OPINION: Abuse of dairy is long-running orchestration of deceit

By Sherry Bunting, Farmshine, March 3, 2023

In what appears to be scripted unison, the disappointing draft guidance on imitation milk labeling, published by the FDA on Feb. 22, is timed perfectly for Danone’s new advertising campaign to position its Silk Nextmilk as “the better milk.”

This includes putting imitation ‘Nextmilk’ mustaches on the adult daughters and sons of several “Got Milk” celebrities that donned real milk mustaches decades ago.

Never has the flagrant abuse of misleading marketing been more corrupt.

Danone officials have been quoted in news releases saying their NextMilk campaign is aimed at “inspiring a new generation of plant-based milk drinkers.”

In fact, Danone is deliberately corrupting the iconic milk mustache of the former MilkPEP ‘Got Milk’ campaign, which was originally launched by the California Milk Processor Board that started Got Milk 30 years ago.

This move by Danone’s Silk actually mocks producers of Real Milk. 

Several weeks ago, in Farmshine, I authored an article detailing Danone’s timeline on plant-based imitations for the milk, yogurt and cheese categories and the company’s stance on seeing this fake-milk area as the growth market they are investing in.

The recent FDA draft guidance on labeling of plant-based and other imitations is pathetic. FDA has caved to big global corporations seeking to exploit the nutritional benefits that are unique to real milk for their own fake-product financial gains. 

FDA even acknowledged in its draft guidance that consumers are confused about the nutritional differences and that a smaller percentage of consumers may even be confused about whether or not these products contain milk. Somehow, the FDA concluded that consumers are not being misled!

The FDA draft guidance “recommends” a “voluntary” statement about nutritional deficiencies, but this is not mandatory.

Even the voluntary statement criteria are described as being measured against USDA’s Food and Nutrition Service “substitution levels” for key nutrients, not what milk actually contains.

Furthermore, no importance is given in the FDA draft guidance to the differences between calcium additives and natural bioavailable calcium. No importance is given to milk as a COMPLETE protein with all 9 essential amino acids we must get from our foods and beverages because our bodies don’t make them.

Animal-derived protein, like in dairy and meat, contain all of these amino acids. Plant-derived proteins only contain some of these amino acids. Consumers need to know this.

There is much to say about the FDA’s track record of ignoring its own standards of identity for milk and other dairy products. The current administration shows little respect for milk’s integrity in the new draft guidance and other bureaucratic moves.

What will the dairy checkoff programs do about the manner in which Danone is stealing and perverting past real milk campaigns to dupe consumers into thinking NextMilk is real and better? What will be done about the packaging made to resemble whole milk?

We asked that question in an email to DMI’s press office and are still waiting for a response.

(UPDATE: The following response was provided to Farmshine by the DMI press office two days after this article was published: “The trademark registration for the ‘milk mustache’ expired and was not renewed by the organization which managed the campaign. And while imitation is the sincerest form of flattery, the national and local dairy checkoff teams along with MilkPEP, NMPF and IDFA remain focused on engaging consumers with the nutritional value that dairy from a cow provides. It’s important to note plant-based alternatives overall are down 2.6% year over year, according to IRI data.” )

To me, it appears the dairy checkoff organizations are unconcerned. We have researchers paid with checkoff dollars looking at ways to fractionate milk and develop new protein drinks that address other desires of consumers — practically giving in to their survey findings that consumers don’t think dairy protein has any advantage over plant protein. 

BUT IT DOES! Why are we not pushing that message? Does USDA forbid such comparisons by checkoff organizations? Or is that a convenient excuse?

Now is not the time to give up the fight. Now is not the time to say, oh well, protein is protein so let’s blend them and make new beverages or let’s focus on other ways to draw consumers. Now is not the time to be shy, but to be bold.

Now is the time to push the education of consumers and rally the troops to support real milk and dairy.

All of the checkoff emphasis on ‘sustainability’ is not going to sell milk.

All of the emphasis on Gen-Z and ‘meeting consumers where they are’ is not going to sell milk.

Gen-Z has been robbed of the opportunity to have good tasting whole milk in school where they grow up receiving two meals a day, five days a week, three-quarters of the year with the only milkfat option being fat-free and 1%. They have been sold a bill of goods by Big Food while farmers have paid billions out of their own pockets in checkoff funds over the past 12 years to ‘play nice’ with the enemy.

To be honest, soy beverage has always been an alternative for those who can’t consume milk, and it remains the most nutritious of the fakes. But the proliferation of fake imitations is now just completely out of control, and most of these beverages aren’t much more than water, flavor and additives.

Danone is using “artificial intelligence” to redesign its imitation products. This global giant takes the lazy and perverse path of stealing not only milk’s name through misleading advertising, it is using a former real milk advertising campaign to promote an imitation product. 

Danone is packaging Silk’s fake imitations in red and white cartons to resemble whole milk in the supermarket dairy case, and even adding the words ‘whole’ or ‘whole fat’ under the brand name to make consumers THINK it’s the whole milk more people are turning to. 

In 2019, Danone even trademarked the phrase and artwork for its imitation beverage: “Silk – the original nutrition powerhouse”.

Silk? Original? Nutrition Powerhouse? Give me a break!

Danone is thumbing its nose at dairy farmers and using “sustainability” as the virtue signal to get away with these perversions.

In fact, I got a text message from a farmer this week who caught the tail end of a Today Show spot on television, where they interviewed the Danone Silk models, wearing Nextmilk mustaches like their celebrity mothers or fathers did years ago in the Got Milk campaign. 

This farmer thought actor John Travolta was going to do a Got Milk mustache campaign. But no, Danone hired his daughter to do a Silk NextMilk mustache campaign. Even the Today Show headline called it a ‘new milk campaign’ and highlighted the way the FDA draft guidance makes it all possible. 

