April 1, 2025
The Vegetarian Useful resource Group (VRG) welcomes the chance to touch upon Labeling of Plant-Based mostly Alternate options to Animal-Derived Meals: Steering for Business. We recognize FDA’s total dedication to having meals labels that present truthful info that helps shoppers make knowledgeable buying selections.
The marketplace for plant-based alternate options to animal-derived meals is increasing. In the USA, in 2022, the newest yr for which info is obtainable, the entire plant-based market worth was $8 billion. Gross sales of plant-based yogurt and plant-based cheese had a 20% and 42% enhance respectively in retail gross sales. Though gross sales of plant-based meat decreased barely (1%), the market worth of those merchandise was greater than $1 billion (1). As of now, there isn’t a particular steering for the wording that must be used on product labels of “plant-based alternate options.”
We agree with FDA’s suggestions that:
- When trying on the identify of the meals on the label, the patron ought to be capable of simply see that it’s plant-based and what the primary plant ingredient is.
- The meals label ought to embrace the particular plant supply(s) that the meals incorporates.
- If wording is used on the label that implies {that a} product isn’t derived from animals, it could be obligatory to point what the product is, and the particular plant sources used within the meals.
Customers who’re on the lookout for alternate options to animal-derived merchandise want to have the ability to simply determine these merchandise and to be assured that the merchandise don’t comprise animal-derived components. Customers with meals allergic reactions or intolerances should be alerted to the presence of frequent allergens.
Within the Questions and Solutions part of this doc, in response to query 8 (What are essential issues when labeling plant-based various meals as “vegan” or “meat-free”?), FDA says, “The usage of truthful and non-misleading label statements (e.g., “vegan,” “meat-free,” “animal-free”, and so forth.) that helps inform shoppers that the merchandise are derived from vegetation, and are usually not derived from animals, is suitable.” We agree with this however imagine that the steering must be expanded in order that merchandise that embrace any animal-derived components couldn’t be labeled “plant-based” as a way to cut back client confusion and keep away from deceptive shoppers.
We’re hopeful that steering can be supplied to business for labeling merchandise which might be produced by means of using genetic engineering and that comprise animal protein or are just like animal protein in construction. Clear labeling is required to assist defend individuals with meals allergic reactions who could also be misled by product labels containing statements not clearly informing shoppers that the merchandise are based mostly on animal DNA. Examples of the sort of deceptive label assertion embrace “animal-free” or “vegan.” We suggest that meals allergen info on these merchandise must be in readable sort and on a readable background, not solely within the ingredient itemizing but additionally together with another declarations on the labels which can be complicated to the patron associated to the presence of the allergen. These could possibly be when phrases are used similar to “animal-free” or “vegan.” We don’t assume that these phrases (“animal-free” or “vegan”) must be used on labels of meals that have been produced by means of genetic engineering based mostly on the DNA of animals (whether or not based mostly on precise DNA, cell strains, or digital DNA), as a consequence of concern for client confusion. Moreover, when a product relies on animal DNA, there must be an announcement on the label so individuals know that the product relies on animal DNA.
We not too long ago commissioned a nationwide You.Gov ballot of adults in the USA. We requested, “There are forms of meat and dairy alternate options which might be made utilizing NO animals (or animal merchandise) however are based mostly on animal cells or DNA extracted years in the past from a reside animal. In your opinion, ought to (they) Embrace an announcement on the bundle that informs shoppers that the product makes use of animal cell DNA or is animal gene-derived?” 72% mentioned sure, 10% mentioned no, and 18% didn’t know.
We additionally requested, “Which of the next, if any, do you anticipate from a meals labeled as a veggie burger? Please choose all that apply.” We discovered:
- 41% of respondents anticipated that the entrance of the burger bundle would determine the primary ingredient (similar to soy or beans) and say one thing like “black bean-based veggie burger.”
- 94% didn’t anticipate a product labeled as a veggie burger to comprise meat from a cow
- 94% didn’t anticipate a product labeled as a veggie burger would have comparable quantities of ldl cholesterol and saturated fats as the same animal-derived product
Our outcomes recommend that some, however not all, shoppers anticipate to have the primary ingredient of plant-based alternate options included on the label.
VRG is an unbiased non-profit group devoted to educating the general public on vegetarianism and the interrelated problems with well being, vitamin, setting, ethics, and world starvation. Our well being professionals, activists, and educators work with companies and people to result in wholesome adjustments in faculties, workplaces, and the group. Registered dietitians and physicians help within the improvement of nutrition-related publications and reply questions in regards to the vegetarian and vegan weight loss program. For the previous 31 years, we’ve commissioned polls exploring vegetarian-related points, outcomes of which are sometimes utilized by researchers, the meals business, and the media. Monetary assist comes primarily from memberships, contributions, and guide gross sales.
Thanks for the chance to touch upon the proposed tips.
Sincerely,
Reed Mangels, PhD, RD, Diet Advisor, The Vegetarian Useful resource Group
Charles Stahler and Debra Wasserman, Co-Administrators, The Vegetarian Useful resource Group
