NMPF Comments Push Back on Standards of Identity
October 1, 2025
NMPF submitted comments to FDA Sept. 15 regarding the agency’s proposal to revoke 18 Standards of Identity (SOIs) for dairy products, saying four of them remain necessary.
NMPF disagreed with FDA’s conclusion that the standards are no longer necessary to promote honesty and fair dealing for Acidified Sour Cream; Cream Cheese with Other Foods; Pasteurized Blended Cheese with Fruits, Vegetables, or Meats; and Pasteurized Process Cheese with Fruit, Vegetables, or Meats.
NMPF agreed that SOIs should be eliminated when they are made redundant by other standards or regulations, or if the product is no longer in the market – FDA’s rationale for the 18 revocations. Most of the dairy product SOIs in the agency’s proposal do fall under one of those two categories. However, each of the four exceptions called out are actively produced by NMPF members and sold across the country, making it necessary for NMPF to speak out on behalf of its members.
FDA established in 1939 the standards slated to be eliminated to protect consumers by ensuring that foods labeled with a specific name, such as “milk,” meet certain expectations of ingredients, characteristics, and processing. NMPF said in its comments that SOIs are as important today, if not more important, as when they were created to keep nutritionally inferior plant-based imitation dairy products in the marketplace from deceiving consumers.
FDA’s initial proposal is part of a larger agency effort to review, and in some cases eliminate, hundreds of SOIs, including those for all dairy products. NMPF will monitor for additional proposals and advocate in members’ best interest.