No one was there to talk about the nutritional differences or to talk about real milk. 

Americans are being misled, dairy farmers are being thrown under the bus, and children are being deprived, while government agencies facilitate, and checkoff organizations twiddle their thumbs or say their hands are tied. 

We are thankful there are champions in the United States Congress who have introduced legislation to try to turn these circumstances around. We are thankful that Pennsylvania lawmakers are working on resolutions to file with federal government agencies on these proposed rules.

We are thankful for people like dairy producer and country singer Stephanie Nash of Tennessee who was interviewed on the Fox Business channel about the FDA guidance. She put it straight: ‘Milk comes from cows, not a lab.’ 

This is going to require all of us to get involved.

Here’s what you can do:

Call your Senators and Representatives and ask them to cosponsor the Dairy Pride Act and Whole Milk for Healthy Kids Act.

Call your state lawmakers and ask them to pass resolutions in support of whole and 2% flavored and unflavored milk options in schools and then formally file those resolutions on the open USDA proposed rules docket.

Sign and promote others to sign the Whole Milk in Schools petition at https://www.change.org/p/bring-whole-milk-back-to-schools

Write a brief public comment and urge others to comment by April 10 on the USDA school nutrition proposed rule that would limit flavored milk in schools. Simply tell USDA our children need the nutrition whole milk provides, so school meals should include the options of whole and 2% unflavored and flavored milk. Comment on that docket at link https://www.regulations.gov/commenton/FNS-2022-0043-0001

Write a brief public comment and urge others to comment by April 24 to the FDA to stop allowing beverages that aren’t milk to be labeled as milk. Comment on that docket at https://www.regulations.gov/commenton/FDA-2023-D-0451-0002

And stay tuned on how to get involved as the next round of USDA Dietary Guidelines Advisory Committee deliberations recently got underway. The stage is already set for more demonization of milkfat and abuse of milk’s integrity there as well.

This abuse of milk cannot stand. It’s going to be up to us — the grassroots farmers and citizens — to stand in the gap for what is right.

With science-fiction, they socially herd us like cattle to ‘alternative’ squeeze chute

By Sherry Bunting, Farmshine, February 22, 2019

All circles lead back to marketing, which is on display right now with the EAT Lancet report in January and the EAT Forums and social marketing that are hitting us in rapid succession, having already filtered into the Green New Deal in Washington and other legislation proposed in California.

Dr. Frank Mitloehner, a greenhouse gas (GHG) emissions expert from the University of California, Davis is not the only one questioning the GHG findings in the report.

He offered proof this week that the science director for the EAT Foundation, in an email (below), admitted the report’s dietary recommendations are not based on environmental considerations, they are based on – you guessed it – a hyper-charged version of the flawed dietary guidelines that have been making us, especially our children, fatter and sicker through ever-increasing government control of food choices!

This is a clear admission that the GHG figures being peddled are, as Mitloehner put it in Lancaster recently “without a single leg to stand on.”

This brings everything back to the common denominator in the ongoing social engineering project: USDA Dietary Guidelines.

In the pages of Farmshine for years (through two dietary guideline cycles, 10 years to be exact), we have warned about the Dietary Guidelines.

For months, we’ve sounded alarms about the genetically-altered yeast making ‘dairy without the cow’.

For weeks, we’ve been tracing the alliances of the Edelman company that has done the marketing and PR for DMI for 20 years and is also doing the social marketing and communication strategies for EAT Lancet.

That story was laid out here last week.

This week the EAT Lancet Commission’s desire for drastic reductions in meat and dairy consumption grew major legs as the Edelman social marketing machine — via staff loaned and now working as employees of EAT’s corporate initiative — have been in full artillery mode with our nation’s dairy and beef cattle in the crosshairs.

The right hand has been telling us we have a seat at the table, while the left hand has been working overtime to pull out the rug.

I’ll borrow this term: Resist! The Science Fiction EAT Lancet report is slowly but surely being spoonfed without a transparent airing in the press.

The EAT Lancet Commission had little actual press since 2019 launch, but not to worry! The global food tranformation effort (EAT Lancet, EAT FReSH) is coordinated by the world’s largest marketing and PR firm — spawning the seemingly random and unconnected legislative and marketing campaigns from the Green New Deal and new global diet ‘wisdom’ (flexitarian / reducitarian) to the outright lies about cows in foundation versions of prominent news organizations like Reuters, Bloomberg, The Economist, The Guardian and positioning of the new PepsiCo’s Quaker Oat beverage launch inprime dairy case real estate this week, to the unveiling of Danone’s new non-dairy yogurt plant in Dubois, Pennsylvania geared to “take plant-based products to the max.”


PepsiCo and Danone are two of the 41 corporate sponsors of the EAT Lancet global food transformation propaganda, and they are launching their ‘solutions’ right now. PepsiCo launched it’s Quaker Oat beverage this week, and it’s showing up prominently in dairy cases like this one. Danone unveiled the largest ‘dairy free’ yogurt plant in the world in Pennsylvania a few weeks ago, with its new ‘sustainable’ yogurt products reaching store shelves also in time to capitalize on the EAT FReSH social marketing campaign. Photo submitted by a Farmshine reader in northwest Indiana 

A convergence of the elite. It’s really one big thing, connected. The funding corporations are rolling out their food ‘solutions’ as we speak, hoping unwitting consumers will jump on the food-transformation-train.

I am resisting any brand that participates in this tomfoolery. 

EAT FReSH corporate sponsor Danone launched their marketing campaign for the new “dairy free” yogurt now made in Pennsylvania, and it has EAT Lancet taglines written all over it.

