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Draft Guidance for Industry: Labeling of Plant-Based Alternatives to Animal-Derived Foods

DraftHuman Foods Program01/06/2025

Description

This draft guidance provides FDA’s recommendations on best practices for naming and labeling of certain plant-based foods that are marketed and sold as alternatives for animal-derived foods (plant-based alternative foods), especially in the absence of a common or usual name for the product.  These recommendations for manufacturers are intended to help ensure that consumers understand the nature or source of individual plant-based alternative foods, including differences among these products, and have the information they need to make informed purchasing decisions.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

3
Plant-Based Alternative Foods

Foods marketed as alternatives for animal-derived foods; Labeling of plant-based alternatives to animal-derived foods

Plant-Based Milk Alternatives

Excluded from the scope of this specific guidance

Plant-Based Alternatives to Animal-Derived Foods

Subject of the draft guidance regarding labeling and naming.

Stakeholders

1
Manufacturer

Entity responsible for submitting NDINs

Regulatory Context

Regulatory Activities

2
Labeling

The primary regulatory activity addressed in the guidance

Naming

The process of establishing a common or usual name for products

Document Types

4
Draft Guidance

The nature of the document regarding plant-based food labeling

Nutrition Facts label

Consumers are prompted to review this to understand product composition.

ingredient declaration

Reviewing this helps consumers with food allergies.

Statement of identity

Must be in bold type on the principal display panel

Attributes

3
Nutritional variety

A characteristic consumers seek when making purchasing decisions

standard of identity

Established definitions for foods under section 401 of the FD&C Act.

Plant source

The nature of the plant origin that should be included in the food name

Technical Details

Substances

3
Plant-derived ingredients

The primary components of the alternative foods

soy

Example of a specific plant source to be identified.

almond

Example of a specific plant source to be identified.

Standards & References

External Standards

1
U.S. Dietary Guidelines for Americans

Recommendations for healthy eating patterns

Related CFR Sections (5)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Misbranded within the meaning of section 403(i)(2)
2
misbranded within the meaning of section 403(q) of the Act
1
Misbranded
1
Failure to declare net quantity of contents
1
Misbranded drugs
1
Adulterated food
1
Misbranded within the meaning of section 403(a)(1)
1
Failure to declare the major food allergen milk
1
misbranded within the meaning of section 403(i)(2) of the Act
1
misbranded within the meaning of section 403(w) of the Act
1

Related Warning Letters (6)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

Draft Guidance for Industry: Labeling of Plant-Based Alternatives to Animal-Derived Foods | Guideline Explorer | BioRegHub