Draft guidance released Monday by the Food and Drug Administration recommends that primary labeling for plant-based alternatives include more detailed information about the ingredients used to better inform consumers.
The guidance is intended to help manufacturers ensure plant-based products are not misleading and accurately describe the items. Plant-based alternatives to eggs, seafood, poultry, meat and some dairy products are included under the guidance.
This latest update does not pertain to plant-based milk alternatives. FDA released draft guidance on labeling for these products in 2023.
The guidance does not create legally enforceable rules; instead, it describes the administration’s current thinking on the issue. It's not clear what direction the Trump administration will take.
Demand for plant-based alternatives has increased over time, with U.S. retail plant-based food dollar sales growing from $5.5 billion in 2019 to $8.1 billion in 2023, according to the FDA guidance. More products have also been added to the market in recent years.
However, the range of ingredients used in these products can vary and include legumes, grains, starches, vegetables tree-nuts, and more.
The guidance sets out to clarify exactly what ingredients are used in each product, and emphasizes the potential nutritional differences between plant and animal-based products. This could help consumers better identify potential food allergens and items that fit best within their diet.
Many plant-based products do not have a common or usual name established by federal regulations, or an established definition. Therefore, FDA recommends products be labeled with a “statement of identity that accurately describes the food.”
Manufacturers could still use names of animal-based foods in the statement of identity, but it must not cause the labeling to be misleading, according to the guidance.
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The labeling must follow existing regulations that require the statement of identity to be presented in bold type on the “principal” display panel in a reasonably sized font.
“The labels of many products prominently display brand names and statements that the food is plant-based but do not conspicuously disclose the nature or source of the food,” according to the guidance. “Consumers should be able to readily observe this information when reading the label.”
For example, rather than just labeling a product as “plant-based fish sticks,” the FDA recommends that manufacturers include the exact ingredients used. So, for example, the label could read “plant-based chickpea & lentil-based fish sticks."
Given that many animal-based alternatives include a mix of ingredients, FDA also recommends the primary types of plant sources be included, with the most dominant ingredient by weight listed first.
For example, a plant-based egg alternative with a chia and flax seed blend that has more chia seeds by weight could be labeled as “chia & flax seed egg-less scramble” on the front of the carton.
Some products have names with modified spelling for animal-based products like Chik’n, Be’f or Cheeze. The guidance appears to allow for these spellings to continue but the labels must also accurately reflect the exact plant sources.
The Good Food Institute's Madeline Cohen, associate director of regulatory affairs, said the guidance "recognizes that consumers are increasingly choosing plant-based foods for a variety of reasons, including dietary restrictions, allergies, religious practices, and ethical concerns. But the recommendations create unnecessary burdens for plant-based producers that may make it more difficult to keep their products on grocery store shelves."The guidance "does not point to any evidence that consumers are confused about the ingredients used in plant-based meat, egg, and dairy products," Cohen said. "FDA already requires ingredients and allergens to be clearly declared on these products’ labels and on all packaged foods. There is no basis for singling out plant-based products for more restrictive labeling."The institute promotes non-meat-based protein alternatives.
