FDA Drafts Guidelines for Plant-Based Milk Labels

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The U.S. Food and Drug Administration released draft recommendations for the industry on the naming of plant-based foods marketed and sold as alternatives to milk on Wednesday. The draft guidance also advises the labeling of certain plant-based milk replacements with optional nutrient declarations.  

“Today’s draft guidelines were intended to help address the enormous surge in plant-based milk replacement products that we’ve witnessed over the past decade,” said FDA Commissioner Robert M. Califf, M.D. “Today’s proposed guidelines should result in unambiguous labeling that provides customers with the information they need to make informed nutrition and purchasing decisions on the items they buy for their families.”  

In addition to the increase in market availability and consumption, the variety of alternative products available on the market has greatly expanded to include cashew, coconut, flaxseed, hazelnut, hemp seed, macadamia nut, oat, pea, peanut, pecan, quinoa, and walnut-based beverages, in addition to soy, rice, and almond. Despite the fact that these products are made from liquid extracts of plant components such as tree nuts, legumes, seeds, and cereals, they are usually labeled as “milk.”  

The draft guidance, “Labeling of Plant-based Milk Alternatives and Voluntary Nutrient Statements: Guidance for Industry,” recommends that a plant-based milk alternative product that includes the term “milk” in its name (e.g., “soy milk” or “almond milk”), and that has a different nutrient composition than milk, include a voluntary nutrient statement that conveys how the product compares with milk based on the United States Department of Agriculture’s For instance, the label may state, “Contains less Vitamin D and calcium than milk.  

In September 2018, the FDA requested information regarding the labeling of plant-based milk alternatives (PBMA) with dairy product terminology, such as “milk.” The FDA received over 13,000 responses and decided that customers realize PBMA do not include milk and chose to purchase PBMA because they are not milk.

Nonetheless, many consumers may be unaware of the nutritional distinctions between milk and PBMA products. For instance, almond- or oat-based PBMA products may include calcium and be used as a calcium source, but their overall nutritional composition is not comparable to that of milk and fortified soy beverages, therefore thus are not included in the dairy group in the Dietary Guidelines 2020-2025.  

Dairy foods, especially milk, are suggested by the Dietary Guidelines as part of a balanced eating pattern and contain many essential nutrients, including protein, vitamins A and B-12, calcium, potassium, and vitamin D, which are under consumed at present. Because their nutritious makeup is comparable to that of milk, the Dietary Guidelines only include fortified soy drinks in the dairy group. However, the nutritional makeup of PBMA products varies significantly between and within varieties, and many do not contain the same quantities of essential elements as milk.  

Parents and caregivers should be aware that many plant-based substitutes lack the same nutrients as milk, according to Susan T. Mayne, Ph.D., director of the Center for Food Safety and Applied Nutrition at the Food and Drug Administration. “Food labels are an important tool to promote consumer behavior, so we advocate the adoption of voluntary nutritional statements to assist consumers in making more informed selections.”  



To promote uniformity across federal nutrition policies, the draft advice suggests that the industry utilize the Food and Nutrition Service’s fluid milk substitutes nutrient criteria to assess if a PBMA is nutritionally comparable to milk. In addition, the FDA urges customers to use the Nutrition Facts label to compare the nutrient composition of various products in order to make educated decisions.  

The FDA is seeking feedback on the proposed guidance. A manufacturer may opt to implement draft guidance recommendations before the guidance is finalized.  

Labels give essential information to help people choose healthier foods. It is a top priority of the FDA’s nutrition initiatives to ensure that Americans have easier access to healthier foods and nutrition information to assist them to make healthier choices. The draft guidance presented today does not apply to alternative plant-based cheese or yogurt products.

The FDA is in the process of drafting a guidance document to address the labeling and naming of other plant-based alternatives and will provide updates as they become available. 


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