National Fisheries Institute Statement on the Food and Drug Administration’s Draft Labeling Guidance

WASHINGTON, DC — February 24, 2023 — The Food and Drug Administration’s (FDA) newly issued draft guidance to help ensure appropriate labeling of plant-based beverages, marketed as milk alternatives, is a solid step in the right direction for regulators and consumers.  Highly processed, plant-based products masquerading as seafood for too long have contributed to consumer confusion and openly flouted existing regulations. Guidance for these products should mirror those now under consideration for “milk” products.

In the case of “milk,” FDA explains that use of the term “plant-based” does not exempt the producer from describing the actual plant source as part of the product name. This is in lockstep with prevailing policies on Statement of Identity. The guidance further affirms labels that promote things solely as “vegan shrimp” or “plant-based fish alternatives” do not accurately  provide American consumers and families with the labeling information they need to make buying decisions.

What’s more, simply adding “fish-less” or “fish-free” would be a further violation of the labeling principles outlined in this guidance. FDA writes, “the term ‘dairy-free milk’ is not an adequate name for any plant-based milk alternative.”

We look forward to FDA releasing draft guidance for plant-based seafood alternatives that aligns with the structure it has applied to milk in this draft guidance. Enforcing long-standing regulations and preventing consumer confusion is of paramount importance.

Lisa Wallenda Picard

President & CEO

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