Photo by Rissa Miller

By Rissa Miller, Vegan Journal Senior Editor

(One portion is about 2 Tablespoons)

2 heads roasted garlic (see instructions below)

1/4 cup sundried tomatoes, soaked in 1/2 cup hot water

One 12-ounce package firm Lite Silken tofu, drained

1/4 cup fresh basil leaves

2 Tablespoons lemon juice

1 teaspoon Italian herb blend

1 teaspoon olive oil

Salt and pepper, optional, to taste

To make roasted garlic, preheat the oven to 400 degrees. Cut very tops off garlic, then place garlic in aluminum foil shaped into a bowl. Add a little water and close the bowl-packet. This will create steam and make it simple to separate the garlic from the skins. Optionally, season with a few drops of olive oil, salt or black pepper, if desired. Bake the closed packet on any oven-safe dish for 45-60 minutes. Allow to cool before handling. Can be made ahead and stored in the fridge.

To make the Sauce, place sundried tomatoes in a bowl and cover with 1/2 cup very hot water. Allow to soak for 25-20 minutes to soften.

Squeeze roasted garlic from papery skins, so just the roasted cloves go into a blender or food processor. Add all over ingredients, including the soaking water from the sundried tomatoes. Process until silky and smooth.

Serve over sautéed tempeh, roasted vegetables, salads, grains, or noodle dishes.

By Reed Mangels, PhD, RD

On an average school day in the United States, nearly 30 million children and teens eat school lunches and 14 million eat school breakfasts. School meal programs are funded by the federal government and  operate in public and nonprofit private schools. Meal patterns for these programs are established by the U.S. Department of Agriculture (USDA).

The USDA is proposing changes to the nutrition standards for school meals to make these meals healthier. The proposed changes include:

• Limiting the amount of added sugar in meals and snacks,
• Requiring that at least 80% of grains served each week be whole grains,
• Reducing the sodium content of school meals, and
• Allowing schools to limit food contract bids to products that are locally grown, raised, or caught.

The USDA is requesting comments on the proposed changes. Parents and guardians of vegan school-aged children may be especially interested in one of the questions that the USDA is requesting feedback on. The USDA says, “While this rule does not propose changes to the fluid milk substitute requirements, USDA has received stakeholder feedback on the fluid milk substitute process on behalf of children who cannot consume, or have difficulty consuming, cow’s milk. USDA seeks public comment on the following question: What feedback do stakeholders have about the current fluid milk substitute process? USDA is especially interested in feedback from parents and guardians and program operators with firsthand experience requesting and processing a fluid milk substitute request.”

By law, schools are required to offer cow’s milk with every school breakfast and lunch. Currently, schools may (but are not required to) provide “non-dairy milk substitutes” for children for non-disability reasons (1, 2). Different rules apply for children who need a milk substitute for reasons related to a disability. In order to provide a substitute for cow’s milk for non-disability reasons, the National School Lunch Act requires that

• a written statement from the student’s parent or guardian or a medical authority be submitted to support the request for non-dairy milk
• non-dairy milks must meet specific nutrition requirements
• The school cover any cost difference between cow’s milk and non-dairy milk.

In its request for comments, USDA says, “USDA recognizes that the specific nutrition and paperwork requirements and cost burden associated with fluid milk substitutes present barriers for schools and families. Additionally, USDA recognizes that under the statute, schools are allowed—but not required—to provide fluid milk substitutes for non-disability reasons; this means that, due to budget constraints, some schools may opt not to provide a fluid milk substitute requested for non-disability reasons on behalf of a child. As noted below, USDA requests public input on the current fluid milk substitute process. While USDA does not have the authority to change the statutory requirements outlined above, better understanding challenges associated with the current process may help USDA address the concerns raised by commenters.”

If your family has requested or considered requesting a milk substitute through the school meals program, the USDA would like to hear about your experience. What challenges did you face? What ideas do you have for improving the process?

Comments on the proposed changes can be submitted at https://www.regulations.gov/document/FNS-2022-0043-0001 and must be submitted by April 10, 2023.

References

1. USDA. Meal Requirements Under the National School Lunch Program and School Breakfast Program. : Questions and Answers for Program Operators. https://fns-prod.azureedge.us/sites/default/files/resource-files/SP05-2022os.pdf#page=27. 2022.
2. Child Nutrition Programs. Title 7. Code of Federa-7/l Regulations. Pt. 210. 2021 ed. www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-210.

