PBFA comments at FDA’s Meeting on Standards of Identity Modernization

Below is PBFA’s public comments by our Executive Director Michele Simon at the FDA’s Public Meeting on Horizontal Approaches to Food Standards of Identity Modernization in Washington, DC, September 27, 2019.

Good afternoon. My name is Michele Simon, and I am the executive director of the Plant Based Foods Association.

PBFA was founded in 2016 to build a strong foundation for the plant-based foods industry to succeed and thrive. Today the association has grown to 160 member companies. We appreciate the opportunity to speak here today, and, we join others in applauding the FDA’s goal of modernizing standards of identity.

American consumers are sophisticated and well informed. Consumers who purchase plant-based foods are keenly aware of why they are making these choices and do so for many reasons: sustainability, health, allergies, ethics, variety and taste. While grocery sales overall are flat, retail sales of plant-based foods are growing quickly, at a rate of 11 percent overall since last year. Therefore, we encourage FDA to support one of the few areas of growth within the food industry and one that is experiencing rapid innovation.

There is much discussion about the use of the word “milk” to identify plant-based alternatives. For our members, and as the data shows, for many consumers, the word simply describes the functionality of the product. We are concerned about an over-reliance on nutrition as the marker by which changes in standards of identity should be measured. Many consumers are seeking out plant-based milks and other animal alternatives to avoid certain components such as saturated fat and cholesterol. In addition, many consumers cannot eat dairy due to allergies or intolerance. Approximately 65 percent of the population is lactose intolerant.

There is widespread agreement among nutrition experts that the nutrients in cow’s milk products can be found in a variety of foods (including plant-based alternatives). There is also mounting scientific evidence that a proper diet based primarily on plant-based foods promotes optimal health.

We suggest that FDA take an approach that answers one basic question: Is the label truthful and non-misleading? The Nutrition Facts panel, combined with the required Statement of Identity, already provide ample information. Moreover, the free speech clause of the First Amendment protects companies that label their foods with truthful, non-misleading names.

To help ensure a consistent labeling approach among our members, in 2017, PBFA convened a Standards Committee to establish voluntary standards for the labeling of plant-based milks. Last year, we shared that finished document with FDA. We have also since required that all companies applying for PBFA’s Certified Plant Based stamp adhere to those guidelines. We are currently working with our members to create similar labeling standards for the plant-based yogurt category, as well as for plant-based meats and plant to share those results by the end of this year.

This is the solution we believe is best for our industry, flexible and inclusive.

The FDA has the unique opportunity to support this growing industry and the millions of American consumers who are voting with their dollars. Our members are committed to working with FDA and look forward to finding a solution to this important issue.

Thank you.

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