Got (Almond, Soy, Oat, Cashew, Pea…) Milk?

Use of the term “milk” in plant-based beverages over the years has been a nutty landscape for some and highly debated. However, with an increase in market availability and consumption, the types and varieties of alternative milk products has continued to expand from soy, almond and rice milk to cashew, coconut, hazelnut, hemp seed, oat, pea and other liquid-based extracts of plant materials including from nuts, seeds, grains, and legumes. These products are frequently identified with names that include the term “milk.”

Regardless of which beverage you choose to quench your milk thirst (or to dunk that cookie!), FDA’s issuance today of draft recommendations for industry on the naming of plant-based foods that are marketed and sold as alternatives to milk is intended to highlight the nutritional differences between milk and plant-based milk alternatives and to help support consumer behavior to make informed decisions and. FDA Commissioner Dr. Robert M. Califf stated, “The draft recommendations issued today should lead to providing consumers with clear labeling to give them the information they need to make informed nutrition and purchasing decisions on the products they buy for themselves and their families.”

The draft guidance, “Labeling of Plant-Based Milk Alternatives and Voluntary Nutrient Statements: Guidance for Industry” recommends that a plant-based milk alternative product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 (such as “almond milk”) and that has a nutrient composition that is different than milk, include a voluntary nutrient statement that conveys how the product compares with milk, based on USDA’s Food and Nutrition Service fluid milk substitutes nutrient criteria. For instance, the label could state “Contains lower amounts of calcium than milk.”

FDA’s draft recommendations are intended to highlight that while plant-based milk alternatives may contain certain desired nutrients, their overall nutritional content is different than milk and fortified soy beverages, and there is significant variety within and across types. Plant-based milk alternatives are also not included as part of the dairy group in the Dietary Guidelines 2020-2025, which recommends dairy foods, including milk, as part of a healthy eating pattern for key nutrients such as protein, Vitamins A and B-12, calcium, potassium and Vitamin D. In addition to the voluntary labeling statement, FDA recommends that consumers use the Nutrition Facts label to make comparisons in nutrient content of different products.

FDA is accepting comments on the draft guidance. Manufacturers are advised that they can elect to adopt the recommendations in the draft guidance now or wait until the guidance becomes final, but industry may very well usher compliance sooner than FDA does.

Note also that the draft guidance does not apply to other plant-based dairy alternatives such as plant-based cheese or yogurt alternatives. More on that is expected in due course.