Of course, Danone is also a client of Edelman. So is PepsiCo.

Follow the money, folks.

Inside this high-stakes game is the world’s largest marketing and PR firm coining elite catch phrases about “eating within planetary boundaries” — you know — to save the planet, and other such “purpose-driven marketing” they are known for.

(Technically, the account director of Edelman Amsterdam planned and organized for two years as employee on assignment with the World Business Council for Sustainable Development (WBCSD), which is the organization launching the EAT FReSH initiative with the 41 corporate sponsors, including Edelman. When the EAT Lancet Report and EAT Forums did launch in mid-January 2019, Lara Luten left Edelman’s employ at that point to become the full time director of the communications and social marketing plans that have been laid).

Boil it down. The nobles are telling the serfs: Forget animal protein, ‘Eat cake!’

I’m not against dairy alternatives, they should be available. We are omnivores. Plants need animals and animals need plants and we need them both.

What I am against is global propaganda that positions itself as science and is being used to socially herd us like cattle to the plant-based chute without the integrity to tell us it’s a bridge to genetically-altered-laboratory-designer-proteins (aka fake-meat and fake-dairy) grown in vats and bioreactors. 

Roughly 70% of the available land for food production is grasslands and marginal lands. It is these lands that cattle can graze or where forages for cattle are harvested in systems much different from row crops and vegetable plots. 

Cows upcycle low quality feedstuffs and plant byproducts that we can’t use, and they turn it into nutrient dense, delicious milk and beef. (Those grasslands and forages sequester carbon too!!)

Animal Ag emits less than half of the total greenhouse gas emissions for all of agriculture, and if we look at this per unit of nutrition, it’s amazing.

Animal Ag (dairy, beef, pork, poultry all combined) are responsible for just 3.9% of the U.S. greenhouse gas (GHG) inventory, but EAT Lancet tells a different story, and the lies are being exposed.

Just imagine how much stress will be on our so-called “planetary boundaries” if science fiction and social purpose-driven marketing prevails and more of us are “herded” or fooled into replacing more of our animal-based dietary nutrients with plant-based sources. It can’t be done. 

This is a Silicon Valley bridge to the billionaire-funded bioreactor factories to grow (3-D print) replacement protein from gene-altered yeast or gene-edited cell blobs. In fact, Microsoft founder Bill Gates was on CNN with Fareed Zakaaria Sunday talking about “cow farts being one of the world’s biggest problems” and the need for lab-cultured animal protein … to save the world. (Let’s be all the dumber for watching that interview clip here)

What Mr. Gates forgot to mention is his considerable investment in this disrupter technology of fake-meat, and that Microsoft is a corporate sponsor of EAT FReSH / EAT Foundation.

Yes, more science-fiction propaganda in the form of so-called purpose-driven marketing is coming from all sides and hyping up fast because the billionaire investors and food supply chain corporations need this social herding process to launch their new products. It’s not about people and it’s not about the planet, it’s about profit — at our expense!

No thanks here. I’m jumping the gate. The social-herders have gone too far.

-30- 

Top photo credit Michele Kunjappu

How will fake milk, fake meat be labeled and regulated?

Say, what? New twist on standards of identity: How will fake milk and fake meat be labeled and regulated?

cows.jpg

In a time when many people have lost their connection to the values and sustainability of the circle of life, cattle have been getting an undeserved bad rap on everything from diet to environment to compassion. On all three counts, the anti-animal agenda lies behind the false narrative that is leading us down a dishonest path to more fake concoctions of ill-fated science fueling profits at the expense of our physical and emotional health and the health of the planet. Fake meat and fake milk are funded by billionaires, genetically engineered by USDA, initiated as the brain children of Silicon Valley techies, with partnership from the biggest names in corporate agriculture. Noble goals of ending hunger are the defense, but it’s difficult to believe that when we have surplus dairy and meat protein produced naturally with the real problem of hunger coming down to distribution and waste. This so-called solution has the potential to quietly dictate food choices, markets and livelihoods.

By Sherry Bunting, updated since first published in Farmshine, November 21, 2018

WASHINGTON, D.C. –  “Dairy reinvented: Sustainable. Kind. Delicious,” is the tagline of Perfect Day’s website.

“Better meat, better world” are the words that jump from the Memphis Meats website.

To be more specific, Perfect Day’s mission is to “create a better way to make dairy protein, the same nutritious protein found in cow’s milk…without the help of a single cow.”

Meanwhile, at Memphis Meats, their mission is “To bring delicious and healthy meat to your table by harvesting it from cells instead of animals… feel good about how it’s made because we strive to make it better for you… and the world.”

On the fake meat side, Memphis Meats received Series A funding from four sources in August 2017: venture capitalist DFJ, billionaire investors Bill Gates and Richard Branson, and Cargill. In January of 2018, Tyson came on board as an investor.

On the fake dairy side, Perfect Day received its Series A funding from Singapore and Hong Kong venture capital and investment companies that have relationships with some of the largest food and beverage companies and brands in the world, according to a company news release. In addition, Continental Grain was part of the early investment, and in November 2018, Perfect Day announced a partnership with Archer Daniels Midland (ADM).

The big question, at present, is how will these proteins be regulated and labeled?

The discussion is converging with FDA’s nutrition innovation strategy and modernization of standards of identity (especially dairy standards of identity), along with parallel hearings and comment periods on how to regulate and label the ‘meat’ version of lab-created cellular proteins.

Make no mistake about it folks: Both of these processes involve genetic engineering start-to-finish.

Perfect Day (fake milk protein), for example, sources yeast from USDA research labs that has been “genetically-altered” to include bovine protein stimulators and synthesizers.