To read more about school meals see:

Getting Vegan Food into Schools

Vegan Options in a California School

Vegan Options in Portland, ME School Lunch

New York City School Lunch Program Features “Vegan Fridays”

School Food Lunch

VRG’s School Lunch Testimony

Tempeh in School Meals

By Anna Markulis, VRG Intern

MOM’s Organic Market is the perfect stop for anyone looking for a quick and delicious vegan lunch made from sustainably sourced fresh ingredients. MOM’s is an organic grocery store located all along northeastern states including Maryland, Virginia, D.C., Pennsylvania, New York, New Jersey, and Massachusetts. The majority of MOM’s locations offer vegetarian and vegan meals at their in-store restaurants, “Naked Lunch” and the “Bake Shop.” While “Naked Lunch” is served at many locations among these states, the “Bake Shop” is unique to Timonium, Maryland and Jessup, Maryland. The inclusion of these restaurants will vary by store, so check your local location!

I visited the MOM’s in Timonium, Maryland, and stopped by their vegetarian food joint, “MOM’s Bake Shop.” The vast selection of made-to-order organic vegan or vegetarian sandwiches served on their homemade bread in addition to their nutritious fresh raw pressed juices certainly impressed me as a first-time customer. I chose to order the “Classic Veggie” – a whole wheat sandwich with hummus, avocado, tomatoes, cucumber, and pea shoots. The staff was so friendly and quick, even with so many people in line! The sandwich was bursting with flavor and had the perfect veggie “crunch” amount. I could immediately tell that they used the freshest ingredients. The hummus offered a contrasting yet delightful tanginess that complemented the bread and vegetables perfectly. My 14-year-old sister had a bite as well. She told me it was one of the best sandwiches she’s ever had, and that it was enough for her to “consider going vegan.” Overall, I was thoroughly impressed by the selection, quality, and flavor of the vegetarian and vegan sandwiches and juices. I will definitely be going back again soon!

Check out the Bake Shop at Mom’s in Timonium, Maryland: https://momsorganicmarket.com/maryland/timonium/
For information on Naked Lunch Kitchen: https://momsorganicmarket.com/nakedlunch/

To find out about other restaurants that serve vegetarian food in the USA and Canada, visit the Vegetarian Resource Group’s restaurant guide: https://www.vrg.org/restaurant/

February 2023

We welcome the opportunity to comment on the Request for Information; Identifying Ambiguities, Gaps, Inefficiencies, and Uncertainties in the Coordinated Framework for the Regulation of Biotechnology. As a consumer organization representing vegetarians and vegans, we have a unique perspective on issues related to biotechnology, especially those involving the use of genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA).

4. Describe any specific issues the agencies should consider in developing a plan to implement regulatory reform including any updated or new regulations or guidance documents.

Our response to question 4:

Regulations and guidance documents should require the provision of clear, helpful label information that consumers can use to make informed choices about products produced using new or emerging biotechnology. An example of this is the labeling of foods that were produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA), due to concern for consumer confusion. We believe that the name or statement of identity of meat, poultry, dairy, egg, or other products comprised of or containing cultured animal cells should inform consumers about how the animal cells were produced. Vegetarians, including vegans, do not eat meat or poultry (and eggs and dairy products in the case of vegans) and would want to be aware that a product contains cultured animal cells. We assume that this would also be the case for those with an allergy to meat, poultry, dairy, or egg products and for those who avoid one or more products due to religious beliefs. In addition, consumers may not want to purchase products comprised of or containing cultured animal cells due to concerns about any negative environmental impact of producing these products.¹

The limited acceptance of these products was shown by a survey conducted online within the United States by The Harris Poll on behalf of The Vegetarian Resource Group from June 22-24, 2020 among 2,074 U.S. adults ages 18 and older.² Approximately six percent of those surveyed are vegetarian (including vegans) all the time, and half of the vegetarians are also vegan (three percent). More than half (54%) of those surveyed always or sometimes eats vegetarian (including vegan) meals when eating out.

