IDFA and the National Milk Producers Federation continue to push for the Food and Drug Administration to allow all ultrafiltered (UF) milk to be used in cheesemaking without requiring special labeling. In a joint letter sent to FDA officials last week, IDFA and NMPF outlined why certain labeling requirements proposed by the agency are impractical and offered suggestions for crafting an exemption based on FDA precedent.
Since FDA released its 2005 proposed rule on ingredient labeling, IDFA and NMPF have argued that UF milk, which is milk with the whey stream removed, should remain under the collective designation "milk" in the product label ingredient list. Because the whey stream is also removed in traditional cheesemaking, the milk used in the process is exactly the same product as UF milk, and cheese made with UF milk is indistinguishable from cheese made from milk.
The letter, which continues a conversation the associations held with FDA officials in January, calls for using the collective term 'milk' in place of declaring "milk and/or ultrafiltered milk" on the label.
"The collective term 'milk' is consistent with FDA precedent, the commercial framework and the enforcement policy that has been in place for milk and UF milk in cheese for the past 10 years," the letter states. "It is difficult to imagine how the failure to declare UF milk would harm or deceive consumers, particularly since under the proposal, firms may continue to ultrafilter milk to make cheese without any special labeling, so long as the ultrafiltration takes place in-plant under an alternate make procedure."
Although externally produced UF milk is used by cheese plants in small and variable amounts, the proposed rule would require every subsequent product using cheese to track whether any supplier in the chain had used UF milk. In the letter, IDFA and NMPF demonstrate how previous action by FDA has allowed collective labeling to help manage the challenges of complex downstream effects.
"The use of a collective term will allow industry to meeting processing and consumer needs without unreasonable costs," the letter concludes.
Read the letter here.
For more information, contact Clay Hough, IDFA senior group vice president, at email@example.com or (202) 220-3516.