Almond milk, coconut cream or milk, soy milk, these are a few of the everyday names you see listed on plant based product label and right now the task to determine if plant based products will continue to use the term “milk” is under FDA review. Having the absence of “milk” a plant based ingredient statement may not be a big deal for the consumer, but from a company’s marketing perspective finding a replacement could be.
The FDA Code of Federal Regulations CFR 131.110, Title 21, defines milk as the lacteal secretion, practically free from colostrum, obtained by the complete milking of one or more healthy cows. Milk that is in final package form for beverage use shall have been pasteurized or ultra-pasteurized, and shall contain not less than 8 1/4 percent milk solids not fat and not less than 3 1/4 percent milkfat. Milk may have been adjusted by separating part of the milk fat therefrom, or by adding thereto cream, concentrated milk, dry whole milk, skim milk, concentrated skim milk, or nonfat dry milk.
What does this all mean and why is it now being challenged? This has been area of concern for US dairy farmers for some time and now legally challenging the issue to not allow “milk” to be associated with plant based products. I understand their argument and if I were a dairy farmer with my livelihood and income solely dependent on dairy milk, I would probably join in. Manufacturers of non-dairy products are utilizing the term to better connect the customer to their product, however ownership of the word “milk” is already taken and defined by the FDA.
What could this mean for the consumer? If the FDA agrees with the argument, then all reference to the word milk on a non-dairy plant based label would need to be eliminated or replaced. Is this a big deal? For the informed consumer, I don’t believe it is. For the manufacturer, it is and could represent a significant expense to brainstorm, create and re-teach a term for their product line. The marketing department will need to come up with a similar word that represents a connotation of milk. Once another term is approved, the manufacturer will need to change every label, brochure, advertisement and sales pitch that include that four letter word milk. Think about it, you’re participating in a brainstorm meeting and written on the whiteboard in bold red letters is the directive “come up with another name or term for milk for our line of products including almond milk and cream, soy milk and cream, cashew milk and cream” – you get the picture.
In the past and through other articles, I have stated that I am a advocate for “truth in labeling” and believe the consumer should be able to easily review a label to clearly understand what is inside the package and believe this issue falls into the same category. A manufacturer may want to look at this a marketing opportunity for their line of plant based product, by reaching out to their social media followers to submit new terminology for their vegan product line.
If passed, it could create a challenge to other non-dairy products such as almond butter, soy cream or even plant based “burgers.”
In working with with ice cream manufacturers outside of the US, one of the tasks at hand is to be sure their terminology on a label is accurate and follow within US label law. So if a coconut based product is labeled as ice cream, I notify the client the name needs to change and the same goes for a 6% milk fat product that is called ice cream. So the current challenge of no milk listed with plant based products seems basically the same issue.
If you not sure of what to name your non-dairy product, contact Darryl. He can help you better understand what a product can be called.
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