Citing consumer confusion and public health concerns, American Farm Bureau Federation is urging the Food and Drug Administration to require manufacturers of plant-based milk alternatives to adhere to current labeling laws and regulations.

In comments to FDA on its recent draft guidance on the labeling of milk alternatives, Farm Bureau said it is imperative FDA ensure consumers have accurate information about the food products they consume.

“Farm Bureau calls on FDA to vigorously enforce food standards regarding the labeling of dairy substitute products and prohibit the misleading labeling of nut and plant-based products as ‘milk’ or other common dairy terms,” Farm Bureau said in it comments.

FDA has acknowledged a potential public health concern related to the substitution of milk with alternatives that contain lower amounts of certain nutrients found in milk. But it would allow the continued use of “milk” on the labels of such products as almond milk with a recommendation that manufacturers voluntarily label the product with its nutrient content if it is different than milk.

For example, the label could state “contains lower Vitamin D and calcium than milk.”

Farm Bureau recognized FDA’s attempt to buffer against nutrition confusion by suggesting the use of voluntary nutrient statements.

“Unfortunately, a suggestion of voluntary nutrient statements is futile since few companies would volunteer such packaging additions,” Farm Bureau said.

“Allowing flexibility in use of these terms nullifies any reason to have labeling enforcement generally and provides fuel to bad actors who may use this case as a reason to push for other wrongful use of terms,” Farm Bureau said.

Under the Federal Food, Drug and Cosmetic Act, a modified food that does not comply with the traditional standard of identity of a term must be labeled as an “imitation,” “substitute,” “alternative” or another appropriate term if it is nutritionally inferior, Farm Bureau pointed out.

“In its draft guidance, FDA says consumers ‘generally’ do not mistake plant-based alternatives as milk and therefore will exempt these products from such regulation. This is baffling as they admit a fourth of consumers do not know the difference or believe the substitutes contain milk,” Farm Bureau said.

USDA used a consumer survey statistic indicating 75% of respondents understood milk alternatives do not contain milk as a reason to allow flexibility with the term. But 25% of shoppers are confused over whether the alternatives contain milk.

That 25% is a massive segment of consumers, representing 83 million people in the U.S. Consumers who buy milk alternatives thinking they contain milk or are milk could jeopardize the health of their families, Farm Bureau said.

“FDA confirms that labeling plant-based beverages as ‘milk’ confuses consumers from a nutritional equivalency standpoint,” Farm Bureau said.

About 90% of the U.S. population does not meet the recommended consumption of dairy products based on U.S. dietary guidelines. Milk alternatives are not included as part of the dairy group in those guidelines because their overall nutrient content is not similar to dairy milk.

“Misleading marketing that leads consumers to replace an intrinsically healthy product with an inferior product … is not appropriate, especially when the health of infants and children is at risk,” Farm Bureau said.