The plant-based food market is growing rapidly, with consumers increasingly and actively seeking sustainable, ethical, and health-conscious alternatives. However, as this industry expands, so does the challenge of ensuring transparent and accurate labelling. As a follow up on our previous article, we’d like to look at some interesting recent developments.
The Food and Drug Administration’s (FDA) draft guidance outlines best practices for naming and labelling plant-based products. It emphasises that labels should provide consumers with clear and truthful information about the product’s composition. For example, the guidance recommends including the primary plant source in the product name - for example ‘soy-based cheese’ or ‘almond yogurt’ - to help consumers understand what they are purchasing.
The draft guidance also advises avoiding terms like ‘meat-free’ or ‘vegan’ as standalone identifiers as these can obscure the product’s specific ingredients and mislead consumers.
One of the most conspicuous recommendations is that labels may use vignettes or statements to indicate a plant-based product’s characterising flavour. However, the FDA’s draft guidance requires this to align with its flavour labelling regulations and avoid suggesting the product contains animal-based ingredients. For instance, if a plant-based beef jerky label features a cow vignette to convey flavour, it should declare it is ‘artificially beef flavoured’ because the flavour has not come from beef.
One of the FDA’s primary goals is to empower consumers to make informed decisions by ensuring that labels are not only accurate but also prominent and easy to understand.
The draft guidance suggests using bold text and appropriate font sizes for product names, ensuring this vital information is not overshadowed by marketing slogans or branding. These steps are designed to reduce consumer confusion and increase trust in plant-based alternatives.
Transparent labelling also plays a crucial role in addressing greenwashing. As consumers prioritize environmental and ethical considerations, vague or misleading claims about sustainability or vegan credentials can create skepticism and damage consumer trust.
Inaccurate or exaggerated claims about a product’s eco-friendliness may also expose brands to legal risks under evolving regulations, such as the EU’s Green Claims Directive.
Will the EU take lessons from the guidelines?
The FDA’s draft guidance on plant-based food labelling offers valuable lessons for the EU.
By emphasising clear statements of identity, disclosure of plant sources, and prominence of truthful labelling, the FDA demonstrates a proactive approach to addressing consumer confusion and promoting informed choices. These recommendations align with consumer protection principles already embedded in EU law, such as those under the FIC Regulation, but provide practical solutions for managing modern marketing practices and complex labelling schemes.
With the adoption of the Green Claims Directive and the directive empowering consumers for the green transition, the EU has an opportunity to incorporate elements of the FDA’s draft into new practices and guidelines or even legislation.
Potter Clarkson’s dedicated foodtech team specialise in ensuring manufacturers’ meet the current EU and FDA requirements. If you would like to discuss any aspect relating to the regulatory side of your products’ branding, please contact us today.
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