Memphis Meats (fake meat) uses animal cells, mainly bovine and poultry, from cell banks that have been edited to grow only desired muscle cells — separate from their whole-animal source.

The fake dairy protein would be the end-product of the fermentation of the genetically-altered yeast, while the fake meat protein would be the protein blobs that grow from the genetically-edited cells, using neonatal bovine serum — or a plant chemical substitute that is under development — as a growth “on” button.

Both systems would require energy feed sources, using a sugar and/or starch substrate to feed the growth.

Both processes would produce waste streams.

The dairy version are grown in fermentation vats. The meat version in bioreactor towers.

While opinions vary on how quickly these technologies can scale, it is clear that the technologies are well-funded, and that agriculture’s top-tier food supply-chain processors and distributors are partnering.

We must continue to let FDA and USDA know what farmers and consumers — the two ends of the supply chain that need to be talking to each other — feel about the potential of these technologies to create captive-supply market control using interchangeable proteins in common manufactured dairy products or as protein enhancements for plant-based beverages, as well as to stretch boneless beef and poultry products with fake counterparts, namely as ground beef, hamburger, meatballs and chicken tenders and nuggets.

In a press release Friday, November 16, the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) announced that they will “jointly oversee the production of cell-cultured food products derived from livestock and poultry.”

There has been no similar FDA PMO-regultory process established for the fake milk proteins.

USDA and FDA had a public meeting in July and October to discuss the use of bovine and poultry “cell lines” to develop these cell-cultured, lab-created foods.

In fact, meat industry stakeholders shared their perspectives on the regulation that is needed to “foster these innovative food products and maintain the highest standards of public health,” said FDA commissioner Scott Gottlieb in an official FDA statement in November.

USDA and FDA announced their “agreement on a joint regulatory framework wherein FDA oversees cell collection, cell banks and cell growth and differentiation. A transition from FDA to USDA oversight will occur during the cell harvest stage. USDA will then oversee the production and labeling of food products derived from the cells of livestock and poultry.”

As FDA and USDA are “actively refining the technical details of the framework,” some of the aspects of the framework are said to include robust collaboration and information-sharing between the two agencies to allow each to carry out our respective roles.

The well-funded startups and their lobbying organization Good Food Institute (a misnomer in this author’s opinion) had pushed for FDA to control labeling and inspection knowing that if USDA were in charge, their efforts to scale production would be slowed.

In view of this joint approach between FDA and USDA, the original public comment period about cell-cultured ‘meat’ had been extended to December 26, 2018. Comments can be seen at the FDA docket at https://www.regulations.gov/document?D=FSIS-2018-0036-0001  and there are thoughts that this comment period could be extended again as has the dairy standards of identity comment period.

Meanwhile, on the lab-created ‘dairy’ protein front, Perfect Day, a Silicon-Valley startup, announced in a press release in November that it has formed a partnership with ADM, an agricultural processor and food ingredient provider with a mission of plant-to-plate collaboration throughout the food industry.

In fact, ADM will provide facilities for scaling this technology as part of the deal.

This partnership is billed as “teaming up” to begin supplying “the world’s first animal-free dairy proteins to the food industry in 2019,” according to Perfect Day.

“Animal-free dairy proteins will not only offer consumers the option to have a lactose-free, animal-free alternative to conventional animal-based dairy, but also provide a portfolio of nutritious and functional, high-purity proteins with similar taste and nutrition profile of dairy proteins for a wide range of food and beverage applications,” Perfect Day said in their press release.

Meanwhile, the FDA has extended — yet again — its invitation for information specifically on “the use of names of dairy foods in the labeling of plant-based products.” So far, 10,043 comments (as of December 28, 2018) have been received on this docket. To comment by the new deadline of January 28, 2019, go to the docket online at https://www.regulations.gov/docket?D=FDA-2018-N-3522.

Dairy checkoff-funded DMI completed a survey of consumers recently showing that 73% are confused about the differences in nutrition between real dairy milk and plant-based alternatives calling themselves ‘milk.’

Other surveys show that more than half of U.S. consumers want healthy foods with ‘clean’ labels having few ingredients and limited or no processing.

It would seem that these findings, among others, would indicate clearly to FDA and USDA that consumers want no more monkey-business when it comes to their food, that they want to see clarity in the enforcement of milk and dairy standards of identity, and that they want to be informed about look-alike ingredients made in laboratories instead of in the time-honored land-and-animal care-taking profession of dairy and livestock farmers and ranchers.

One thing to keep in mind when commenting is to highlight the fact that over half of U.S. consumers want food that does not have a long list of additives and that is minimally processed.

That, on top of nutritional differences and new unproven processes, are enough reason to aggressively label any food containing either the fake dairy or fake meat protein because standards of identity are in place not just for health and safety but also to prevent fraudulent misleading of consumers.

Consumers should know what they are buying and be able to choose food based on their beliefs about what is a better world, not someone else defining what is kind and good and sustainable for them and not using the government’s currently flawed dietary guidelines to decide for consumers what is deemed “healthy.”

Let FDA and USDA know that we as consumers and farmers want clear labeling if these technologies are going to scale into our food system. We want the fake versions to have all of the inspection rigor that real dairy and meat proteins are subjected to.

Above all, we do not want the government quietly removing — via its one-size-fits-all nutrition innovation strategy — our ability to choose foods and production methods with which we want to nourish our bodies and on which we wish to spend our hard-earned money.

This may come down to a battle between fake animal protein ingredients funded by billionaires aligned with Silicon Valley startups and partnered by the biggest names in corporate agriculture vs. a collaboration between individual farmers and ranchers who are the backbone of our nation, the stewards of land and livestock, along with the public at-large, the consumers who are confused by the lines that are blurring.

