The US Food and Drug Administration (FDA) has released draft guidelines aimed at improving transparency in the labeling of plant-based alternatives to animal-derived foods. While this document is non-binding, it gives plant-based brands a preview of what the FDA considers best practices for labeling—and a potential roadmap for future regulations.
These recommendations cover plant-based substitutes for eggs, seafood, poultry, meat, and dairy products under FDA jurisdiction, excluding plant-based milk, which is addressed in separate guidance. According to the FDA, the goal is to ensure that “consumers understand the nature or source of individual plant-based alternative foods, including differences among these products, and have the information they need to make informed purchasing decisions.”
Clearer statements of identity
A key focus of the guidance is the statement of identity, which must include the plant source of the product. For example, names like “Soy-Based Burger” or “Cashew Cheese Spread” are recommended over more generic terms like “Plant-Based Burger.” The FDA advises that this specificity helps consumers make more informed purchase decisions.
For products made from multiple plant sources, it’s suggested that the primary ingredient be listed first, such as in “Chickpea and Lentil Patties.” The guidance states, “The primary types of plant sources [should] be included in the name so that consumers can easily identify the particular plant source and distinguish the food from similar foods.” The agency warns that failing to provide this clarity could confuse consumers or even lead to allegations of misleading labeling.
Guidance on modified spellings and common terms
The FDA also takes aim at the creative names often used by plant-based brands, such as “Chik’N” or “Be’f.” While these can remain part of product marketing, it’s advised that brands pair them with clear descriptions of the plant-based ingredients. The agency notes, “If using this type of modified spelling, the label [should] also make clear what the product is and that the name describes the nature of the plant source.”
Similarly, terms like “vegan,” “meat-free,” or “animal-free” may be helpful but insufficient on their own, adding that such terms must also describe the specific plant sources to avoid ambiguity.
The FDA highlights the need for prominence, stating that the product name or statement of identity should appear in bold type and be “reasonably related to the most prominent printed matter” on the label. This ensures that consumers can quickly identify the product’s plant-based nature and its main ingredients.
Implications for plant-based brands
The agency explains that its recommendations aim to help “manufacturers of plant-based alternatives to animal-derived foods ensure that the labeling for, and names of, their products are truthful and non-misleading and accurately describe the food.”
However, the draft guidance has sparked concern among some plant-based industry leaders. Paul Shapiro, CEO of The Better Meat Co., argues that requiring plant-based brands to display their primary ingredient on the front of packaging creates inconsistent standards compared to other food categories.
“There are numerous food products on the market today that are not compelled to disclose their primary ingredient on the front of their packaging, yet consumers have not demonstrated confusion about these products,” Shapiro notes, citing examples like pepperoni, breakfast cereals, and snack foods. He warns that such a precedent could unfairly stigmatize plant-based products and place unnecessary burdens on the sector.
For more detailed information, the full draft guidance is available here.
