Only days left to submit written comments to FDA


As the Food and Drug Administration (FDA) is evaluating its labeling standards as part of its “Comprehensive, Multi-Year Nutrition Innovation Strategy,” there is a short window of opportunity for people to provide written comments to stop plant-based products from labeling their products as “milk.”

The federal standards of identity are in place to promote “honesty and fair dealing in the interest of consumers.” Labels that call “nut juice” milk not only deceive consumers, but also negatively impact family farmers as demand for milk has dropped, according to the American Dairy Coalition (ADC).  

"Use of the term “milk” on plant-based and other laboratory-created beverages easily misleads consumers into believing all of these drinks are equal in content and nutrition," said Kim Brenner, Executive Advisory Member of the American Dairy Coalition in a letter to FDA Commissioner Scott Gottlieb. 

Brenner sent the letter on behalf of the 30,000 producers nationwide represented by the Coalition. 

"Following your current standard of identity used to define the word milk — specifying from lactating animals — while restricting its use on plant-based beverages is important, not only to dairy farmers, but more so to consumers. Nutrition matters," Brenner said in the letter. "There is absolutely no product on the market that can compete nutritionally with cow’s milk, even though they have all been able to brand themselves as equivalent through this play on words. This has made it confusing and misleading for consumers."

The FDA is receiving comments until Aug. 27.  Commentary can be submitted electronically at  or by mail.

Formal ADC comments have been submitted to the FDA demanding the use of the term “milk” to be used only on items derived from FDA’s standard 21 CFR 101.3(b)(2), which is the FDA standard established by federal regulation.

In addition to providing verbal comments at the FDA’s Public Hearing last month, ADC has also launched a initiative campaign to “take back the word milk” called,  Protecting Milk Integrity Initiative. This ADC initiative includes a petition drive and so far has received numerous signatures from consumers residing in almost 30 different states across the nation.  

“You, the FDA, play a critical role in promoting public health by ensuring that food labeling provides consumers with reliable, evidence-based information so they can make informed choices about the healthfulness of the foods they purchase," said Brenner. 

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