Now, more than ever, both ends of the supply chain — farmers / ranchers and consumers — need to engage with each other directly — and not through the industry-scripted mouthpieces.

Stay tuned.

-30-

Comment period for milk, dairy identity ends 8/27. Part 2 of 7/26 hearing right here

iStock-544807136.jpgBy Sherry Bunting, from Farmshine, August 17, 2018

WASHINGTON, D.C. – There are 10 days remaining for public comment on FDA standards of identity for milk and nearly 80 other dairy products, along with the other aspects at stake as FDA launched its Nutrition Innovation Strategy to determine – and stamp – healthy choices for consumers while taking steps to “modernize” standards of identity to “achieve nutritional goals.”

The daylong FDA hearing on July 26 was one of several relating to these issues on the FDA docket, and as previously reported in Farmshine, dairy has taken center stage for several reasons.

First, Scott Gottlieb, head of the FDA, responded to calls for FDA to take a closer look at the dairy industry standards of identity, especially for milk. He opened the hearing saying that the agency must first determine “how consumers understand and use the term ‘milk’ to know if the inherent differences between these products is well understood by consumers so we can understand how consumers are being misled.”

The public comments being received by FDA through August 27, are the first step in its multi-faceted approach.

Individual comments on any of these converging standards of identity issues and the Nutrition Innovation Strategy can be sent to FDA prior to the Aug. 27, 2018 deadline at the docket portal here.

Or, send to: Dockets Management Staff (HFA–305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20857. 

The second aspect of this brief comment period is to discuss the standards of identity more broadly.

“We want to hear about changes in science to review and update,” said Gottlieb. “We are hearing the standards of identity can cause the food industry to avoid reformulations that would reduce fat and calories. We want to gather this input and encourage out-of-the-box thinking with the bottom line helping consumers to identify healthier options.”

We covered some of the testimony at FDA’s July 26 listening session in Part One in Farmshine, Aug. 10, 2018.

Here, in Part Two, published in Farmshine August 17, 2018, are more of the elements from that hearing that are so important to know and understand…

Of particular interest on dairy product standards of identity were the hearing comments by Cary Frye, senior vice president of regulatory affairs for the International Dairy Foods Association (IDFA). She commended Commissioner Gottlieb for undertaking the Nutrition Innovation Strategy “to improve nutrition and health.”

While absolutely silent on enforcement of milk’s standard of identity, despite representing the nation’s milk and dairy food processors, Frye said, “the key area we are working on is to modernize the standards of identity for dairy products, which make up more than one-third of the 280 standards of identity currently on the FDA books.”

She said these standards “are outdated and stand in the way of innovations and novel processes. Current systems are not working and definitely need to be reformed.”

Frye noted that the cheese standards have been unchanged while ultrafiltered milk processes have been around for 20 years. “Clearly a new approach is needed for processes like this to be used to create new and healthful products.”

She said “processing milk by filtration to concentrate proteins and remove lactose is embraced around the world, but these new processes are not permitted in our dairy products with the current standards.”

Frye did, however, thank the FDA for what she described as FDA’s “recent guidance allowing ultrafiltered milk as an ingredient for cheeses.”

“But the agency needs to go further and make dairy a top priority for modernized standards of identity,” said Frye on behalf of IDFA. “We must incentify innovation. We can’t make these investments if we must petition for standards that take decades to complete.”

Along with standards, FDA wants to modernize label claims as a key element of the nutrition innovation strategy, to give consumers “quick signals” with important information on the nutritional benefits of food choices.

A key question FDA is looking at is: What claims best stimulate innovation to create products that are better choices?

Speakers at the hearing identified food trends, saying consumers are committed to a more balanced approach between nutrition and function, but also the idea of food, that it is part of how they experience life, with taste becoming more important to consumers than nutritional profile as they move away from “lowfat” foods.

(Unfortunately, this FDA strategy has not yet acknowledged there are health-related and nutritional reasons for consumers to move away from “lowfat” dogma of the past 30 to 40 years. My comment to the FDA docket will include sending by mail, a copy of The Big Fat Surprise, by Nina Teicholz, who will join me in sending copies of this book to FDA?)

As in many of these discussions, the generational shifts in food trends and choices are the most noticeable. Hearing presenters noted that millennials are pursuing “clean eating and natural foods” as more important than a nutrition-based label.

With that in mind, upholding and enforcing the current standards of identity for milk and dairy products becomes important since it is simple compared with concocted imitation formulations with long lists of ingredients unable to provide all of the nutrition milk has – naturally.

Hearing presenters also acknowledged that the declines in consumption of meat and dairy over the past 40 years have just begun to “shift back the other way.” People are returning to the fresh perimeter of the grocery store.

(Again, no mystery here, FDA needs to read the book: The Big Fat Surprise)

With millennial food choices driven by a so-called “return to purity,” my thoughts as I listened to the July 26 FDA Nutrition Innovation Strategy hearing is this: Will FDA move incrementally toward giving consumers what they want, while slipping into that desired food the science and innovation the FDA and food industry believe consumers need… in order to “get” the FDA ‘healthy choice’ stamp – however that is ultimately defined in this multi-year strategy and however it is ultimately designed for packaging?

These are big things to watch and participate in.

This is not to say that some new standards aren’t needed. Rob Post for Chobani, testified that they produce a nutrient dense, healthy, strained Greek yogurt, but because no standard of identity exists for this type of yogurt, they are challenged to have standardized nutrition profiles “that account for the 52% protein content in Greek yogurt” when used in institutional feeding programs like the National School Lunch Program.

“Today’s consumers have evolving demands and a new set of food values,” said Post. “Health is important, but so are other values and drivers.”

Others noted that the current standards of identity “do not allow lower salt content for cheese.”

