OFA provides comments to the review of guidelines for simulated meat and simulated poultry products. OFA strongly supports the review of the federal guidelines for simulated meat and simulated poultry products and the addition of new guidelines for certain plant-based protein products. The proposed guidelines have been updated to differentiate between simulated meat and poultry products from those which are neither meat nor poultry, and not intended to substitute for these products. OFA encourages consumer choice and competitive markets; however, we believe in accurate, truthful, and easy to understand labelling of products which do not mislead consumers and allows for informed choices. OFA supports clear, concise guidelines that are necessary to support industry in their understanding and support of informed purchasing decisions for consumers.
OFA supports the requirement for the word “simulated” being used in the description of the product when referring to animal species. To decrease consumer confusion and to increase clarity regarding nutritional profile, plant-based protein products should be labelled distinctly as “containing no meat” or “containing no poultry”. Consistency between terminology, product definitions, and labelling requirements is also critical. Additionally, OFA supports that plant-based products should not be allowed to make comparative claims to being nutritionally equal or superior to animal-based products, as they are simply not comprised of the same component material. OFA welcomes the opportunity to provide feedback on the proposed updates to the guidelines for simulated meat and simulated poultry products.