{"id":14502,"date":"2019-11-22T09:00:41","date_gmt":"2019-11-22T14:00:41","guid":{"rendered":"https:\/\/www.vrg.org\/blog\/?p=14502"},"modified":"2019-11-11T14:23:36","modified_gmt":"2019-11-11T19:23:36","slug":"vegetarian-resource-group-testimony-submitted-to-food-and-drug-administration-fda-on-horizontal-approaches-to-food-standards-of-identity-modernization","status":"publish","type":"post","link":"https:\/\/www.vrg.org\/blog\/2019\/11\/22\/vegetarian-resource-group-testimony-submitted-to-food-and-drug-administration-fda-on-horizontal-approaches-to-food-standards-of-identity-modernization\/","title":{"rendered":"VEGETARIAN RESOURCE GROUP TESTIMONY SUBMITTED TO FOOD AND DRUG ADMINISTRATION (FDA) ON HORIZONTAL APPROACHES TO FOOD STANDARDS OF IDENTITY MODERNIZATION"},"content":{"rendered":"\n
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The Vegetarian Resource Group (VRG) is an independent non-profit organization dedicated to educating the public on vegetarianism and the interrelated issues of health, nutrition, environment, ethics, and world hunger. Our health professionals, activists, and educators work with businesses and individuals to bring about healthy changes in schools, workplaces, and the community. Registered dietitians and physicians aid in the development of nutrition-related publications and answer questions about the vegetarian and vegan diet. For the past 25 years, we have commissioned polls exploring vegetarian-related issues, results of which are often used by researchers, the food industry, and the media. Financial support comes primarily from memberships, contributions, and book sales. \u00a0<\/p>\n\n\n\n

We welcome the\nopportunity to comment on Horizontal Approaches to Food Standards of Identity\nModernization. We commend FDA for their commitment to protecting consumers\nagainst economic adulteration; maintaining the nutritional integrity of food;\nand providing flexibility to encourage manufacturers to produce more healthful\nfoods. As a consumer organization, we also prioritize providing clear, helpful\nlabel information that consumers can use to make an informed choice and to be\nable to find the foods that they are looking for. It is important for Standards\nof Identity to be modernized so that label information is relevant to today\u2019s\nconsumers. <\/p>\n\n\n\n

We recognize the need\nto update Standards of Identity. Regardless of the approach used to update\nthese Standards, it is important to meet the needs of a variety of\nconsumers.  We have both specific and\nbroader suggestions for meeting the needs of vegetarians, vegans, and those who\nwish to eat vegetarian and vegan foods.<\/p>\n\n\n\n

According to our most\nrecent poll (1), about 4% of adults in the United States consistently follow a\nvegetarian diet, about half of these are vegan and do not eat any animal\nproducts. People choose to follow vegetarian or vegan diets for a variety of\nreasons including health, ecological, and religious concerns, dislike of meat,\ncompassion for animals, belief in non-violence, and economics. Many other\npeople avoid dairy products and\/or meat products due to environmental concerns;\nhealth issues such as allergies, lactose intolerance, or hypercholesterolemia;\nor for other reasons. Our most recent poll (1) finds 46% of American adults\nsometimes or always eating vegetarian (including vegan) meals. This segment is\nlikely to increase since 60% of 18-34 year olds always\/sometimes eat vegetarian\n(including vegan) meals when eating out. Clearly, a large and growing segment\nof the population needs products to be labeled in a way that meets their needs\nas consumers of plant-based products.<\/p>\n\n\n\n

Vegetarians and those\ninterested in reducing animal product consumption commonly use plant-based\nproducts (milks, cheeses, yogurts, meats) in place of animal-based products.\nThe plant-based products are used to add variety, to enable users to prepare\nfoods similar to those made with animal-based products, and, in some instances,\nto supply nutrients such as calcium, vitamin D, vitamin B12, and protein. Label\ninformation should allow consumers to recognize plant-based products that\nreplace meat or dairy products using familiar words like \u201cburger,\u201d \u201cmilk,\u201d\n\u201ccheese,\u201d or \u201cbacon.\u201d<\/p>\n\n\n\n

Our understanding of\ndairy terms like milk, yogurt and cheese, and meat terms like burger, sausage,\nor bacon, when they are used to label plant-based products is that these\nproducts are plant-based alternatives to animal-based products. In many,\nalthough not all cases, plant-based products can be used in food preparation\nand will behave similarly to animal-based products. For example, plant-based\ncheese may be used to top pizza; plant-based milk used to make a cream soup.\nJust as different dairy milks and cheeses have different tastes,\ncharacteristics, and uses, so do plant-based milks. For instance, chocolate\nmilk, even though it\u2019s labeled as milk, would not be used to make a savory\ndish. Similarly, replacing Cheddar cheese with ricotta cheese in macaroni and\ncheese would result in a very different product. Despite these differences,\nthese products are all identified as milk or cheese. Considering the wide\nvariety of animal-based products identified as milk, cheese, or yogurt, it does\nnot seem incongruous to also identify plant-based products as milk, cheese, or\nyogurt with a modifier identifying the main plant ingredient (e.g. soy milk,\ncashew cheese, almond milk yogurt). Similarly plant-based meat replacers could\nbe identified as \u201csoy burger,\u201d \u201ctempeh bacon,\u201d or \u201ctofu-based sausage.\u201d<\/p>\n\n\n\n

The Nutrition Facts\nand ingredient list on food labels along with front of label information allows\nconsumers to evaluate the nutritional characteristics of plant-based products.\nOur website, and those of other vegan organizations, encourage consumers to\nseek out plant-based products that are fortified with nutrients such as\ncalcium, vitamin D, and vitamin B12 if they rely on these products as a source\nof these nutrients. Consumers are aware that there are nutritional differences\nbetween plant-based and animal-based products. We note that terms such as\ncoconut milk and peanut butter have been used for many years without confusion\nas to their plant origins or to these products\u2019 nutritional differences from\ncow\u2019s milk or dairy butter.<\/p>\n\n\n\n

We believe that prohibiting\nplant-food labels from including words like milk, cheese, burgers, sausage, and\nyogurt in the name of these products would lead to consumer confusion. We urge\nyou to permit the labeling of plant-based products with names that include\nmilk, cheese, burgers, sausage, and yogurt.<\/p>\n\n\n\n

Our suggestion for allowing\nfor increased flexibility and for providing useful information is to use\nstandardized label terminology. The following terms are proposed:<\/p>\n\n\n\n