This could be an issue when it comes to nutritional cheese getting a ‘healthy choice’ FDA stamp in the future, if such stamps are based on what are now questionable low-salt directives for healthy eating.

“Standards are important because they assure the consistency of the product, its authenticity and nutrition,” said Post.

Laura MacCleery, Policy Director, Center for Science in the Public Interest testified that, “Americans overconsume saturated fat.” They are among the contingent of wanting to work on labeling to steer consumers away from saturated fat.

Meanwhile, the American Heart Association testified to FDA that they want the standards of identity “modernized to improve the nutritional value of food by reducing both sodium and saturated fat.”

On the flipside, members of the dairy processing industry said they are looking for standards to be modernized to abolish the milk fat minimums and allow lower sodium on natural cheeses that currently have rigid standards of identity. Dairy processors testified that this is necessary to conform to the nutritional focal points of this discussion – salt and fat – that are still based on current dietary guidelines.

Will FDA grant these wishes and will we see lowfat and low salt cheeses introduced as “the real thing” because the standard has changed based on a dietary guideline many in the scientific community are already saying is a flawed guideline?

You can see the intertwined dilemma this FDA Nutrition Innovation Strategy could spawn.

Taste is king, according to the food processors speaking about low salt claims. They said they go ahead and formulate low salt varieties, they just are not always advertising it on the packaging space.

Will modernization of standards of identity low-salt and low-fat our food – our cheese for example — without our knowing it or being able to choose? Do we care if that happens as long as it tastes good? And how is that happening? With milk protein concentrates, given FDA’s already loosened grip on allowable ingredients in cheese standards of identity?

A representative for Great Lakes Cheese spoke up to say that, “Consumer transparency around label claims and that presents a huge consumer perception issue. We are interested in experimenting to reduce sodium in cheeses, but without having to put a flag saying so on our product.”

Without a change in standards, a low salt or low fat cheese would have to be labeled that way. If the fat and salt standards are abolished, no ‘flag’ is needed and consumers won’t know the fat or salt is lowered – it just may taste different.

One question asked was “If our goal is to impact consumer behavior, how do we empower consumers to look for better choices by looking to the nutrition facts instead of making changes to do it for them (with modernized standards and healthy-choice stamps)?”

Part of this process is FDA’s work to “update” the definition of “healthy” as a “voluntary” claim. What kind of symbol should be used, should it be by food group.

“What’s healthy and not healthy shifts over time, and it’s not the same for everyone. If you’re putting a stamp on something today, you may have to take it off at some time down the road,” said one hearing participant.

Dieticians were on the side of “one size doesn’t fit all” when it comes to using FDA-sanctioned ‘healthy’ stamps or symbols on food labels. They preferred to see a focus on foods and food patterns more than specific nutrients.

In fact, one anonymous dietician has already commented on the public document online to say they have spent 30 years with government food programs and this is his or her observation over those 30 years: “We have done a great disservice to the public in trying to get people to eat 6 to 12 servings of carbohydrates per day while subsisting on a lowfat diet.”

A participant from the Edge dairy farmer cooperative of 800 members in the Midwest (formerly Dairy Business Association Cooperative based in Wisconsin) said that, “Accurate labeling is the first step in FDA’s enforcement of existing standards for milk, cheese, yogurt. High nutrition and taste have come to be expected,” he said.

“Inaccurate labeling is not fair to farmers and their investment or to customers who may have been misled. We’re encouraged by FDA’s announcement and we encourage innovation in the dairy case to keep up with changing wants and needs with options for healthy products, but most people under-consume dairy products. We must have the flexibility to make what competes and to label innovative foods made with milk.”

-30-

FDA admits almonds don’t lactate, but here’s the rest of the story…

CowFace.jpg

They’re even taking her ‘moo!’ Investor-heavy high-tech startup companies are (with USDA’s help) taking her DNA to give food-grade yeast her protein-producing ability in a fermentation process to make “animal-free milk and dairy.” They’re editing her cells to grow muscle blobs in bioreactors for “animal-free boneless beef” and using her unborn bovine fetal serum as the culture media for the so-called ‘clean’ ‘animal-free’ cell-cultured meat growth. And they are taking her “moo” with website invitations to “join the ‘Moo’-vement or to get ‘moo-ving’ for all the dairy you love with none of the cows.” Meanwhile, FDA is poised — in a multi-year nutrition innovation strategy — to expand standards of identity for milk/dairy and meat/beef to accomplish nutrition innovation goals that, themselves, are being questioned and in the end may give these companies the license to steal. Photo by Sherry Bunting

FDA nutrition innovation strategy poised to ‘modernize’ how milk, beef defined as high-tech labs make cow-less versions of both

By Sherry Bunting for Farmshine, July 27, 2018

WASHINGTON, D.C. — As President Ronald Reagan famously said: “The nine most terrifying words in the English language are: I’m from the government and I’m here to help.”

Last week’s news that the Food and Drug Administration (FDA) will “help” the situation of imitation milk labels was followed by specifics from FDA Commissioner Scott Gottlieb.

He revealed in a live interview with Politico: “An almond doesn’t lactate, I will confess.”

Now there’s the sound bite everyone wants to hear, and the media and social media worlds went wild. But what does it really mean? Here’s the rest of the story and how to get involved.

Gottlieb said publicly that FDA plans to start gathering public comments before taking next steps in “redefining the rules for milk products”.

What he didn’t say in the Politico Pro Summit on July 17 is that FDA has already published a hearing and comment notice in the June 27, 2018 Federal Register for a July 26 hearing that covers three topics related to “modernizing” standards of identity, and the comment period ending August 27, 2018.