We asked if survey respondents would purchase a meat alternative grown from animal cell DNA obtained ten years ago, which does not currently involve the raising of animals. Only 12% of respondents said they would purchase such a product; 19% of vegetarians including vegans would purchase a meat alternative grown from animal cell DNA; 19% of those that sometimes or always eat vegan meals when eating out and 18% of those that sometimes or always eat vegetarian, including vegan, meals when eating out would purchase this type of meat alternative.²

Similarly, a 2021 national survey was commissioned by The Vegetarian Resource Group and conducted online by YouGov, of 8 -17 year-olds. This survey found that more than half (53%) of 8-17 year-olds sometimes or always eat vegetarian meals when eating out. As was done in the adult poll, we asked if survey respondents would purchase a meat alternative grown from cells (DNA) from an animal, which was collected years ago which does not currently involve the raising of animals. Only 9% of respondents said they would purchase a meat alternative grown from animal cell DNA.³

Since so many consumers would choose not to purchase a product produced using animal cell DNA, it is important that consumers be informed about the presence of cultured animal cells in products in clear, easily understood language. This should be indicated in the product name and in the ingredient list on the product label so that consumers can be aware of the product’s composition.

In addition to label information, it is important for companies to have specific information about the source of these cells in their products on their websites since many people look on product websites for information. This information should also be presented in clear, easily understood language.

Guidance and regulations are also needed to prevent the use of confusing terminology on labels of products produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA). Terms such as “vegetarian,” “vegan,” “animal-free,” or “plant-based” used on product labels of products produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA) are potentially confusing to consumers. Survey research indicates that U.S. consumers are not in favor of labeling products using animal cell DNA or derived from animal genes as “vegetarian,” “vegan,” “animal-free,” or “plant-based.”

A survey, conducted in the United States in March 2022 by YouGov on behalf of The Vegetarian Resource Group, consisted of 2,889 adults.⁴ Over six in ten (62%) vegans didn’t want meat and dairy alternatives that are made using NO animals or animal products but are based on animal cells or DNA extracted years ago from a live animal labeled as vegan. 62%-65% of those that ate vegan meals (not all those individuals are vegan) didn’t want them labeled vegan, animal-free or plant-based, with an even higher percentage at 71% wanting the product to be labeled so it informs consumers that the products use animal cell DNA or is animal-gene derived. ⁴

The terms “vegetarian,” “vegan,” and “plant-based” should not be used in the product name or on the product label of a food comprised of or containing cultured animal cells or produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA). This terminology would be a misrepresentation of the food product. Although neither the USDA nor the FDA currently defines “vegetarian,” “vegan,” or “plant-based,” these terms are commonly used to imply that products do not contain ingredients from meat/fish/poultry (vegetarian) or from all animal products and by-products (vegan). “Plant-based” has a variety of meanings but it is commonly used to indicate that a product is vegetarian or vegan.⁵ Having “vegetarian,” “vegan,” or “plant-based” on a label of a product containing cultured animal cells would be misleading to consumers.

Additionally, terms such as “non-animal” or “animal-free” should not be used in the product name or on the product label of a food comprised of or containing cultured animal cells or produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA). Use of these terms would be misleading for consumers who, for religious, ethical, philosophical, environmental, or other reasons do not want to purchase products in which animal products were used at some point in production.

The results of our surveys strongly support the need for updated or new regulations or guidance documents related for foods produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA).

5. Describe any new or emerging biotechnology products that, based on lessons learned from past experiences or other information, the agencies should pay particular attention to in their evaluation of ambiguities, gaps, or uncertainties regarding statutory authorities and/or agency roles or processes.

Our response to question 5:

We are concerned that the rush to market foods produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA) may not allow for adequate time to evaluate the safety of these foods for human consumption and for the environment. We urge the statutory authorities and/or agencies to develop rigorous requirements for safety evaluation.

7. What is the highest priority issue for the agencies to address in the short term and in the long term?

Our response to question 7:

As a consumer organization, we prioritize providing clear, helpful label information that consumers can use to make an informed choice. As discussed in our response to question 4, we believe that this is a high priority need that should be addressed in both the short term and the long term. Food labels should clearly indicate that products are animal DNA replicated, so that those with allergies, religious, or other concerns can differentiate these products from similar looking items.

Thank you for the opportunity to comment on this issue.

References

1. Meat Atlas. https://eu.boell.org/en/MeatAtlas. 2021; pp. 60-61.
2. What vegetarian and vegan products will American adults purchase? Questions asked by The Vegetarian Resource Group in a national poll. https://www.vrg.org/nutshell/harris2020veganadultwriteup2blog.pdf. 2020.
3. How many youth in the U.S are vegan? How many teens eat vegetarian when eating out? https://www.vrg.org/nutshell/Yougov2021youthteenwriteup.pdf. 2021.
4. How many vegetarians and vegans are there? https://www.vrg.org/nutshell/CulturedMeatYouGov2022.pdf. 2022.
5. What does plant-based actually mean? https://www.vrg.org/journal/vj2018issue4/2018_issue4_plant_based.php. 2018.

