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NMPF Submits Dietary Guidance Statement Comments Pushing for Clarity

November 7, 2023

NMPF strongly objected to FDA’s discussion of plant-based milk and yogurt alternatives in the agency’s draft guidance ,“Questions and Answers About Dietary Guidance Statements in Food Labeling: Draft Guidance for Industry” published by the Food and Drug Administration (FDA) in comments submitted Sept. 25.

Dietary guidance statements can be used on food labels to provide consumers with information about foods or food groups that can contribute to a nutritious dietary pattern to help consumers make healthier choices. NMPF’s comments supported the use of consensus statements from authoritative bodies as the basis for dietary guidance statements but requested clarification on food group equivalents. NMPF also questioned FDA’s approach to plant-based milk and yogurt alternatives, saying it will encourage false and misleading advertising — which FDA has already acknowledged as an issue in their draft guidance for the labeling of plant-based milk alternatives.

“Despite the agency’s instructions to use consensus statements from authoritative bodies in developing guidance statements, FDA appears to violate its own principle by describing a means by which plant-based alternatives other than fortified soy could make dietary guidance statements based on consensus statements about the dairy group,” NMPF wrote in its comments.

NMPF’s comments on the proposed guidance for dietary statements is one small part of the organization’s broader campaign against the mainstreaming of plant-based beverages as legitimate dairy alternatives, an issue FDA itself has acknowledged is a public health threat. Other efforts include our campaign for a stricter version of FDA’s draft guidance on plant-based beverage labeling, multiple letters to the agency, and a Freedom of Information Act request on agency communications regarding plant-based beverages.