industry.

AFBF supports a consumer’s right to access dairy-free products, but one in four Americans – 83 million people – are confused or have been misled about whether dairy alternatives contain milk, according to a survey used by FDA.

Non-dairy beverages are sold in the milk case alongside traditional milk, very often with labeling that implies they are dairy products. Nut- and plant-based beverages do not include several important nutrients that are found in cow’s milk, however.

“Consumers know the healthiness of dairy labels such as ‘milk’ and may infer that any product bearing this term possesses the same or an equivalent nutritional profile,” wrote AFBF Vice President of Public Policy Sam Kieffer. “In many other cases, consumers have been led to believe plant-based alternatives are healthier. As the draft guidance describes, ‘The research also suggests that a majority of consumers who purchase plant-based milk alternatives state they do so because they believe the products are healthier than milk.’ These conclusions demonstrate the dangers of utilizing the term ‘milk’ on non-milk products.”

AFBF urges FDA to require non-dairy products to be labeled accurately, as is required in several markets outside of the U.S. For instance, 'almond milk' is labeled 'almond beverage' in Canada. Applying the same standards in the USA should not be a heavy or unreasonable burden on companies.

FDA already requires truth in labeling for other foods. For example, products labeled as 'jams' must contain a minimum amount of fruit, and products that don’t meet a minimum standard for cheese must be labeled as 'cheese alternative' or 'cheese substitute'.

FDA’s proposed guidance for milk substitutes risks setting a precedent that could lead to many other dairy, meat, fruit and other food names to be misused for imitation products.

“The American Farm Bureau Federation believes that plant-based alternative milk products should adhere to current labelling laws and regulations and that consumers should be presented with accurate information on a product’s label so that they can make an informed choice about the wide range of attributes associated with milk and other dairy terms, including butter, ice cream, yogurt, etc.,” the comments continue. “We ask that FDA amend their draft guidance to prohibit the use of ‘milk’ or other dairy terms on non-dairy substitutes unless products follow proper use of imitation terminology, as defined by existing law. Allowing such changes runs the risk of undercutting the entire current FDA labelling framework for imitation products, to the detriment of farmers, honest processors, and all consumers.”

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