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Do people think ‘plant-based yoghurt’ comes from a cow, or are lobby groups crying over spilt milk?
Meat- and dairy-like terms make plant-based labels less confusing for consumers, not more.
Plant-based food labels in the UK could soon change – and get a bit more complicated in the process. The new draft guidance suggests that dairy alternatives will no longer be able to use qualifiers such as “yoghurt-style” or “cheddar-like”. In fact, dairy groups are trying to stop them from advertising themselves as “dairy alternatives” at all.
Who knows whether this specific legislation will get through. But you can be sure that there will be more challenges, just like it. It’s just one of many challenges to food labelling rules for plant-based foods across the UK, EU and further afield. There’s almost always a country under pressure to tighten the rules.
This creates an unstable environment for manufacturers and prospective innovators in the space. I guess for lobbying groups, that’s kind of the point. But it could be confusing for consumers too – a frustrating fact because the core argument for making tighter rules is to make things easier for the customer.
Despite having done a lot of research into the environmental and nutritional impacts of food, I realised I wasn’t fully up-to-speed on the legal, marketing and labelling side. I wanted to know how these rules vary across countries. And to see if there were any merits to the claims made by lobby groups.
That’s what I’ll do in this post: take a brief tour of the current rules, and look into the research of whether food labelling is really the consumer headache that it’s claimed to be.
What can brands put on a plant-based food label?
First, what are the rules around labelling for plant-based foods? Well, it depends on the country. I didn’t do a complete global analysis – I expect some countries don’t even have a market for these products, so there’s little need for guidelines. But I did dig through the regulations for the countries where plant-based substitutes are most popular – the UK, the European Union (EU), and the US.
I should say that it was actually pretty hard to keep up-to-date with what the latest ruling was (which seems like a problem in itself). So if you spot any errors or things I’ve got wrong, then let me know.
Here’s a quick run-down.
🇬🇧 UK rules on plant-based labelling
The rules vary depending on whether the product is a plant-based milk, other dairy alternative or meat substitute.
Plant-based milks such as oat, almond, and soy are banned from referring to themselves as “milk”. That’s why on most packaging you’ll see a different term such as “oat drink”. Some don’t mention drink at all. Instead, they simply put “Almond” on the carton, with an image of a milk-like drink in the background.
While it says it on the label, I’ve never heard anyone refer to it as “oat drink”. Not even once. Whether it’s in cafes, supermarkets or at home, it’s always “oat milk”.
Dairy alternatives such as plant-based cheese, yoghurt, or ice-cream can’t use these terms explicitly. They’re protected for animal products (with some historical exceptions such as peanut butter, and custard creams).1
But packaging can nod towards them by using similar terms. So you’ll see lots of “plant-based cheddar”, “dairy-free block” or “cheese alternative” labels.
These are the rules that are currently under debate. Lobby groups want to ban these associated terms, and even any reference to them being dairy alternatives at all. Even terms that are misspellings such as ‘mylk’ would be banned.
Meat substitutes – such as plant-based burgers, sausages, and bacon – are allowed to use these terms as long as there are meat-free qualifiers.
That’s why you’ll see “Beyond Meat: Plant-based Burger”, “This Isn’t Beef Burgers” (with ‘plant-based’ on the label), “vegan sausage rolls” or “meat-free bacon rashers”.
🇪🇺 European rules
The rules in the European Union are very similar to those in the UK. Makes sense, given the UK adopted them when it was in the EU.
Plant-based milk cannot use the term ‘milk’; dairy alternatives can’t use these terms explicitly (but can use associated terms, such as ‘cheddar-style’) and meat substitutes can use terms such as ‘burger’ and ‘sausages’.
However, these regulations are almost constantly under threat. In 2020, there was a ruling on whether dairy alternatives could use associated textural terms such as ‘creamy’. It was later dropped by the European Parliament. In 2020 they also voted against a change to legislation that would have protected meat-like terms, with suggestions for ‘veggie burgers’ to be called ‘veggie discs’ and sausages to be ‘veggie tubes’ (yes, you read that right…).