Vegan business for sale. This vegan cheese company has been making and selling their product for over 18 years in retail stores across the US and in Canada. The owner is looking for a change and would love to hand the business over to – preferably passionate and compassionate people – who can see with fresh eyes and can take this company to the next level and beyond. There is so much potential! The core product is easy to make, contains only a handful of ingredients, no cooking, no liquids; it is nutrient dense and tastes great. If this interests you, reach out and let’s have a conversation, [email protected].

Photo from Casa Borinqueña

The Vegetarian Resource Group maintains an online Guide to Vegan/Vegetarian Restaurants in the USA and Canada. Here are some recent vegan restaurant additions. The entire guide can be found here: http://www.vrg.org/restaurant/index.php

To support the updating of this online restaurant guide, please donate at: www.vrg.org/donate

Here are some new additions to VRG’s guide:

Algorithm Queen Village, 705 E. Passyunk Ave., Philadelphia, PA 19147

Select from signature plates, burgers, sandwiches, grain bowls, tacos, soup, and fries. Hot and cold brew coffee, milkshakes, non-alcoholic beer, milkshakes, and desserts also available. Many gluten-free options as well.

Casa Borinqueña, 6211 Shattuck Ave., Oakland, CA 94609

Enjoy vegan Puerto Rican food! Try the Chicken sampler plate and bori fries (deep fried plantain topped with onions, Impossible meat, mojo, and mama spread).

Karyn’s Kitchen, Flossmoor Commons, 3331 Vollmer Rd., Flossmoor, IL 60422

Karyn’s Kitchen is a plant-based restaurant that serves pizzas, sandwiches, and soups. Pizzas include the meat lover’s made with plant-based meat and the veggie pizza made with hummus, mushrooms, and artichoke hearts. Potato wedges and soup are included with the meatball sub, falafel sandwich, and other sandwiches. The black bean soup is served with shredded jackfruit and coleslaw. Chef’s specials such as vegan mac & cheese are also available.

Ice Queen, 2012 SE 11th Ave., Portland, OR 97214

Enjoy vegan popsicles and Thiccflurries with toppings based on classic paletas flavor. This is 100% plant-based Mexican inspired street food.

Likkle Patty Shop, 80 Poquonock Ave., Windsor, CT 06095

If you’re the type of person who loves new things and always down for an adventure, you’ll be overjoyed to try the goodies at the Likkle Patty Shop! A women-owned vegan Jamaican bakery, Likkle Patty Shop serves a delicious array of patties, coco bread, soups, pasta, pizza, and more! Some favorites include the Jerk Spiced Eggplant Patty: A blend of eggplant, onions, garlic, soy sauce, herbs, spices, and sea salt wrapped in a signature flaky coconut oil crust, and the Baby Got Broc! Patty: A spinach-infused crust filled with broccoli, potato, vegan cream, garlic, red pepper flakes, and nutritional yeast. For those with a sweet tooth, cookies and scones are also available! Packaged meals like “RastaPasta” and “Yumus Hummus” are also included on the menu to purchase.

Tandem Bakery and Café, 1221 Helen Ave., Missoula, MT 59801

Treating yourself to delicious vegan desserts and hot foods is a piece of cake with your local Tandem Bakery and Cafe! From soups and sandwiches to baked goods, a wide selection of vegan and gluten-free options are available to meet your needs. Some popular choices at the café include the Grilled Chz, soft and melty vegan cheese on Multigrain bread buttered and grilled to perfection; Tomato Bisque, a warm and comforting tomato soup with fresh herbs and cashew cream; and the House Salad, a blend of apple sage quinoa, roasted root veggies, and pickled red onions on a bed of mixed greens topped with roasted pecans and served with your choice of house-made dressing. For those with a sweet tooth, donuts, cupcakes, and cakes are also available in-house! Some options include the Hazelnut Espresso Cupcakes, a fluffy vanilla cake infused with espresso and coffee liqueur finished with hazelnut buttercream and garnished with toasted hazelnuts, and the Lavender Lemon Cake, a vanilla cake filled with house-made lemon curd, topped with lavender buttercream, and garnished with dried lavender flowers. All flavors and options are listed on the website or refreshed in-store. For custom treats, please visit the website for more information on lead times, limits, and more.

