February 20, 2023

The Vegetarian Resource Group (VRG) welcomes the opportunity to comment on the proposed revision in the WIC food package. We especially appreciate the greater flexibility offered by these changes which accommodate participants’ personal and cultural food preferences and special dietary needs. As the number of vegans and other vegetarians in the United States increases (1,2), the inclusion of foods acceptable to vegans and other vegetarians in programs like WIC becomes even more important. We believe that the proposed changes, with modifications as noted below, when implemented, will strengthen the WIC program’s ability to improve the nutrition and health status of millions of families.

Fruits and vegetables

We support the increase in the fruit and vegetable benefit. The increase in the maximum cash-value voucher (CVV) monthly allowance encourages fruit and vegetable consumption. We also support the provisions that increase the variety of fruits and vegetables that are available for WIC recipients to choose from. The proposed increases in variety allow for greater accommodation of cultural and other food preferences.

Milk and milk substitutes

We support the addition of more non-dairy substitution options for dairy milk, such as soy-based cheese and soy-based yogurt. These additions, along with the previously approved soy-based milk, allow vegans and others who avoid dairy products for reasons including milk allergy, lactose intolerance, and cultural preference to have access to acceptable products that provide nutritional benefits. In addition, the removal of the restriction on the amount of milk that can be substituted ensures that those who do not drink dairy milk can receive the same nutritional benefits as those who use dairy milk.

We question the requirement that dairy substitutes be solely based on soy. Since the nutrient content of products is specified, any plant-based dairy substitute (milk/cheese/yogurt) that meets these nutrient requirements should be allowed. For example, plant milks based on pea protein have been developed and have nutrient profiles that are similar to dairy milks (3,4). Products such as these should be eligible for inclusion in the WIC food package. Additionally, products are being developed that are based on a combination of base ingredients such as soy and almond (3). If these products meet nutritional requirements, they should be allowed.

We are concerned that few brands of tofu are currently on the market which meet the requirement that tofu contain a minimum of 200 mg of calcium per 100 grams of tofu. We were only able to find one brand of tofu which met this requirement. We propose a modification of this requirement to better reflect the calcium content of currently available calcium-set products.

Soy-based cheeses rarely, if ever, meet the stated requirements for calcium and protein (5). While few appropriate products currently exist, we are hopeful that their inclusion as options in the WIC program, along with the removal of the requirement that they be based on soy, will increase manufacturers’ interest in producing products that meet the specified nutrient standards.

In the interest of health of vegans, we propose that non-dairy milks, cheese, and yogurt be fortified with vitamin B12. Vitamin B12 is naturally present in foods of animal origin; thus, vegans must obtain vitamin B12 from fortified foods or supplements. The requirement that non-dairy milks, cheese, and yogurt be fortified with vitamin B12 would provide a reliable source of vitamin B12 for those using these products.

We also urge that children be able to receive soy products without “consultation with the participant’s health care provider, if necessary as established by State agency policy.” This requirement is not included for other food substitutions. We question the need for this additional step since soy products used to replace dairy milk are required to be fortified with nutrients in amounts similar to dairy milk and are, for practical purposes, nutritionally similar. Requiring medical documentation will add an unnecessary expense and may potentially deter some who would benefit from access to non-dairy products from choosing this option. This could lead to their missing out on important nutrients.

We support the use of an added sugar limit in place of a total sugar limit for yogurt and soy-based milk. This would be consistent with the public health message to limit added sugars. Since flavored soy milks are available which contain little or no added sugar, we support the continued inclusion of both flavored and unflavored soy milk provided requirements for added sugars are met.

Infant foods

We are concerned by the lack of options to infant meat for infants age 6-11 months who are fully breast-fed. Other foods including tofu and legumes are alternative sources of protein, iron, and zinc for vegans and other vegetarians. Without appropriate options to replace infant meat, vegan and vegetarian families will simply avoid this category and their infant will not receive the same benefits that infants whose families eat meat will. Cooked legumes would need to be well mashed or pureed to be acceptable for infants.

Whole grains

We support the proposed expansion of whole grain options to include foods like quinoa, teff, wild rice, millet, corn meal (including blue), and whole wheat naan, which support wider personal and cultural food preferences and can accommodate wheat allergies. Other whole grains and whole grain products which could be added include red rice, and black rice. If whole-grain chapati and roti become commercially available, they should also be added to the list of whole grains.

Legumes and eggs

We support the proposed change to require State agencies to authorize canned legumes in addition to dried legumes. This is respectful of those who may not have time, knowledge, or cooking facilities to prepare dried legumes and adds flexibility to this part of the WIC package. We propose adding frozen unflavored dried legumes to the list of authorized foods. This addition would add flexibility and allow the inclusion of highly nutritious products such as frozen edamame.

We also support the proposed change which requires authorization by State agencies of peanut butter and legumes as substitutes for eggs for vegans, those with egg allergies, and for “other reasons (e.g., cultural preferences as determined by the State agency’s policy.” We note that lacto vegetarians, who are commonly of Asian Indian origin, also avoid eggs and should be specifically included in the list of those who are eligible for egg substitution without relying on State policy to ensure that this group is included. The proposed change gives State agencies the option to authorize tofu as a substitute for eggs. We question the reason for treating tofu differently from peanut butter and legumes and support a change to require authorization by State agencies of tofu as a substitute for eggs. This would allow for consistency, provide variety, and allow another alternative to eggs.

Other possible replacements for eggs include tempeh and frozen legumes (such as edamame).

It is not clear if the proposed requirement for substitution for dairy milk that tofu provide 200 mg of calcium per 100 grams also is required for tofu substitution for eggs. Since eggs provide limited amounts of calcium, tofu being substituted for eggs should not be required to contain a specified amount of calcium.

Thank you for the opportunity to comment on the proposed changes.