Will the government’s offer to ‘help’, in this case, result in more dishonesty and skulduggery, tricking consumers into eating what they may not otherwise choose and allowing investor-heavy startup companies to steal from farmers and ranchers, not only the identity of the products they produce, but also the very commodity-promoting checkoff dollars the government mandates they pay?

FDA already has a standard of identity for milk, and almost 100 dairy products, that it has chosen to ignore for more than a decade on any product except actual dairy milk.

Here’s the rub… If real dairy milk does not have added Vitamin D (when fat is removed Vit D is added to bring it back to full-fat levels of Vit. D), it can be deemed “mislabeled” by FDA and unable to call itself MILK.

But, if there are almonds and soybeans in your milking parlor — by all means, have at it,  label it milk — with or without Vit. D — not to mention without real milk’s levels of protein, quality amino acid profile and 9 essential nutrients.

You see, the standard of identity for milk is enforced when it comes from a cow, but not when it comes from a plant. And yet, because there is a standard of identity for milk — a nutritional and functional expectation — the plant-based knock-offs get to hijack that profile without being held to it and can selectively market from it with ‘more xxx’ or ‘free of xxx’ statements without stipulating what they are deficient in. (Example: Almond milk labels should say “88% less protein” if they are going to differentiate from the standard of identity they are hijacking).

By its own admission, FDA has maintained a non-enforcement posture on plant-based imitation beverages. Described as “enforcement discretion,” FDA has looked the other way and the dairy foods industry was either asleep at the wheel or developing imitations on the side, while these imposters were flooding the dairy case.

Meanwhile the companies investing in the imitations were free to do their market development and consumer confusion while securing space in the dairy case.

The timing of Gottlieb’s comments last week is even worse, given FDA’s launch of a multi-year nutrition innovation review as part of the agency’s nutrition innovation strategy revealed in March that seeks to expand standards of identity for products like milk and meat.

FDA meetings are happening quickly and quietly in various areas of imitation animal protein labeling and regulation. Yes, they are public meetings, but no one really knows about them.

Milk and dairy products have already been on the receiving end of identity-theft for more than a decade, and now that griddle is heating up to pancake both dairy farmers and ranchers (cattle are the target) with new plant-based mixtures, but even more horrifying are the genetically-edited cellular protein blobs or white-substance-exuding yeast grown in bioreactors yearning to be beef and milk.

There are new identity-thieves lurking about and guess what? USDA — the government — is the source of the bovine gene-edited cells and bovine gene-sequenced yeast in the heavily-investor-funded tech food startup companies that are the real focus of FDA’s recent moves.

With patents in hand — and funding from their big investors to scale up manufacturing — they seeking regulatory and labeling authority under FDA to be meat/beef and milk/dairy — without the cows.

FDA had a hearing on cell-cultured proteins July 12, and comments on regulation and labeling for this are due September 25.

A hearing on standards of identity was held by FDA on July 26 (after Farmshine press time), and comments are due August 27. (Look for more on this in next week’s Farmshine).

Dairy and beef producers need to become actively engaged in these moves by FDA because the main organizations that represent them — National Milk Producers Federation and National Cattlemen’s Beef Association — are on record stating these cell-cultured products should be subject to regulation under USDA like real meat and dairy. They are mainly seeking a level playing field in the marketplace, not opposing their classification as meat, milk, dairy.

(NMPF is vigorously defending milk’s standard of identity against plant-based imitations on nutritional grounds, but seeking a level playing field on the cell-cultured proteins).

Trust me, food and dairy manufacturing companies and investors have already hired the best and the brightest and are already involved in this FDA process — cheering for the other team.

Here’s an example: Perfect Day ‘animal-free milk’ is on the market after receiving its patent in February and raising $24.7 million in first-round startup funding from investors to scale-up manufacturing.

This company has a business-to-business (B2B) model, according to an interview with Reuters, and is already working with some of the world’s largest dairy food and beverage manufacturers. Its website states that the product is just like milk in terms of proteins, but without the cholesterol, saturated fats, lactose, and environmental impact of cattle. Just think what this portends for the dumping of even more fat-free real milk from the market.

In fact, a primary foreign investor indicated support for the Perfect Day (fake milk) startup because it aligns with United Nations Sustainability Goals for 2030. (There’s that S-word again. I hope we are paying attention to how the S-word and cattle are getting along these days). Continental Grain is a big investor in both the Memphis Meats (fake meat) and Perfect Day (fake milk) startups, while Cargill and Tyson are investors in the Memphis Meats startup.

These high-tech food sciences are attracting big high-tech investors at a rapid rate because they are viewed as “disruptor technologies,” and their websites and promotional materials hold nothing back. Milk, meat, beef, dairy – no words are off limits in their branding and marketing.

In effect, while the government forces dairy and beef producers to pay a checkoff tax for promotion of their commodities, beef and dairy — and the names of products associated with those commodities — the government is looking the other way or now potentially encouraging more identity-theft as techies enter the food space to market proteins using the dairy and beef profiles and images, without paying one dime.

As for Perfect Day, this fake-milk is made by genetically altering food-grade yeast, taking DNA from a cow and sharing its protein-producing qualities with the yeast. (Sourced from the USDA, the genetically-altered yeast are cultivated to produce ‘dairy’ protein).

This process results in a microbe that is combined with a sugar substrate (food for the microbe) to feed, grow and exude in a fermentation process the company says is like “craft-beer-style-brewing,” producing protein “building blocks” for making dairy milk, yogurt and cheese. Perfect Day’s website says: “Dairy reinvented: Sustainable. Kind. Delicious.”