However, some countries within the EU have made moves to change their own laws. Last year, France voted to ban meat terms such as ‘bacon’ or ‘chicken’ on plant-based labels. It later paused this ban after NGOs lobbied the high court, saying that food companies did have enough time to change and update their labelling. It remains to be seen whether this ban will come back around again.
Italy is currently under pressure to change its laws in a similar way.
Outside of the EU, Turkey has banned the production and sale of ‘dairy-free cheese’.
🇺🇸 US rules
Companies in the US can use meat- and dairy-like terms. Unlike in the UK and EU, the term ‘milk’ is allowed. So you’ll find terms like ‘oat milk’ and ‘soy milk’ on labels, rather than ‘oat drink’. You can see this when comparing the US and UK labels for Oatly below.
However, it does recommend that these products give nutritional comparisons to cow’s milk on the label. For example, “Contains lower amounts of potassium’ or ‘contains more calcium than milk’.
The rules can be challenged across different states, so they might not remain the same everywhere. There have been long legal battles to ban these meat- and dairy-related terms in Missouri, Arkansas, and Louisiana, for example.
Other rules across the world
🇿🇦 In South Africa, a ban on using meat-like terms (such as ‘burger’ or ‘sausages’) was passed in June last year. Companies were given 30 business days to update their labels and were at risk of their products been seized off the shelves in August if they had not done so. This seizure had been postponed after legal action from pro-veg groups. It’s not yet clear if there is a new deadline.
🇯🇵 In Japan, meat and dairy terms can be used as long as there are qualifiers that the product is plant-based, or the ingredient name (e.g. oat milk) is included.
🇨🇳 In China, meaty terms can also be used if they have a plant-based qualifier. Its 2021 guidance lays this out, providing examples such as “Plant-based beef” and “Plant meatballs”.
🇸🇬 In Singapore, companies are allowed to use meaty and dairy terms as long as they are qualified with ‘plant-based’, ‘made from plants’, or similar. It is the only country in the world to have lab-grown meat on the market. When it arrives in pre-packaged form, it will have the same labelling laws as current ‘plant-based’ products.
Why do lobby groups argue for a ban on dairy- and meat-equivalent names?
What’s the argument for making labelling rules stricter? Lobby groups – who are mostly dairy or livestock farming associations – make two key points. Both relate to customer confusion.
The first is that consumers will mistakenly buy plant-based products thinking that they are animal products. They’ll pick up oat or soy milk and think it’s cow’s milk. Or they’ll think that a ‘plant-based burger’ is really a beef burger. Seems hard to believe that this would be a common mistake, but we’ll look at the evidence for it soon.
The second is that consumers will buy plant-based products assuming that they have the same nutritional profile as the equivalent animal one. So they’ll assume that soy milk has the same nutritional profile as cow’s milk. Or that an Impossible Burger matches a beef burger.
Do consumers really get confused by plant-based food labels?
I find it hard to believe that people think ‘soy milk’ is actually cow’s milk. But I realise my sample on this is incredibly biased. So let’s not go by my intuition and look at what the research says.
Unsurprisingly, a lot of the research on this topic is not great. Many of the surveys are carried out by lobby or activist groups (on both sides of the debate) and often don’t disclose the methodology or information on how the survey was done. Peer-reviewed academic studies are hard to come by.
Most studies suggest that most consumers do understand the difference between meat- and dairy-free foods from their descriptions and labels.
In the most basic survey, more than 22,000 people in the Netherlands were asked if they knew what a ‘vega sausage’ meant. 96% did: it was a sausage that was vegetarian. Now, this report was light on methodology and insightful questions, so I wouldn’t use this as definitive proof of anything. Still, it would suggest that most people understand these basic differences.
