---

Dear Editor,
On 02/23/2023, the Food and Drug Administration (FDA) released DRAFT guidance (This draft guidance is not final nor is it in effect at this time.) on "Labeling of Plant-Based Milk Alternatives and Voluntary Nutrient Statements: Guidance for Industry" which can be viewed at:
fda.gov/media/165420/download.
The FDA proposed plant-based, dairy-free milk can be called 'milk' and asks for public feedback.
Submit either electronic or written comments by April 24, 2023, identified with this docket number - FDA-2023-D-0451.
Background.
The number of plant-based non-dairy beverages has exploded.
In the U.S., almond milk is the most popular variety, but oat milk has been seeing the fastest growth.
Still non-dairy sales are dwarfed by traditional milk. Sales of refrigerated cow's milk grew to $12.3 billion in the 52 weeks ending January 28, 2023 compared to $2.5 billion for non-dairy milk according to NeilsenIQ.
The FDA established a standard of identity for milk in 1973, and it defines the dairy* product as "the lacteal secretion, practically free from colostrum, obtained by the complete milking of one or more healthy cows."
(The FDA does not have a standard of identity for plant-based milk.) 
What is almond milk?
Five brands of unsweetened unflavored almond milk (available from Target and Walmart) list as their first ingredient**: Almondmilk (Filtered Water, Almonds).
All brands list: calcium carbonate, gellan gum, sea salt, and sunflower lecithin as ingredients (listed here in alphabetical order, not by weight).
Some brands listed other ingredients (also in alphabetical order) such as: D-Alpha-Tocopheral (natural Vitamin E), guar gum, locust bean gum, natural flavors, potassium citrate, vitamin A palmitate, Vitamin D2, Vitamin E acetate.
Almond milk contains 1 gram of protein in an 8-ounce serving.
Compare that with:
Milk, lowfat, 1% milkfat, with added vitamin A and vitamin D.
Ingredients: lowfat milk with Vitamin A palmitate and Vitamin D3.
An 8 ounce serving contains: 8 grams protein, 9 minerals, and 10 vitamins.
*To clarify: fortified soy milk is the only plant-based food included in the dairy category of U.S. dietary guidelines because of its nutrient levels.
**Ingredients are listed in descending order by weight. So the ingredient that weighs the most in the product is listed first.
Eileen Z. Fitzsimons
Dodgeville, WI