The end game is to provide a ‘base dairy’ protein that looks and tastes like milk, for inclusion in manufactured dairy products like cheese, ice cream, pizza, yogurt, and to work “synergistically” with the dairy foods industry as — according to the website — “a complement to cow-based milk that takes some of the stress away from the factory-farming system, rather than replace dairy cows entirely.”

fake-meat.jpg

Enter a caption

Memphis Meats and other companies on the fake meat side are doing similar things with cell-culturing to grow cellular protein blobs in laboratory bioreactors.

In each case, the ultimate goal is to decrease the need for cattle — be they dairy or beef bovines.

Think about this for a moment. Even at a 1 to 3% inclusion rate in common dairy foods or ground beef, these lab-cultured proteins and genetically-altered yeast give processors even more control over supply, demand and pricing of milk as well as boneless beef, and if standards of identity allow this, or if FDA enforcement discretion looks the other way – consumers will never know the integrity of their food has been changed.

If FDA modernizes its standards of identity to accomplish the goals as outlined by Commissioner Gottlieb — including a reduction in saturated fat consumption despite revelations that saturated fats are healthful not harmful — it is entirely possible that FDA’s new guidance could allow these protein “innovations” in standardized dairy and meat products, without being considered mislabeled and with no indication to consumers.

Gottlieb has already established FDA’s desire to accomplish certain nutritional goals by spurring innovation with more “flexible” standards of identity.

Ahead of the July 26 hearing, FDA published its intention to cover three aspects in the standards of identity discussion: 1) Protecting consumers against economic adulteration; 2) Maintaining the basic nature, essential characteristics, and nutritional integrity of food; and 3) Promoting industry innovation and providing flexibility to encourage manufacturers to produce more healthful foods.

FDA’s Federal Register notice also says the following: “Our intent is that modernizing standards of identity to improve the nutrition and healthfulness of standardized foods will promote honest and fair dealing in the interest of consumers and achieve the goals of the Nutrition Innovation Strategy.”

How can FDA pursue this course in the face of what has been revealed in the past three to four years? It appears that bringing these B2B products to market, along with the FDA nutritional innovation strategy, are happening ahead of the battleground brewing for the next round of Dietary Guidelines.

It appears they want to modernize standards of identity for dairy within less than one year, to get them in place before the current flawed dietary guidelines are challenged in the 2020 cycle, which begins in earnest in 2019.

Numerous investigations and scientific reports and studies show that the saturated fat avoidance of more than 30 years was not only never proven to be healthful, it is now shown to be harmful. And the rhetoric from the United Nations and various Sustainability projects continues to focus on cattle as being bad for the planet, despite evidence to the contrary.

FDA wants comments that specifically talk about how the agency can use standards of identity to encourage the production of more healthful foods, to take into consideration technology, nutrition science and marketing trends, and to assess what consumers expect these standards to tell them.

Is FDA about to help the food industry blur the lines of food integrity to trick people into eating according to USDA/HHS flawed set of dietary guidelines (and UN environmental sustainability assumptions)?

That would be the ultimate dishonesty, and much worse than the 10-plus years of ignoring dairy identity theft already happening daily in the supermarket dairy case. Expanding the standard of identity, depending upon how it is accomplished, would give large, powerful, multinational food corporations a true license to steal.

Last week, the American Dairy Coalition (ADC) launched a “Protecting Milk Integrity Initiative” to advocate for the proper use of federally standardized terms established for the word “milk” on product labels. ADC is a coalition of dairy, ag and livestock producers, and they are devoting a branch of their organization to work specifically on “providing clarity and consistency for consumers across the nation,” the organization said in a July 17 news release.

ADC is getting the word out that it believes the dairy industry must speak up to ensure the FDA understands how important it is, not only for the current standard of identity for milk and dairy products to be upheld, but for it to be fully enforced — restricting the use of the word “milk” on all future plant-based or alternative product labels.

They point out that the price of milk continues to decline while sales of plant-based alternatives are up 61% over the past five years with projections of more market share gains in the future.

Don’t be fooled by FDA’s admission that almonds don’t lactate. Instead of the enforcement of milk’s standard of identity that dairy farmers have been waiting for, FDA has already quietly launched its process for modernizing standards of identity to achieve specific (and flawed) nutritional goals.

To comment on Docket No. FDA-2018-N-2381 for “FDA’s Comprehensive, Multi-Year Nutrition Innovation Strategy,” due August 27, 2018, use the docket portal at https://www.regulations.gov/docket?D=FDA-2018-N-2381.

To comment on Docket No. FDA-2018-N-2155 for “Foods Produced Using Animal Cell Culture Technology, due September 25, 2018, use the docket portal at https://www.regulations.gov/docket?D=FDA-2018-N-2155 .

To mail comments for either one, reference the appropriate docket name and number in your letter and mail to: Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852

In addition to commenting, a petition has been developed by the American Dairy Coalition’s Protecting Milk Integrity Initiative, and signatures are being collected to submit with public comments. ADC is also taking donations to raise funds to fight this cause.

More information about Protecting Milk Integrity Initiative, visit American Dairy Coalition

To learn more about the July 12 FDA cellular protein hearing (fake meat) and July 26 standards of identity hearing (fake milk), stay tuned to future editions of Farmshine for full reports ahead of the deadlines for commenting to FDA on both.

-30-

CAPTIONS

FAKE MEAT and FAKE MILK

New Harvest and Memphis Meats testifed to FDA on July 12 that cell-cultured ‘meats’ are inevitable. They showed diagrams of how gene-edited bovine DNA and culture media are combined in bioreactors to make cellular blobs they want to call ‘boneless beef’ — without the cow. Similar diagrams can be found for Perfect Day and their phrase: ‘all the dairy you love with none of the cows’ at their website perfectdayfoods.com. Screenshot of materials displayed during FDA hearing by Sherry Bunting