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, environment, ethics, and world hunger. 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. For the past 25 years, we have commissioned polls exploring vegetarian-related issues, results of which are often used by researchers, the food industry, and the media. Financial support comes primarily from memberships, contributions, and book sales.  

We welcome the opportunity to comment on Horizontal Approaches to Food Standards of Identity Modernization. We commend FDA for their commitment to protecting consumers against economic adulteration; maintaining the nutritional integrity of food; and providing flexibility to encourage manufacturers to produce more healthful foods. As a consumer organization, we also prioritize providing clear, helpful label information that consumers can use to make an informed choice and to be able to find the foods that they are looking for. It is important for Standards of Identity to be modernized so that label information is relevant to today’s consumers.

We recognize the need to update Standards of Identity. Regardless of the approach used to update these Standards, it is important to meet the needs of a variety of consumers.  We have both specific and broader suggestions for meeting the needs of vegetarians, vegans, and those who wish to eat vegetarian and vegan foods.

According to our most recent poll (1), about 4% of adults in the United States consistently follow a vegetarian diet, about half of these are vegan and do not eat any animal products. People choose to follow vegetarian or vegan diets for a variety of reasons including health, ecological, and religious concerns, dislike of meat, compassion for animals, belief in non-violence, and economics. Many other people avoid dairy products and/or meat products due to environmental concerns; health issues such as allergies, lactose intolerance, or hypercholesterolemia; or for other reasons. Our most recent poll (1) finds 46% of American adults sometimes or always eating vegetarian (including vegan) meals. This segment is likely to increase since 60% of 18-34 year olds always/sometimes eat vegetarian (including vegan) meals when eating out. Clearly, a large and growing segment of the population needs products to be labeled in a way that meets their needs as consumers of plant-based products.

Vegetarians and those interested in reducing animal product consumption commonly use plant-based products (milks, cheeses, yogurts, meats) 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. Label information should allow consumers to recognize plant-based products that replace meat or dairy products using familiar words like “burger,” “milk,” “cheese,” or “bacon.”

Our understanding of dairy terms like milk, yogurt and cheese, and meat terms like burger, sausage, or bacon, 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). Similarly plant-based meat replacers could be identified as “soy burger,” “tempeh bacon,” or “tofu-based sausage.”

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, burgers, sausage, 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, burgers, sausage, and yogurt.

Our suggestion for allowing for increased flexibility and for providing useful information is to use standardized label terminology. The following terms are proposed:

• Plant-based: Used to indicate a product that contains exclusively ingredients not originating from animals
• Mainly plant-based: Used to indicate a product that contains mainly ingredients not-originating from animals
• Animal-based: Used to indicate a product that contains mainly or exclusively animal-based ingredients
• Vegan: Used to indicate a product that
  • Does not an contain animal products (meat, fish, fowl, dairy, eggs, and honey) or ingredients derived from animals such as vitamin D3 from lanolin
  • Is not produced with animal-based processing aids or with processing procedures using animal products such as bone char for cane sugar
  • Does not contain insects or insect-derived ingredients, or insect secretions
  • Does not contain animal genes and is not genetically derived from animals

Nutrient Content Claims such as “high in” or “good source of” could be used to indicate plant-based or vegan products that provide significant amounts of key nutrients such as calcium, vitamin D, iron, and vitamin B12 that consumers may expect to be in animal-sourced products.

Thank you for the opportunity to comment on this issue.

References

1. Stahler C. How many adults in the U.S are vegetarian and vegan? How many adults eat vegetarian and vegan meals when eating out? Asks the Vegetarian Resource Group. https://www.vrg.org/nutshell/Polls/2019_adults_veg.htm Published 2019.