The US Food and Drug Administration (FDA) has released draft guidance for plant-based food companies on best practices for labelling alternatives to meat and fish, eggs, cheese and other plant-based products.

The draft guidelines, which are yet to be finalised and open to comments from industry, encompass recommendations on how to label and name a variety of plant-based alternatives to traditionally animal-derived products. The document covers alternatives to meat, seafood, eggs and dairy (excluding milk alternatives, which are being addressed separately).

According to the FDA, its new guidelines aim to “ensure food labels provide truthful, non-misleading and useful information, so that consumers can make informed purchasing decisions”.

The document states: “In this guidance, FDA provides its view on best practices for plant-based alternative food labels that are clear and accurate, to help enable consumers to quickly ascertain the attributes of products they are purchasing.  We are committed to accomplishing this by empowering consumers with more informative labelling to make informed dietary choices.”

As the predominant ingredients in plant-based foods – such as fungi, vegetables, legumes, grains and nuts – are diverse and can vary widely from product to product, the guidance emphasises that conveying the plant source in the naming of the product may provide clarity and help consumers understand how the nutritional composition of the product may differ from its animal-derived counterpart.

For example, it suggests a cashew nut-based cheese should be named ‘Cashew Cheese Spread’ or similar, rather than just using a generic ‘Plant-based Cheese Spread’ label. This may also provide support for consumers with allergies and allow people to identify the plant source more easily, the FDA notes.

Additionally, it acknowledges the use of modified spellings for naming plant-based alternatives to common meat and dairy products – such as ‘Chik’n’ and ‘Cheeze,’ advising that if these kinds of names are used, they should be accompanied by clear labelling that describes the nature of the plant source.

Where several plant sources are used, the FDA recommends that the predominant source by weight should be stated in the name or statement of identity, so consumers can easily identify the primary plant-based ingredients.

For products that blend two or more plant sources, it encourages brands to provide clarity with the predominant ingredient listed first – for example, an egg alternative product containing a blend of chia and flax seeds, with chia seeds as the predominant ingredient, could be labelled ‘Chia and Flax Seed Egg-less Scramble’. All plant sources must remain declared in the ingredient statement, as required by law.

If the labelling of a food refers to recognisable flavours traditionally derived from animal sources, such as a ‘beef-flavoured’ wheat-based jerky product, the FDA said manufacturers must ensure that they do not imply animal sources are used, highlighting the plant source and using statements such as ‘beef-free – artificially beef flavoured’.

The FDA emphasises that the product name or statement of identity should appear in bold type on the principal display panel and must be ‘reasonably related to the most prominent printed matter’ on the packaging.

FDA will continue to assess whether the naming and labelling of products complies with all relevant provisions of the Federal Food, Drug and Cosmetic Act on a case-by-case basis, considering the totality of the information.

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