Oct 31, 2020
The Indian plant-based industry in India has urged upon the Food Safety and Standards Authority India (FSSAI) to review its recent announcement proposing to ban the use of dairy terms such as ‘milk’ and ‘cheese’ for plant-based products.
FSSAI has proposed this ban due to its regulatory vocabulary – namely because current FSSAI regulations define ‘milk’ as the ‘normal mammary secretion derived from complete milking of healthy milch animals’ and plant-based products are not included in this definition.
And based on these regulations, anything else cannot be called milk as per this definition, even though that thing is from alternate/substitute milk, a milk product or composite milk product, a dairy term shall not be used.
These provisions specifically prohibit the use of any dairy term for a product which is not milk or milk product or composite milk product [actually] already exists in FSSAI’s regulations, hence the proposal is only a repetition of what is in the rules.
FSSAI suggested that the plant-based products in the market use term that is ‘indicative of the dairy analog’s true nature’. Like, it may be mentioned here that in the Codex Regional Standard for Non-Fermented Soya Bean Products (CXS 322R-2015), the term ‘beverage’ can be used in the nomenclature of the soya-based product analogous to milk
The plant-based industry in India is not at all happy with this suggestion – plant-based advocacy body Good Food Institute (GFI) expressed apprehension that this was likely to not only confuse consumers, but also affect product sales across the board.
GFI expressed disappointment on the, given the reputation of the FSSAI as a progressive, evidence-based regulator, and risks stifling innovation which would benefit the consumer.
Plant-based milks and other products have a wide variety of uses, a survey shows that Indian consumers use plant-based milks across several applications, including tea, coffee, and cooking, so the use of the term ‘beverage’ therefore may not accurately represent to the consumer what the product is and its full scope, which could result in confusion and a drop in sales.
The ban on the use of “milk” will have potential negative impacts on the entire industry, as well as the lack of consistency in its proposed implementation. The plant-based industry claims that this is against the interest of a young industry with major promise for sustainability, job creation, and consumer choice. Further, they added, there are other regulations already in place for other foods such as peanut butter, cocoa butter, and coconut milk, and risks confusing consumers, who for the most part do not seem to have any ambiguity about the source of plant-based milk.
GFI and IPSOS research shows that a majority (over 70%) of Indians were found to be able to successfully identify the source of cow’s milk v/s plant-based milks, where they were from small cities or large towns, and whether or not they consumed plant-based dairy.
So even in a relatively immature market like India, consumers are not only educated enough about plant-based dairy to distinguish between these products and animal-derived dairy, they also believe that it is fair and correct to utilize dairy terms to describe them.
Local dairy firm Epigamia, which also sells plant-based products agreed with the plant-based industry stressing that Indian consumers who are already seeking dairy alternatives are ‘capable of making informed choices while purchasing these products’ and already ‘understand their inherent differences in ingredients and sources’ without a nomenclature change
Furthermore, it is important to note that many consumers are resorting to alternatives on the back of health reasons or the fact that they can’t digest dairy and we would need to cue the generic consumption category for these alternatives. “Plant-based alternatives are critical in our move towards building safe, resilient, and sustainable food systems in the wake of COVID-19 [and] we hope that FSSAI will consider all these factors in its decision.
The ban will impact plant-based product manufacturers apart from dealing with consumer confusion would be both figuring out new nomenclature as well as dealing with additional costs – a situation that is neither fair nor sensible,
Fair and sensible labeling would account for the fact that consumers have been educated about soy milk for decades and do not face any ambiguity in this choice and fair labeling is critical to creating a level playing field for the growth of any new industry, and we believe that prohibiting the use of dairy terms may stifle this growth, to the detriment of producers and consumer welfare.
GFI and Epigamia proposed that FSSAI focus on instead getting plant-based product companies to add appropriate qualifiers to their product labels. Ultimately, plant-based manufacturer is using the appropriate qualifier such as ‘plant-based’ along with the dairy term will be the ideal solution (e.g. plant-based cheese), and consumers agree. The whole group is hoping that FSSAI can come to a sensible conclusion on this matter which enables this very promising industry to advance.