WCMA Comment to FDA on Use of Dairy Labels for Plant-Based Products
Wisconsin Cheese Makers Association and Edge Dairy Farmer Cooperative and Dairy Farmers of Wisconsin commissioned the consumer research firm Ravel to conduct research to understand how consumers perceive plant-based foods that mimic dairy products, namely natural cheeses. This consumer research study is attached.
The questions and areas of inquiry in the study were based on the questions prepared by the U.S. Food and Drug Administration in its Request for Comments on Use of the Names of Dairy Foods in the Labeling of Plant-Based Products.
We ask that FDA staff review the Ravel study, its methodology, its data and conclusions prepared by Ravel staff. Among the conclusions noted in the report:
•One quarter of consumers mistakenly indicated that pasteurized milk was present in plant-based foods that mimic cheese and one quarter don’t know what ingredients are in these mimics. The high prevalence of ‘don’t know’ and mistaken responses perhaps indicates that the use of traditional dairy names such as cheddar and mozzarella confuse consumers, leading to the selection of dairy ingredients in these plant-based foods.
•About one-third of consumers don’t know or think that the plant-based cheese has higher quality protein, even though plant-based foods that mimic cheese have little to no protein content.
•Significantly more consumers indicate that they would buy one of the plant-based foods that mimic cheese because they are low in calories, low in fat, and contain no additives. In actuality, plant-based foods that mimic cheese contain an equal or comparable amount of fat and calories and contain substantially more additives than dairy cheeses.
•About half of consumers say plant-based foods that mimic cheese are actually cheddar or mozzarella cheese. And compared to the dairy cheeses, a significantly higher percentage don’t know if the plant-based foods are cheddar or mozzarella cheese. Together, these answers indicate more than half of consumers surveyed mistook a plant-based food mimicking cheddar or mozzarella to be traditional cheddar or mozzarella or were unclear about applying these traditional cheese names to plant-based foods.
Based on the data presented in the attached study, Wisconsin Cheese Makers Association concludes that the use of the word “cheese,” and the use of traditional cheese types such as cheddar and mozzarella on labels for plant-based foods confuses and misleads consumers. The U.S. Food and Drug Administration should use its authority to stop the makers of plant-based foods that mimic dairy products from using the word “cheese” or the names of cheese types on packaging or in marketing and advertising. These products are simply not what they claim to be, and consumers are confused and deceived.
Since 1893, Wisconsin Cheese Makers Association has represented manufacturers of dairy products, as well as companies that process cheese or market and distribute cheese. Today, 105 member companies and cooperatives operate more than 260 facilities in 22 states. We thank you for this opportunity to provide data for this Request for Comments.