I realize I am dating myself with the title of this blog, but as they say, “What is old is new again.”

This time, though, it should be “Where’s the meat” or “Where’s the poultry?”

I am referring to the use of USDA standards of identity that define meat and poultry products being used on the label of plant-based products such as plant-based “bacon.” Last week France became the first country in the EU to ban the use of terms that define meat or other animal-based products to describe plant-based products. Terms such as “sausage” and “steak” can only be used to describe animal-based products. The only exception is the term “burger,” which is more ambiguous and allows for the inclusion of other non-meat materials, which is similar in the US.

Specifically, the ban reads as follows, “It will no longer be possible to use terms proper to sectors traditionally associated with meat and fish to designate products not belonging to the animal world.” France has taken an important step — and we should take note and follow suit in the US.

This is more than a mislabeling issue and it is not meant to bash plant-based products by any means. It is an action needed because it misleads consumers along with other concerns.

First, if there is an outbreak and a consumer is asked to retrace their consumption of product, it is possible that they perceived that they consumed a meat/poultry product when in fact it was plant-based. When a label misleads a consumer, the outbreak investigation could be misguided.

Secondly, there is a nutritional issue. Plant-based products do not carry the same nutritional composition of meat and poultry products and consumers have an expectation of particular nutrients (iron, complete proteins, etc.).

And finally, there is a risk of allergic reactions or other ill effects that could occur if a consumer perceives they are consuming meat when in fact it is a plant-based product. Soy along with other plant proteins carry particular risks in terms of allergens. When shopping online when I lived in D.C., plant-based ground products were returned in a search for “ground beef” as if it was the same thing.

USDA has a standard of identity for many products, including jerky, ground beef, bacon, meat and poultry. They have the regulatory authority to have oversight of these products as granted by Congress. As most of you know, meat and poultry facilities operate under continuous inspection while FDA regulated products do not.

When I was at the agency, the inspectors did a retail survey to identify plant-based products bearing names of meat and poultry products with standards of identity that were regulated by FSIS. These products included plant-based bacon, chicken nuggets, jerky products and various other items. The information was shared with CFSAN at FDA on multiple occasions with documentation including photos of the labels. The answer given to USDA was, “We sent them a letter.” That is all and nothing ever changed.

The misuse of standards of identity seems to be growing because there are no actions taken by FDA. Additionally, stakeholders were reaching out asking USDA to hold these entities accountable to their misleading labels. However, the regulatory authority did not fall within FSIS and we urged the stakeholders to reach out to FDA.

The standards of identity will become irrelevant if action isn’t taken. If a product proclaims to be a USDA-regulated product as determined by a standard identity, then maybe they should fall under USDA inspection, meeting all standards other USDA facilities meet. They should have validated processes and must meet compositional analysis.

I know this is highly unlikely, so I suggest a different approach: Continue to put pressure on the FDA. They need to know the risks and the impact it has on the meat and poultry industry. If needed, petition them and ask for regulatory enforcement. We have witnessed what has happened with the terms “butter” and “milk” in recent years. We do not want that to happen in this industry.

Where's the beef???

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