Government
FDA’s Plant-Based Milk Labeling Guidances: “Unprecedented, Unwarranted, and a Solution in Search of a Problem”
The Plant-Based Foods Association recently submitted a response to the FDA regarding its “Draft Labeling Recommendations for Plant-based Milk Alternatives…
The Plant-Based Foods Association recently submitted a response to the FDA regarding its “Draft Labeling Recommendations for Plant-based Milk Alternatives to Inform Consumers” paper which recommends that brands add nutrition statements comparing plant-based milk to milk from dairy cows. This move would be completely unique to plant-based milk and has been described by the PBFA as “unprecedented, unwarranted, and a solution in search of a problem.”
Taking a deep dive into the supposed evidence behind this guidance, the PBFA has lodged a Freedom of Information Act Request to access the consumer research employed by the FDA, and here shares the assessment compiled by Professor Joel H. Steckel of New York University’s Leonard N. Stern School of Business, scrutinizing the foundation of the FDA’s conclusions.
The report critically assesses six consumer research papers cited in the draft guidance, revealing a scarcity of scientifically valid evidence supporting the notion that consumers are in any way concerned or confused about the nutritional qualities of plant-based milk products.
A few key findings of the report:
- There is no science backing FDA’s conclusion: The FDA Summary tries to piggyback on studies that, by and large, do not have objectives related to consumer perceptions of relative nutrient content.
- Conclusions are confirmation bias: As Steckel states, drawing any conclusions about perceptions of relative nutrient content from reports at issue can only be the result of what is often referred to as “confirmation bias” on the part of the FDA.
- Research is out of date with today’s consumer: While the FDA asserts its guidance is intended for present-day consumers, the research reports referenced were conducted between 2017-2019. The plant-based milk industry has grown significantly from 2019 to present day, our 2022 U.S. retail sales data shows that from 2018 to 2022 alone, plant-based milk sales have grown from $1.6 billion to $2.8 billion and 40.6% of U.S. households are purchasing plant-based milks. The current U.S. consumer of plant-based milks has expanded significantly since these research reports were conducted.
PBFA’s Vice President of Policy, Nicole Negowetti, concludes: “The proposed guidance treats plant-based milk differently than any other foods. It is unprecedented and would create an unnecessary burden for all plant-based milk companies.” Given the flawed foundation of their conclusion, PBFA advocates for the removal of the nutrient statement from the FDA’s final guidance on plant-based milk labeling.
The complete report can be found here, along with PBFA’s comments to the FDA.
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