One of the rare peer-reviewed academic studies found that including meat-like terms such as “burger” or “sausages” did not make consumers any more likely to mistake plant-based products for meat.2 In this study (which was only 155 people – much smaller than we’d like), they polled participants on the following product comparisons.3
“Next-Generation Meat: Plant-based Beef Burger” vs. “Plant-Based Vegetable Patty”. 88% of respondents thought that it was unlikely or very unlikely that the plant-based beef burger came from a cow. Only one person thought it was likely. People were no more likely to think the ‘burger’ was meat-free than the ‘patty’.
“Cultured Vegan Butter” vs. “Cultured Vegan Spread”. Again, most people understood that neither of these products contained dairy from a cow. In fact, slightly more understood this for “butter” than for “spread”.
“Plant-based Deli Slices: Bologna Style” vs. “Sandwich Slices”. Interestingly, more people thought that “sandwich slices” contained meat than the “Deli slices: Bologna Style”. In fact, the majority thought “sandwich slices” came from an animal.
These results make the opposite case to those that lobby groups raise. Food labels that have terms such as “burger” and “butter” in them actually help the consumer understand what they are. Generic terms make this harder.
A bigger study in Australia – from the Institute for Sustainable Futures at the University of Technology Sydney – polled more than 1,000 people on their understanding of food labels. They showed participants a random sample of 15 images (from a set of 60), and asked them to identify if they were plant-based, contained meat, or they weren’t sure. Overall, 8-out-of-10 identified correctly. At the end, they asked participants if they found it easy to tell the difference; 91% said yes.
The same study also asked participants if they had ever accidentally bought a plant-based product thinking it was animal-based. 80% said no, 7% were not sure, and 12% said they had.4 Of the 12% that said they had, two-thirds said they were in a hurry (or distracted) and didn’t read the label. Just one-third were confused about what the label meant. That means just 4% of the total sample had accidentally bought the wrong product because they were confused by labels.
Now, to the often-quoted study on the other side. It comes from the National Cattlemen’s Beef Association. Now, we shouldn’t pretend that this is an unbiased source but I expect many of the statistics quoted on the pro-veg side are also biased, so we should be fair here. It asked 1,800 participants a range of questions related to plant-based substitutes.
Its results don’t change my overall conclusions from the research – that most people easily understand the difference between these products – but I do think the study highlights a few important points. The results of the study are often quoted as “less than half of consumers understand that plant-based beef is entirely vegan”. And interpreted as “most consumers think plant-based beef contains meat”. But that’s not quite what the numbers say:
45% said that plant-based beef was completely vegan, containing no animal byproducts (egg, dairy).
31% thought it doesn’t contain meat but may contain animal byproducts.
17% thought it can contain small amounts of meat, but is primarily plant-based.
7% thought it contains meat and there are no restrictions on the amount.
Here the problem was not using the term ‘beef’. It’s that people don’t understand – or don’t fully agree on – what ‘plant-based’ means. The study says that ‘plant-based’ means ‘entirely vegan’, and it, therefore, concludes that the 31% and 17% of people that think it can contain small amounts of animal products are wrong. But does plant-based mean ‘entirely vegan’?
People don’t know what ‘plant-based’ means
The peer-reviewed academic study we looked at previously posed a similar question but assumed that ‘plant-based’ did not mean entirely vegan. It said that the majority of people knew that “Raised and Rooted: Plant-Based Nuggets” correctly identified that it didn’t contain chicken, but most incorrectly thought it was unlikely to contain eggs.5 The nuggets weren’t vegan.
How can we expect people to know what these terms mean when surveys and brands can’t even agree?
Most definitions of ‘plant-based’ on Google are along the lines of:
“A diet consisting largely or solely of vegetables, grains, pulses, or other foods derived from plants, rather than animal products.”
“Plant-based diets are dietary patterns that have a greater emphasis on foods derived from plants.”
“Plant-based or plant-forward eating patterns focus on foods primarily from plants.”
“Plant-based” typically refers to one who eats a diet based primarily on plant foods, with limited to no animal-derived products.”
Very few definitions say that animal products are completely forbidden. They say that most of the diet comes from plants, and animal products are limited. That doesn’t mean they are banned.