Willowbeez SoulVeg, 59 Spruce St., Columbus, OH, 43215

Operating as a pop-up in Columbus’ North Market, Willowbeez SoulVeg offers a menu the mere reading of which starts to feed your soul. From the BBJerk Bella with its authentic Jamaican jerk and side of cornbread to the No*Fish Fry made with a breaded Banana Blossom to the Rich Boi comprised of Oyster mushroom drizzled with house-made Remoulade, you may find yourself making multiple trips to North Market in order to try it all. Make sure you visit one Wednesday, as that’s when they serve up their So’Lasagna, which includes eggplant, kale, mushrooms, vegan cheese—and, of course, Love—all rolled in a lasagna shell.

Broccoli Casserole by Rissa Miller

By Rissa Miller, Vegan Journal Senior Editor

Ingredients:

1 medium yellow onion, roughly chopped

2-4 cloves garlic, chopped

1 Tablespoon olive oil

1-2 cups broccoli, chopped (or frozen and thawed florets)

2-3 cups additional veggies, chopped (you can use carrots, corn, celery, mushrooms, spinach, bell pepper, zucchini…)

One 15-oz. can tomato sauce

1 Tablespoon dried oregano

1 teaspoon dried basil

1/2 cup shredded vegan cheddar (optional)

Handful of breadcrumbs

Salt and pepper, to taste

Tabasco sauce, to serve (optional)

Instructions:

Preheat the oven to 400 degrees and spray a 9- x13-inch casserole dish with olive oil.

In a deep pan or cookpot, sauté onions and garlic in oil until soft and fragrant. Add all veggies. Cover and cook for 10-15 minutes on medium heat until veggies reduce. Add water as needed to keep from sticking. When veggies are soft, add dried herbs and tomato sauce and simmer for another 5-7 minutes to combine flavors.

Pour into the prepared casserole dish and top with cheddar shreds and breadcrumbs. Bake in the oven, covered, for 10-15 minutes until the cheese is melty and top is lightly toasted. Serve immediately while hot. Season to taste with Tabasco sauce or more oregano/basil.

Thank you to more generous donors, in 2023 The Vegetarian Resource Group will be awarding $30,000 in college scholarships! Deadline is FEBRUARY 20, 2023.

We will accept applications postmarked on or before FEBRUARY 20, 2023. Early submission is encouraged.

Applicants will be judged on having shown compassion, courage, and a strong commitment to promoting a peaceful world through a vegetarian (vegan) diet/lifestyle. Payment will be made to the student’s college (U.S. based only). Winners of the scholarships give permission to release their names to the media. Applications and essays become property of The Vegetarian Resource Group. We may ask finalists for more information. Scholarship winners are contacted by e-mail or telephone. Please look at your e-mail.

If you would like to donate to additional scholarships or internships, go to www.vrg.org/donate

Applications

Please click here to download a PDF of the application. However, applicants are not required to use an application form. A neatly typed document containing the information below will also be accepted as a valid application.

Please send application and attachments to [email protected] (Scholarship application and your name in subject line) or mail to The Vegetarian Resource Group, P.O. Box 1463, Baltimore, MD 21203.

If emailing, please put your essay in a separate attachment with your first name and last initial. A PDF or Word document is preferred, but if you send a Google document, make sure permission is given so readers can access it. For more information call (410) 366-8343 or email [email protected].

Each issue of Vegan Journal, Chef Nancy Berkoff pens the Vegan Cooking Tips column. One of her columns focused on eggplant. She offers a variety of ways to prepare eggplant including:

