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  1. Food Labeling & Nutrition

Plant-Based Milk Alternatives (PBMA)

Plant-based products that are marketed and sold as alternatives to milk are made from nuts (including hazelnuts, walnuts, coconuts, cashews, and almonds), seeds (including sesame, flax, and hemp), rice, oats, or legumes (including soy). The composition of these plant-based milk alternative (PBMA) products, including their nutrient profiles, varies depending on the plant source, processing methods and added ingredients.

PBMA products, such as soy, almond, and oat beverages, are often used the same way as milk. But the Dietary Guidelines for Americans currently only include fortified soy beverages in the dairy group because they have key nutrients similar to those found in milk. The Dietary Guidelines recommends milk and fortified soy beverages as part of a healthy eating pattern because they contribute multiple key nutrients, including calcium, protein, vitamin A, vitamin D, magnesium, phosphorus, potassium, riboflavin, and vitamin B-12, as well as zinc, choline, and selenium. When shopping for PBMA products at the grocery store, it’s a good idea to take a look at the Nutrition Facts label and choose products that are higher in protein, vitamin D, calcium, and potassium and lower in saturated fat and added sugars.

In February 2023, the FDA issued draft guidance that notes that common or usual names of some PBMA, such as “soy milk” and “almond milk,” have been established by common usage. It also includes the FDA’s draft recommendation for PBMA products that are labeled with the term “milk” in their names, such as “soy milk” or “almond milk,” and that have a nutrient composition that is different than milk, include a voluntary nutrient statement that conveys how the product compares with milk based on the USDA’s Food and Nutrition Service (FNS) fluid milk substitutes nutrient criteria.

The goal of this draft guidance is to assist PBMA producers in providing consumers with clear labeling to help them make more informed dietary choices when it comes to PBMA products.

In September 2018, the FDA requested comments to gain insight into how consumers use PBMA products and how they understand terms like “milk” when included in the names of products made, for example, from soy or nuts. After reviewing more than 13,000 comments, including research studies, the FDA determined that consumers generally understand that PBMA do not contain milk and choose PBMA because they are not milk. However, many consumers may not be aware of the nutritional differences between milk and PBMA products. For example, almond or oat-based PBMA products may contain calcium and be consumed as a source of calcium, but they are not included as part of the dairy group in the Dietary Guidelines because their overall nutritional content is not similar to milk and fortified soy beverages. In addition, consumer studies submitted to the notice indicated that many consumers expect that products labeled with the term “milk” in their names (e.g., soy milk) have a nutritional content similar to milk.

In 2019, the FDA held 12 focus groups with nearly 100 participants to explore consumer understanding and expectations related to PBMA products. In these focus groups, the FDA learned that some participants consume PBMA products to replace milk and that some perceive PBMA products as a healthier alternative. And in 2021, the FDA conducted an additional 16 focus groups to explore consumer reactions to several types of nutrition statements for PBMA products.

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