Many meat substitute products use small amounts of egg or dairy as binding agents, so they’re not entirely vegan. To me, that seems to be the biggest problem with labelling. It seems much more likely that vegans will accidentally pick up a non-vegan meat substitute (thinking it has no animal products), than a meat-eater doing the same (thinking it’s meat).
If the term ‘plant-based’ is so confusing, why do companies use it? People prefer it to terms like ‘vegetarian’ or ‘vegan’. It signals that these products are not just for this small group of people. It also brings up feelings of health and nutrition (rightly or wrongly – I’ll look at nutritional differences in a future post).
More freedom to use descriptors would make it less confusing for consumers
Having looked at the labelling rules across countries and the limited survey research, is there anything to these labelling protests?
Not really. In fact, the rules that dairy and meat lobbies suggest would make things worse, not better.
There are basic food terms that people use and understand. People know what a ‘burger’ is, they know what a ‘sausage’ or ‘bacon’ or ‘yoghurt’ is. Now, on their own, these terms bring the animal product to mind. Say ‘burger’ and people think of a beefburger.
In that sense, allowing plant-based products to use those terms without the clarity that they are meat-free is misleading. If all the package says is ‘burger’ then that’s misleading. If a label only has the term Che*se or Chick’n on it, then that’s misleading. That shouldn’t be allowed.
But with a disclaimer or explanation of what’s in it? That shouldn’t be confusing to consumers. In fact, it helps them.
Before the big drive for plant-based foods, you’d find the odd “veggie burger” or “bean burger” on a restaurant menu. That wasn’t confusing: you knew what you were getting (a burger) but the caveat was enough to tell you that it wasn’t a beef one. People were not confused by this.
These caveated terms lead to less confusion, not more. It gives people an indication of what the meal or product will be like, and how it should be used. What’s more confusing for people are the random new terms that companies would have to use instead.
Let’s say a company couldn’t label their product “meat-free bacon”. Instead, they called it something like “[Generic brand name] sandwich slices”. If it looks like rashers in the packet, many will assume it’s meat. This wouldn’t happen if companies were allowed to use the term “meat-free bacon”.
The same applies to dairy products. People know oat milk is not cow’s milk. And that dairy-free yoghurt doesn’t come from cows.
The proposed regulations would make things more confusing, not less. In that sense, these lobby groups are making a fuss out of nothing. Taking time, money, and attention away from areas where change would really make a difference.
As I said above, the one problem I see with labelling is the lack of clarification on what ‘plant-based’ means. Does it mean entirely vegan, or are eggs and dairy allowed? That’s the biggest source of confusion, but won’t be solved by blanket bans on the use of ‘meaty’ or ‘dairy-like’ terms.
Note: Here I haven’t addressed the question of the nutritional equivalence of dairy and plant-based alternatives. I’ll take a detailed look at that in a future post.
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A reader pointed out to me (thank you) that the Netherlands is an exception to this. There, peanut butter is called “pindakaas”, which means “peanut cheese”. This is because the term “butter” has been reserved for “real butter”.
I think this supports my later point that restricting these terms makes things more confusing for consumers, rather than less. People know what peanut butter is (and isn’t), but many would be confused by a translation of “peanut cheese”.
Gleckel, Jareb A., Are Consumers Really Confused by Plant-Based Food Labels? An Empirical Study. University of Louisville, Louis D. Brandeis School of Law, Journal of Animal and Environmental Law.
These questions were planted within a larger questionnaire about food preferences so that the intention behind them was not obvious.
This study also had a very small percentage of vegans. And the majority of respondents said they were unlikely to buy plant-based products. That means most were probably less familiar with them prior to the survey.
I know these numbers add to 99%, not 100% – I'm going to assume it's a matter of rounding from the survey.
This question was based on a new Tyson product “Raised and Rooted: Plant-Based Nuggets.” It uses the qualifier “plant-based” but is not made entirely free from animal products because one of the ingredients is eggs.