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Dairy Defined: Need Peanut “Butter”? Got “Milk” of Magnesia? We’re Fine with That

ARLINGTON, VA | Of all the misinformation the plant-based sector has aimed at dairy over the decades, one of the most aggravating has been the idea that because dairy farmers want nut-juice manufacturers to stop pretending their products are equal to theirs, they must somehow also oppose terms like peanut butter, Cream of Wheat, and other common products that have dairy-associated words in them. They do this to both to obscure our real point – that their mimicking of dairy’s properties and use of dairy terms to sell nutritionally inferior imitations creates a real public health issue – and to try to make our arguments seem silly. But the problem is, that’s never been our position – it’s just another “plant”-ed lie. We’ve even specifically rebutted the point, in the Citizen Petition we sent FDA in 2019. So once more, with feeling, here’s the difference between our position on terms like “peanut butter” vs. plant-based dairy alternatives. It all comes down to: 21 U.S. Code § 343 - Misbranded food Plant-based fake-dairy products are misbranded. According to FDA regulations, a food shall be deemed to be misbranded … “If it purports to be or is represented as a food for which a definition and standard of identity has been prescribed by regulations.” The italicized part is the important part. (That’s why we italicized it.) The main principle behind the concept of misbranding is “don’t pretend to be something you’re not,” and that’s the difference between plant-based imitators and common foods that have long used dairy terms without pretending to be in the same food category. Cream of Wheat is a wholesome breakfast food, but no one’s urging you to pour it in your coffee. Coconut-milk-in-a-carton is problematic (we’ll explain why), but coconut-milk-in-a-can isn’t being sold as a beverage. Nut butters are spreads, but they don’t substitute for butter in baking -- and if you decide to slather body butter on your toast because you thought it’s dairy flavored with … then you’re just an awful human being, and you deserve to vomit. By the same token, Milk of Magnesia isn’t pushing to worm its way into the federal school lunch program, even if the occasional school lunch may make some students wish that were so. The common thread is that none of these items are trying to masquerade as dairy products. They aren’t promoting marketplace confusion, and they aren’t implying nutrient content they don’t provide. Contrast that with the plant-based imposters. They’re sold in gallon jugs, cartons and tubs. Even though most don’t require refrigeration because they’re not fresh, they try to fool consumers by paying grocery stores to put their products in the dairy case. They add artificial colorings to make them look like the dairy products they mimic, and they market themselves as being able to do whatever true dairy milk, butter, cheese, or yogurt can do – with the implication that if they can do the same things, they must be equivalent, which in nutrition, they clearly are not. That’s misleading, as consumer research shows. That’s misbranding, as the FDA defines the term. And that’s what we oppose, as we continue our fight for labeling transparency. This charade’s been going on for decades. As then-WhiteWave CEO Steven Demos said in 2001 of how soy beverage came to be a dairy imitator: “We also had to figure out how to get this product category to market. Dairy milk is a staple food that we consider a fundamental part of the scenery in a supermarket. Why not position fresh soymilk to be as close as possible?” That attitude is all about market position – but not market integrity. But integrity has never been the plant-based sector’s strong suit. We’re hoping that our campaign to add comments to FDA’s draft guidance on plant-based beverage labeling will encourage the agency to start enforcing its own rules, just as we’re supporting the DAIRY PRIDE Act as a congressional solution. We’d encourage you to use the materials we provide as you compose your letter to FDA. Write it while you’re enjoying a peanut butter sandwich and cooking a coconut-milk-based curry. Maybe treat yourself to some chocolates for dessert (the cocoa butter in them must be 100 percent pure to meet FDA’s chocolate standard of identity, by the way). Dairy is fine with that. We know who we are -- and we know where the confusion always comes from. It’s time for it to end.


The National Milk Producers Federation, based in Arlington, VA, develops and carries out policies that advance dairy producers and the cooperatives they own. NMPF’s member cooperatives produce more than two-thirds of U.S. milk, making NMPF dairy’s voice on Capitol Hill and with government agencies. For more, visit


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