The Vegetarian Resource Group (VRG) is an independent non-profit organization dedicated to educating the public on vegetarianism and the interrelated issues of health, nutrition, ecology, ethics, and world hunger. In addition to publishing the Vegetarian Journal, VRG produces books, pamphlets, and article reprints. Our health professionals, activists, and educators work with businesses and individuals to bring about healthy changes in schools, workplaces, and the community. Registered dietitians and physicians aid in the development of nutrition-related publications and answer questions about the vegetarian and vegan diet. Financial support comes primarily from memberships, contributions, and book sales.

We welcome the opportunity to comment on Use of the Names of Dairy Foods in Labeling Plant-Based Products. Many of our members follow a vegan diet and do not eat any animal products. They choose to follow this diet for a variety of reasons including health, ecological, and religious concerns, dislike of meat, compassion for animals, belief in non-violence, and economics. Other members of our organization may avoid dairy products due to health issues such as milk allergy or lactose intolerance. Members of our organization commonly use plant-based products (milks, cheeses, yogurts) in place of animal-based products. The plant-based products are used to add variety, to enable users to prepare foods similar to those made with animal-based products, and, in some instances, to supply nutrients such as calcium, vitamin D, vitamin B12, and protein.

Our understanding of dairy terms like milk, yogurt, and cheese when they are used to label plant-based products is that these products are plant-based alternatives to animal-based products. In many, although not all cases, plant-based products can be used in food preparation and will behave similarly to animal-based products. For example, plant-based cheese may be used to top pizza; plant-based milk used to make a cream soup. Just as different dairy milks and cheeses have different tastes, characteristics, and uses, so do plant-based milks. For instance, chocolate milk, even though it’s labeled as milk, would not be used to make a savory dish. Similarly, replacing Cheddar cheese with ricotta cheese in macaroni and cheese would result in a very different product. Despite these differences, these products are all identified as milk or cheese. Considering the wide variety of animal-based products identified as milk, cheese, or yogurt, it does not seem incongruous to also identify plant-based products as milk, cheese, or yogurt with a modifier identifying the main plant ingredient (e.g. soy milk, cashew cheese, almond milk yogurt).

The Nutrition Facts and ingredient list on food labels along with front of label information allows consumers to evaluate the nutritional characteristics of plant-based products. Our website, and those of other vegan organizations, encourage consumers to seek out plant-based products that are fortified with nutrients such as calcium, vitamin D, and vitamin B12 if they rely on these products as a source of these nutrients. Consumers are aware that there are nutritional differences between plant-based and animal-based products. We note that terms such as coconut milk and peanut butter have been used for many years without confusion as to their plant origins or to these products’ nutritional differences from cow’s milk or dairy butter.

We believe that prohibiting plant-food labels from including words like milk, cheese, and yogurt in the name of these products would lead to consumer confusion. We urge you to permit the labeling of plant-based products with names that include milk, cheese, and yogurt.

Thank you for the opportunity to comment on this issue.

Please note: The U.S. Food and Drug Administration is announcing its intention to extend by 60 days the comment period on the request for information on labeling plant-based products with names that include the names of dairy foods, such as “milk,” “yogurt,” and “cheese.” The original comment period was scheduled to end on November 27.