• Roast an eggplant whole, in the oven or on the grill, until soft enough to mash with a fork. Scoop out pulp and add oil and vinegar, garlic, and black pepper to use as a dip or salad dressing. This dish is sometimes called “eggplant caviar.”
• For homemade baba ganoush, purée roasted eggplant and mix with garlic, tahini (sesame paste), lemon juice, chopped parsley, and olive oil. Use it as a dip for vegetables or as a sandwich filling.
• Mix diced, grilled eggplant with grilled peppers,lentils, onions, and garlic. Serve cold, topped with balsamic vinaigrette, or hot, atop grains, pasta, or pizza.
• Skip-the-Frying Baked Eggplant: Peel eggplant and cut into ½-inch slices. Create a breading with your favorite crumbs (bread, cornmeal, etc.) and dried Italian herbs (garlic powder, oregano, parsley, red pepper flakes, etc.). Spray eggplant slices with vegetable oil, coat with breading, place on non-stick pan, and bake until soft. Layer baked eggplant into a deep baking dish, alternating layers with thick tomato sauce; drained, diced, canned tomatoes; sliced mushrooms (if desired); and either shredded vegan cheese or thinly sliced extra-firm tofu. Cover and bake until bubbly.
• Mini Japanese or Thai eggplant stuffed with a mixture of diced smoked tofu, tempeh, or veggie crumbles; pine nuts; and roasted peppers. Wrap in foil and bake.
• Make Eggplant Frisbees: Preheat oven to 375 degrees. Place slices of unpeeled eggplant (about ½-inch thick) individually on a non-stick baking sheet. Sprinkle with grated vegan cheese, minced onions, sunflower seeds, and nutritional yeast. Bake until bubbly and the eggplant is slightly soft. The Frisbees may also be used as eggplant burgers served on a hearty roll with fixins.

Find the complete article here: https://www.vrg.org/journal/vj2021issue4/2021_issue4_cooking_tips.php

Subscribe to Vegan Journal in the USA only by visiting https://www.vrg.org/member/2013sv.php

We welcome the opportunity to comment on Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug, and Cosmetic Act (Edition 5): Guidance for Industry [Draft Guidance].

As a consumer organization, we prioritize providing clear, helpful label information that consumers can use to make an informed choice. We commend the FDA for their consideration of newer methods of food production and trends in food choices and for promoting the provision of clear information to consumers.

Specifically, we were pleased to see guidance specifying that products packaged in containers or in bulk to be used by food manufacturers that contain a major food allergen must comply with the allergen labeling requirements (B.2, B.3). This is important to help assure proper handling and clear labeling of the finished products. We were also pleased with the guidance for declaration of incidental additives in spice mixes which might be major food allergens (B.4). This guidance will also protect consumers. We also agree that an incidental additive that contains a major food allergen would have to be declared as a food source of the major food allergen (D.10).

Allergic reactions have been associated with the consumption of milk from other ruminants in addition to cows. In order to protect consumers, we are in favor of a revision of the FDA’s interpretation of “milk” for this guidance (C.1). We propose a revised phrase “animal milk” or “animal-derived milk” which would distinguish cow, sheep, goat, buffalo and other ruminant species’ milk from “plant milk” which would include milk derived from plant sources and that does not contain animal products. These revised phrases would be used in educational and informative materials about major food allergens. On food labels, the source of the animal milk should be identified similar to the way in which the specific species of fish or Crustacean shellfish or type of tree nut are identified.

Similarly, due to the potential risk of allergic reaction from various bird species, the definition of “egg” (C.2) should be revised to include eggs from other bird species in addition to chickens. On food labels, the source of the egg should be identified similar to the way in which the specific species of fish or Crustacean shellfish or type of tree nut are identified.

We support the proposed guidance that proteins from major food allergens, produced in other sources through the use of genetic engineering are subject to the food allergen labeling requirements of the FD&C Act (B.14). This type of labeling will help to protect people with food allergies who may be misled by product labels containing statements such as “animal-free” or “vegan.” We propose that food allergen information on these products should be in readable type or a readable background, not only in the ingredient listing but also along with any other declarations on the labels which may be confusing to the consumer related to the presence of the allergen. These could include terms such as “animal-free” or “vegan.” We do not think that these terms (“animal-free” or “vegan”) should be used on labels of foods that were produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA), due to concern for consumer confusion

We are concerned with the response to question D.8 that does not clearly state what is needed in order to “ensure that the ingredient does not contain protein.” In order to protect the consumer, products containing lactose or ghee should be required, without exception, to declare milk on the label. The possibility that a product may contain residual protein from milk is of great concern for those with food allergies.

We agree with the statement in response to question D.13 that good manufacturing practices should be used to protect against food allergen cross-contact. We are concerned that sometimes allergen advisory statements to warn consumers about potential allergen cross-contact are confusing to consumers. The allergen advisory statement may list an ingredient that does not appear in the product. It would be helpful to consumers to clarify that shared equipment or other cross-contact is the source of the allergen. Thank you for the opportunity to comment on this issue.