What Does the FDA’s Labelling Guidance Mean for Plant-Based Meat?

The FDA has updated its draft guidance for vegan meat, egg and dairy labelling, suggesting companies place an emphasis on the plant-based sources that make up the product.

‘Chickpea meatballs’ is a more favourable term than ‘plant-based meatballs’ when describing vegan products on packaging, according to the US Food and Drug Administration (FDA).

The government body, which has regulatory authority over all plant-based alternatives, has published draft guidelines for the labelling of vegan meat, seafood, egg and dairy products, excluding alt-milk (which were covered in separate guidance last year).

For plant-based food producers, there’s one big win: they’re allowed to use terms like ‘sausage’, ‘burger’, and ‘yogurt’ on their packaging, so long as they don’t mislead consumers.

But there is a big caveat too. The FDA prefers that companies highlight the source ingredients in their products. So instead of ‘vegan Cheddar cheese’, it’s more comfortable with ‘soy-based Cheddar cheese’. Likewise, ‘chickpea and lentil nuggets’ is preferred over ‘meat-free nuggets’.

“Names such as ‘Plant-Based Burger’, ‘Meatless Meatballs’, or ‘Vegetarian ChickN Sausage’ may signal to consumers that the food is a meat alternative, but they do not identify the plant source comprising the food,” the document says.

“The nature of the plant-based ingredients is important information for consumers and should be included in the name or statement of identity to identify and describe the food and distinguish it from similar foods.”

How would this work in practice?

The FDA believes that when looking at a food label, consumers should be able to “easily determine not just that the product is plant-based, but also the plant source (e.g., soy, lentil, walnut, etc.).”

It’s not just the use of ‘plant-based’ or ‘vegan’ – even descriptors like ‘meat-free’ or ‘beefless’ should be used in conjunction with the source ingredient. So, instead of ‘pork-free bacon’, it recommends using ‘plant-based soy bacon’ as the main term, with ‘pork-free’ used as a sub-descriptor above or below.

These terms should be presented in a bold font on the front of the packaging. “We consider a prominent print or type for the statement of identify to be at least 1/2 the size of the largest print on the label,” the document reads.

Meanwhile, vignettes or images that further describe the product’s flavour are allowed too, so long as they aren’t misleading. The FDA’s example includes the image of a cow on vegan jerky, with ‘artificially beef-flavoured’ written underneath.

If a product has multiple plant sources, the predominant ingredient by weight should be stated first. So, for a vegan egg that contains chia seeds as its majority ingredient, alongside flax seeds, the recommended label would read: ‘chia and flax seed eggless scramble’.

Within vegan subcategories too, the FDA outlines why it feels using the source names is important. “Plant-based alternatives to yogurt that are soy-based should bear names that distinguish these alternatives from those that are almond-based. Qualifying the names with “soy” or “almond” would inform consumers of the nature or source of the food, while also distinguishing one subclass of alternatives from another,” it states.

Why is the FDA prioritising the source ingredients?

Foods within the plant-based category can come from a variety of sources, from legumes and tree nuts to seeds, grains, and vegetables. The FDA feels its recommendations can help consumers distinguish between these products to align their purchases with their dietary needs or desire for nutritional variety.

“Omitting a descriptor of the legume, nut, grain, seed, or other plant source in the name of the food may be confusing to consumers, as the product would not be readily distinguishable from other types of similar plant-based alternatives,” it says.

Since there may be nutritional differences between plant-based alternatives and their conventional counterparts, conveying the source ingredients “may help consumers understand that the composition of the product is different and prompt consumers to review the Nutrition Facts label”.

It argues that this practice could help Americans with food allergies, encouraging them to review the ingredient declaration and allergen disclosure statements on the packaging.

“Further, consumers may value or be seeking out certain plant sources as they incorporate foods into their diet, especially as they are looking to build a healthy eating pattern in line with current dietary guidelines, so having this information on the principal display panel is important because it will enable consumers to identify the plant sources more easily,” the guidance reads.

How should brands respond, and what happens next?

It’s important to note that draft guidance documents aren’t legally enforceable – instead, they’re recommendations that reflect the FDA’s “current thinking on a topic”.

Companies may not need to change anything on their packaging, but the recommendation to use plant sources on packaging does feel a bit unnecessary. After all, other product categories don’t have the same obligation, so why should plant-based?

The assumption that people with allergies wouldn’t look at the ingredients label anyway also seems a bit unrealistic. And imploring companies to use product descriptors like ‘soy and wheat jerky’ might hinder their efforts to attract meat-eaters looking for more realistic taste experiences in plant-based meat products.

The FDA is now accepting written or electronic comments, which firms can submit until May 7, when it will begin work on the final version of the guidance.

Its draft document comes just two weeks before Donald Trump returns to the White House. The incoming president has picked Robert F Kennedy Jr as his health secretary, who has promised to overhaul the US health and food systems. It could mean a significant overhaul of the FDA and the US Department of Agriculture, with processed plant-based proteins coming under significant scrutiny.