FDA releases Draft Guidance on Labeling of Plant-Based Alternatives to Animal-Derived Foods

The US Food and Drug Administration (FDA) has issued draft guidance outlining best practices for the labeling of plant-based alternatives to animal-derived foods. The document provides recommendations to ensure that product names and labels are clear, accurate, and non-misleading, helping consumers understand the nature and source of these foods.

The guidance, published in January 2025, focuses on plant-based alternatives to eggs, seafood, poultry, meat, and dairy products (excluding plant-based milk alternatives, which are addressed separately). It offers clarity on how companies should name and describe these products to prevent consumer confusion while supporting informed purchasing decisions.

The FDA emphasizes that plant-based alternative foods do not have standardized definitions under existing food regulations. As a result, manufacturers are advised to adopt labeling practices that clearly communicate the plant source of the product.

Labels should indicate the primary plant ingredients, such as soy, pea, or almond, in addition to the product’s name. For example, a product might be labeled as 'Soy-Based Burger' or 'Almond Cheese Spread' to ensure clarity. The FDA also advises against misleading naming practices, cautioning companies against using terms that closely resemble traditional animal-derived products without proper qualification. Instead of simply calling a product 'Cheddar', for instance, the agency recommends using names like 'Chickpea-Based Cheddar'.

The guidance also addresses the use of modified spellings and creative naming conventions. While some brands use terms like 'Chik’n' or 'Be’f' to indicate a plant-based alternative, the FDA suggests that such names should be accompanied by a clear statement of identity to prevent consumer misunderstanding. Additionally, the agency underscores the importance of nutritional transparency, stating that labels should not imply plant-based alternatives are nutritionally identical to their animal-based counterparts unless scientifically supported.

The document also provides recommendations on the size and placement of labels. The primary display panel must prominently feature the product’s identity, ensuring consumers can easily recognize its composition and intended use. The FDA suggests that statements of identity should be in bold type and sufficiently large so that they are immediately visible to shoppers.

The FDA highlights the increasing popularity of plant-based alternatives, with US retail sales growing from US$5.5 billion in 2019 to US$8.1 billion in 2023. This expansion has led to greater product diversity but also raised concerns about consumer clarity in labeling.

“Consumers should be able to quickly and easily determine what they’re purchasing,” the guidance states. “Providing clear information about the plant source helps shoppers align their choices with dietary preferences, nutritional needs, and ingredient sensitivities.”

The document also acknowledges that many plant-based products are designed to replicate the flavor, texture, and appearance of animal-based foods, which can make labeling more complex. However, it stresses that accurate descriptions are essential for transparency and compliance with the Federal Food, Drug, and Cosmetic Act.

The draft guidance has been welcomed by some industry stakeholders as a step toward standardizing labeling practices, though some concerns remain. While clarity in product descriptions can aid consumers, some manufacturers worry that stringent naming guidelines could limit marketing flexibility.

A spokesperson from a leading plant-based food company commented, “Clear labeling is important, but overly rigid rules could make it harder for consumers to recognize products that fit their preferences. The balance between transparency and marketability is key.”

Meanwhile, consumer advocacy groups support the FDA’s effort to prevent misleading labels. “Many shoppers assume plant-based alternatives have the same nutritional profile as animal products, which isn’t always the case,” said a representative from a nutrition research organization. “Stronger labeling practices will ensure consumers get the information they need.”

The FDA is seeking public comments on the draft guidance for 120 days following its publication in the Federal Register. Stakeholders, including food manufacturers, retailers, and consumers, are encouraged to provide feedback through the official regulatory portal.

While the guidance does not establish legally binding requirements, it reflects the FDA’s current thinking on best practices for labeling plant-based alternatives. The final version of the guidance will be shaped by industry and public input.

For more details, the full FDA draft guidance can be accessed here