The State of the Labels, FDA Comment Edition (a Photo Essay)

July marked the end of the comment period for FDA’s draft guidance on the labeling of plant-based beverages. The guidance, offered in February, is filled with flaws and still doesn’t do what FDA actually needs to do — enforce its own Standard of Identity for milk, which is clearly defined as an animal product.

But that doesn’t mean the guidance is all bad. By advising plant-based beverage-makers to add disclosures on their packaging noting their nutritional differences (read: inferiority) with true dairy milk, FDA is acknowledging an important point: That mislabeled beverages are creating confusion over the nutritional value of plant-based beverages in the marketplace. Such guidance is significant, and food manufacturers tend to follow it so as not to get on FDA’s — or a judge’s — bad side.

No final guidance has been adopted. Now that the comment period is over, FDA can create a final guidance, or do nothing. But since its advice has been public since February, we thought it was worth checking in on the State of Plant-Based Beverage Labeling, ca. summer of 2023. Has the guidance had any effect? Is there any hope for positive change? Let’s check in, so we can check in later, as labeling evolves to however FDA, consumers and manufacturers shape it. A new era is dawning. Click this link to see what it looks like today.