FarmFirst Submits Comments to FDA on Dairy Labeling Guidance

FarmFirst Dairy Cooperative > News > News Releases > FarmFirst Submits Comments to FDA on Dairy Labeling Guidance

Looking out for the best interests of U.S. dairy farmers and consumers, FarmFirst Dairy Cooperative has submitted detailed comments to the Food and Drug Administration (FDA), on a guidance document on dairy labeling. The cooperative urged the enforcement of current dairy labeling regulations and requiring clear labeling differentiating real dairy products from imitations and substitutes.
On February 22, 2023, the FDA issued draft guidance titled “Labeling of Plant-Based Milk Alternatives and Voluntary Nutrient Statements: Guidance for Industry,” in the Federal Register. Comments have been requested by the FDA on this guidance, with a deadline of July 31, 2023.
“While we appreciate the FDA’s efforts in the draft guidance, we firmly believe that it is time to enforce the established regulations and standards of identity for milk and dairy products,” said Jeff Lyon, FarmFirst General Manager. “Consumers deserve clear and accurate information when making purchasing decisions. Enforcing dairy labeling requirements is essential to protect the interests of our farmers and maintain trust between producers and consumers.”
The FDA’s guidance document includes a recommendation for voluntary nutrition statements on plant-based milk alternatives, which differ nutritionally from milk. However, the cooperative is deeply concerned that voluntary labeling falls well short of the necessary enforcement required to protect the dairy industry and consumers effectively. FarmFirst appreciates that the guidance does recognize the importance of milk and dairy in a healthy diet, stating that milk and dairy products provide essential nutrients like calcium, protein, vitamin A, vitamin D, magnesium, phosphorus, potassium, riboflavin, vitamin B-12, and more. The FDA’s acknowledgment of these benefits further highlights the necessity of accurate dairy labeling.
In addition, FarmFirst emphasized the importance of distinguishing dairy-based products from plant-based alternatives to prevent consumer confusion and misperception.
“The use of dairy terms for plant-based alternatives not only misleads consumers about the nutritional content but also undermines the hard work and dedication of dairy farmers,” said Lyon.” We also included recommendations on utilizing the term “imitation” in the labeling of imitation dairy products, as well as the need for clear and easily understood food labels to ensure transparency.
You can submit comments on the FDA guidance by July 31st at, referencing docket number FDA-2023-D-0451. Read the comments submitted to FDA by FarmFirst Dairy Cooperative here

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