
In January 2025, the U.S. Food and Drug Administration’s (FDA) released Labeling of Plant-Based Alternatives to Animal-Derived Foods: Draft Guidance for Industry. I’d like to provide an overview of the latest trends in plant-based food labelling regulations across various countries, viewed from Japan.
The U.S.
As mentioned above, the guidance on alternatives for animal-derived foods was released in January of this year. The scope of this guidance includes plant-based alternatives to eggs, seafood, poultry, meat, and dairy products (excluding plant-based milk alternatives). For guidance on labelling plant-based milk alternatives and voluntary nutrient statements, please refer to Draft Guidance for Industry released in February 2023.
The guidance primarily aims to prevent misleading labels regarding product names. The main points of the guidance are as follows,
– Plant-based alternative foods, which do not have established definitions or identity standards, are classified as “non-standardized foods”
– Labels for these non-standardized foods should clearly indicate the specific plant source(s) (e.g., soy, lentil, walnut, etc.)
– Simply labelling them as “meat-free” or “dairy-free” is not recommended The guidance on plant-based milk alternatives includes nutritional guidance, such as labelling to highlight differences in nutritional values between plant-based milk alternatives and milk (referring to Appendix 1) and recommending indication of lower amounts of certain nutrients than found in milk. (Other examples of cautionary labelling for the nutritional content of milk alternatives can also be found in the labelling standards of Australia and New Zealand (2018))
Canada
In October 2024, Proposed guidance: How to label and represent plant-based alternatives to egg products was released. In addition to font size and words, there are provisions to prevent misleading impressions from images (e.g., Image of a farm). Claims such as “30% less fat than chicken’s eggs” must meet the specific requirements for nutrient content claims. For claims such as “egg free”, allergen labelling must also be considered.
France, Czech Republic
In January 2025, the Council of State of France annulled the decrees prohibiting the use of terms such as “steak” on plant-based products. The decrees were initially established in June 2022 and February 2024, but were subsequently opposed by the Court of Justice of the European Union in October 2024, leading to the repeal. Following this announcement, indicating terms such as “soy steak” and “vegetable sausage” are now permitted again. In January 2025, the Ministry of Agriculture of the Czech Republic announced it would not implement any changes to the requirements concerning meat, fishery products, eggs, and their products (regarding the regulation of “meat” labelling for plant-based products, 2024). (Note: EU has established requirements regarding the labelling of milk products (whey, cream, butter, etc.))
Thailand
In July 2024, the Thai Food and Drug Administration (FDA) announced that it is actively preparing to enter the plant-based protein market. Thai FDA solicited public comments on a draft proposal outlining labelling requirements and other regulations for plant-based protein alternatives in May 2024. The relevant standards are expected to be published after further review.
In Japan, the Q&A on Labelling Plant-Based (Plant-Derived) Foods was released in 2021, requiring indications such as “made from soy” in addition to the product name to prevent any confusion. Additionally, in 2022, Textured soy protein products under the Japanese Agricultural Standards (JAS) were established, stipulating requirements on labelling such as “肉を使用していません(En: This product does not contain meat)”.
Labelling for plant-based foods has been a topic of significant interest, along with FOP (Front-of-Pack) labelling, HFSS (High in Fat, Sugar, or Salt) regulations, and PAL (Preventive Allergen Labelling). We would like to take up any major revisions or updates to these regulations in this Newsletter in the future.
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Label bank Co., Ltd. CEO (Founder)
Born in Japan. Working on solving various issues related to food labeling operations. Also regularly gives lectures for various organizations in Japan.
Co-author of ‘Latest edition: Guide book Food Labeling Law and related business practical points – from scratch (Japanese version only)’ (DAI-ICHI HOKI CO., LTD/2019).