Plant-based Beverage Name Regulation

Good day all,

I have been given the task of finding out what we are and are not allowed to call our plant-based products. We are primarily focused on plant-based dairy alternatives ('milk' and 'creamers').

It's clear enough that, in the Canada and the United States at least, we are restricted from calling it a 'milk' without appropriate fortification, which is fine. I believe we are going with 'Milked Oats' or something along those lines.

That being said, I am having difficulty understanding whether or not there are restrictions on plant-based 'Creamers'. Are there government restrictions from CFIA or FDA that limit the use of the word 'Creamer'? It is somewhat confusing as for numerous products here in Canada, plant-based beverages frequently say 'For Coffee', whereas some from the United States state something along the lines of 'Non-dairy Creamer' or something.

I've tried looking into the void of both CFIA and FDA's online websites, but am no closer to making a conclusion. If someone has had experience with this or can direct me to a URL or person who may know, it would be greatly appreciated.

Thank-you and regards,

Gareth

You can call it VEGAN CREAMER or NON-DAIRY CREAMER. We produce plant-based products: kefir, yogurt, cream cheese and sour cream. The names vary from "dairy-free kefir, probiotic fermented coconut milk" to "cultured coconut milk yogurt alternative". All are made for one of the biggest retail chain. No objections from CFIA - though, I have no info re: FDA requirements.

So i happen to have a carton of Silk for coffee in my office fridge

They've called it "coffee whitener"

You probably cannot say "milked oats" as that is misleading (you cannot "milk" an oat plant ergo, misleading for the folks in the back row.  The word MILK cannot be used as it is regulated and has a standard of identify  https://inspection.c...1/1521473555532

The term "milk" cannot be used generically to describe all types of fluid milk in all labelling situations.

In order to meet the common name requirement, the term "milk" is a reference only to "milk" as standardized in section B.08.003 of the FDR. For other types of milk, the prescribed common names as shown in bold face type in Division 8 of the FDR or in the Canadian Standards of Identity, Volume 1 – Dairy Products must be used. Likewise, in the list of ingredients, either the prescribed common names must be used, or the term "milk ingredients" may be used as per item 7, Table 2 of the Common Names for Ingredients and Components document [B.01.010(3)(b), FDR].

Reference to the term "milk" is considered to mean milk in the generic sense when Regulations refer to formulations designed for mixing with milk, for example, under D.03.002 of the FDR. These formulations may be mixed with any "milk" (for example, skim milk, partly skimmed milk, whole milk, either reconstituted or fresh, etc.).

The directions for use or any other similar references found on labels or in advertisements should state the exact type of milk which is to be used (for example, "made with partly skimmed milk").

Declaration of the percentage milk fat of milk used as an ingredient is considered a non-permitted nutrient content claim. It is only permitted when used in conjunction with a permitted nutrient content claim.

The claim "non-dairy" or "dairy-free" cannot be used for products containing milk derivatives such as caseins or sodium caseinate

https://inspection.c...0/1625516122800

In summation, dairy free, non dairy or coffee whitener are all acceptable, tread lightly with the word MILK