U.S. FDA Issues Draft Plant-Based Food Labeling Guidance 

On January 6, 2025, the U.S. Food and Drug Administration (FDA) issued the Draft Guidance for Industry: Labeling of Plant-Based Alternatives to Animal-Derived Foods. The guidance provides naming and labeling recommendations for plant-based foods that are marketed and sold as alternatives for animal-derived foods (plant-based alternative foods).

In the draft guidance, the FDA makes several recommendations including the following:

• The statement of identity of plant-based alternative foods should include the plant source to allow consumers to make informed purchasing decisions.
• “Plant-based” or similar statements should include the plant source as part of the statement of identity. For example, instead of listing the statement of identity “plant-based fish-sticks”, a product could state “plant-based chickpea & lentil-based fish sticks”.
• Only listing “non-[name of animal or meat type]”, “vegan”, or similar statements does not provide sufficient information to consumers and should be supplemented with information about the plant source. 
• If the product has multiple plant sources, then the primary plant ingredients should be listed in order of predominance with the statement of identity.

Background
Plant-based alternative foods do not have established standards of identity and therefore, must list the common or usual name of the food, if there is one. The common or usual name shall not be misleading. If there isn’t a common or usual name, the product must be labeled with an accurate description or a fanciful name commonly used by the public. Since many plant-based alternative foods do not have standards of identity or common or usual names, they should be labeled with a statement of identity that accurately describes the food.

Scope
This guidance does not apply to plant-based milk alternatives. The FDA published the Draft Guidance for Industry: Labeling of Plant-Based Milk Alternatives and Voluntary Nutrient Statements in April 2023 discussing labeling recommendations for plant-based milk alternatives labeling.  

Link: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/draft-guidance-industrylabeling-plant-based-alternatives-animal-derived-foods 

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