Consumer interest in plant-based foods is thriving and driving explosive growth in the industry. Through our specialty practice, the Free From Forum, we run a monthly study of consumer attitudes and behaviors around natural products. Our March 2019 study shows that 34% of households reported purchasing dairy free products like plant-based milk, yogurt, or cheese in the past 12 months and 20% of households purchased plant-based meat and seafood alternatives.
Because Linkage has been monitoring this consumer trend closely, we have been very curious about the response to the FDA’s Request for Information on what the agency called “the use of the names of dairy foods in the labeling of plant-based products.” We partnered with the Plant Based Foods Association (PBFA), which commissioned us to read and analyze more than half (7,061) of the 11,903 publicly available comments on the issue.
WHAT IS THE OVERALL SENTIMENT?
Three-quarters (76%) of commenters are in favor of allowing plant-based foods to use dairy terms. Another 1 in 8 commenters (13.5%) believe plant-based foods should be precluded from using dairy terms. The remainder (10.5%) provide comments that are not conclusive on their opinion about the use of terms. Two-thirds of these inconclusive comments (66% of the 10.5% inconclusive) express concerns about animal welfare when it comes to the production of dairy products, suggesting that they support plant-based foods companies.
CONSUMERS ARE OVERWHELMINGLY IN FAVOR
The majority (66%) of commenters make no mention of their role in society. However, among the comments reviewed in this analysis, 1,715 individual commenters specifically state they are consumers. Looking at these consumer comments alone, 97% are in favor of allowing plant-based foods to use dairy terms.
The majority (87%) of these consumers specifically state they are not confused by current labeling. Further, 6 in 10 consumers (59%) who are in favor of plant-based foods using dairy terms state that requiring a label change at this point would actually risk creating confusion where none now exists, as consumers are already accustomed to seeing dairy terms used on plant-based foods.
“As an American consumer, I support the continued labeling of plant-based products with names that include milk, cultured milk, yogurt, and cheese. As a reasonable consumer, I know that the qualifying ingredients almond, soy, cashew, etc. indicate that these products are derived from such ingredients and not from cows on dairy farms. As a diverse society, I believe we should continue to enjoy greater dietary variety over time, including the availability and consumption of more plant-based products as substitutes for dairy-based foods and beverages. I do not believe consumer confusion truly exists in the plant-based products industry, and plant-based milks should therefore continue to be labeled as such.” – Consumer Comment, ID FDA-2018-N-3522-6573
DAIRY FARMERS ASK THE FDA TO ENFORCE STANDARDS OF IDENTITY
An additional 482 commenters specifically identified themselves as dairy farmers or family members of dairy farmers. These comments are diametrically opposed to those offered by consumers; nearly all are opposed to plant-based foods using dairy terms. Their arguments are that consumers believe plant-based foods are nutritionally similar to cow’s milk (94% cite this as a reason) and that consumers can be confused or misled when plant-based foods are labeled with dairy terms (91%).
CONCLUSION
Three-quarters of commenters in total, and nearly all who describe themselves as consumers, are in favor of allowing plant-based foods to use dairy terms. Consumers are more savvy than ever before and are increasingly turning to plant-based options. From our extensive research in the natural products industry over the past five years, we know they do so for a variety of reasons, including allergy/intolerance, because they believe plant-based foods are healthier, or for environmental or animal welfare reasons. It is clear from our review that the vast majority of consumers want FDA to leave labeling for plant-based dairy alternatives alone. They feel confident they understand the distinctions between plant-based and dairy foods.
About the FDA Call for Comments
The call for comments was issued on September 28th, 2018 and after extension, the comment period closed on January 28th of this year.
Linkage Research & Consulting, Inc partners with companies to develop actionable consumer insights through market research. The Free From Forum is a specialty practice of Linkage Research that focuses on understanding market place and consumer trends around free-from, natural, and better-for-you products through trend monitoring, custom analysis, and data mining. For media inquiries or questions about this study, contact info@linkagereserach.com.