FDA suggests brands clarify ingredient sources on plant-based product labels – a shift some industry groups say may be burdensome to manufacturers and limit consumer choice.
FDA’s draft guidance, Labeling of Plant-Based Alternatives to Animal-Derived Foods, aims to alleviate confusion on food and beverage labels to “help ensure consumers have the information they need to make informed purchasing decisions,” according to the agency.
FDA cites current statements of identity for plant-based alternatives to eggs, seafood, poultry, meat and dairy products are “identified in multiple ways, sometimes inconsistently across a class or subclass.”
Plant-based milk alternatives are not addressed in this draft guidance, as the topic will be “addressed elsewhere,” according to FDA. In a hearing last December hosted by the Senate Committee on Health, Education, Labor and Pensions, agency officials stated that it is unlikely FDA will prohibit the use of ‘milk’ as a descriptor for plant-based alternatives “when adequately qualified,” as previously reported by FoodNavigator-USA.
FDA: Communicating plant sources on packaging will help consumers
To avoid confusion surrounding a food and its characterizing properties or ingredients, FDA recommends that companies clearly communicate the plant source comprising the food. For example, names like “plant-based burger,” “meatless meatballs,” or “vegetarian chickN sausage” should print the plant sources (e.g. soy, lentil, walnut, etc.) on packages to help consumers easily determine the product’s contents.
For products that use a mix of two or more plant sources, FDA recommends that the “predominant plant source by weight be stated first in the name of statement of identity.” Additionally, all plant sources must be declared in the ingredient statement as required by 21 CFR 101.4, according to FDA.
If an animal or meat is included in the labeling of a product, like ‘pork-free,’ FDA recommends that the plant-source (e.g. soy) should be on the packaging to “distinguish the product from other similar plant-based alternative foods.”
Modified spelling, like Chik’N or Cheeze, on packaging should also clarify the type of product and include the plant-source.
The statement of identity must be prominently printed in bold type at least half the size of the largest print on the primary display panel to help consumers identify the product.
While statements such as ‘vegan’ or ‘meat-free’ are truthful, FDA recommends including the plant source to clarify the statement of identity.
Plant-based foods should clearly communicate the characterizing flavor
Brands also can make statements on packaging to convey the flavor of a plant-based product if manufacturers ensure that these statements do not “communicate that animal-based ingredients are the source of the product when it is in fact plant-based.”
For example, a plant-based wheat jerky also can include the phrase “artificially beef flavored” to convey the characterizing flavor, according to FDA.
FDA recommendations may ‘create unnecessary burdens’ for manufacturers, consumers
While FDA’s draft guidance does “not establish legally enforceable responsibilities,” according to the agency, the suggestion to communicate plant sources in product names triggered concern.
Madeline Cohen, associate director of regulatory affairs for Good Food Institute, explained to FoodNavigator-USA that FDA could improve the proposed guidance by removing the plant source request. Cohen pointed out that the additional information is “readily available to consumers on the ingredients disclosure FDA already requires.”
Cohen added, “Consumers are accustomed to turning to the information panel for ingredients and allergen disclosures, and are well equipped to choose the foods that are best for themselves and their families.”
The Plant Based Foods Association argued FDA’s recommendations “are unfairly burdensome to plant-based food companies and treat plant-based products differently than other food in the market,” according to Marjorie Mulhall, PBFA’s senior director of policy. The trade group did not specify which suggestions it deemed unfair, however.
‘Plant-based’ an effective differentiator from animal products
Good Food Institute applauded FDA for “explicitly confirming” plant-based products can use the names of animal-derived foods (e.g. yogurt and cream cheese), said Cohen.
“FDA has refused to ban the use of meat, egg and dairy terms on plant-based product labels. FDA also recognizes that terms like ‘plant-based’ differentiate these foods from animal products,” Cohen said.
Public comments can be submitted on FDA’s website until May 5, 2025 using docket number FDA-2022-D-1102.
