The publication of the regulatory framework proposal marks a new stage in the process of discussing the regulation of plant-based products, which has been taking place in Brazil and around the world in recent years.
On July 3, 2023, the Ministry of Agriculture, Livestock and Supply (MAPA) opened a Public Consultation to establish the minimum requirements for identity, quality, labeling rules and the obligation to register with MAPA for plant-based analogue products.
A Public Consultation is a transparency mechanism that can be used by the Public Administration to obtain information, opinions and criticisms from society regarding a given topic. The objective of this tool is to encourage the participation of the population in issues of collective interest, broaden the discussion on the subject and support the decisions of public policy makers. In the case of this ordinance (SDA/Mapa nº 831/2023), contributions can be sent until September 15th.
The objects of the Public Consultation are plant-based analogue food products (including beverages) formulated exclusively with ingredients of plant, fungal or algal origin and which seek to achieve similarity in appearance, texture, flavor and other attributes to traditional products of animal origin, such as meat and meat products, fish, eggs, milk and dairy products.
Although there are already regulations for industrialized and processed foods, which are also applied to products of plant origin, to date there is no specific standard in Brazil for plant-based products, especially with regard to identification and nomenclature standards.
The topic has been under discussion at MAPA since 2019, with active participation from GFI Brasil. In 2022, Anvisa held virtual workshops to prepare a Regulatory Impact Analysis (RIA) on plant-based foods. At the time, it was concluded that the biggest regulatory obstacle was the asymmetry of information in the market for this type of food. According to Anvisa, this problem has national and international scope and can be characterized as a market failure that is related to guaranteeing the consumer's fundamental right to adequate and clear information about different products and services, specifying their characteristics, composition, and risks.
Thus, with Ordinance SDA/Mapa No. 831/2023, MAPA takes on the discussion and establishes the proposal for a regulatory framework to address the lack of minimum regulations for plant-based analogue products.
For Alexandre Cabral, Director of Public Policies at GFI Brazil, the regulatory framework proposed by MAPA calls for discussions on important details such as terminology and labeling of plant-based products in the country. “Not having rules means walking in uncertainty, and the consultation will contribute to the development of the sector.”
The regulatory proposal includes the following central provisions:
- Plant-based analogue products must contain on their labels the name “Plant-based analogue of” followed by the sales name of the product of animal origin (for example “Plant-based analogue of hamburger”);
- It is permitted to use the sales names of the product of animal origin, followed by the word “vegetable”, as long as they are written in smaller characters than the sales name of the product;
- Plant-based analogue products must state that the product does not replace its analogue of animal origin in nutritional or functional terms;
- They must not use terms or images that could depreciate the product of animal origin or the animal production system;
- They must not contain words, signs, names, symbols, emblems, illustrations or other graphic representations that could make the information misleading or that could lead the consumer into error;
- They must not make nutritional claims that are not provided for in specific legislation.
Regarding product registration, they must be registered with the Department of Inspection of Products of Plant Origin (Dipov) and include the seal established by MAPA on their labeling.
The products plant based They must also meet certain quality requirements: they must use ingredients authorized by specific legislation; free from substances that are harmful to health; they must meet the microbiological standards set out in specific legislation; produced in accordance with good manufacturing practices and without odors that are foreign to the product.
This proposal, as laid out today, allows products plant based present on their labels terms such as “meat”, “cheese” and “milk”, as long as they are accompanied by the expression “vegetable analogue of”, a subject that was controversial last year, when former minister Marcos Montes took an emphatic position against the use of these classic terms in analogue vegetable products.
Institutions and individuals interested in submitting technically-based suggestions to the Public Consultation can collaborate through Normative Acts Monitoring System (Sisman), until September 15, 2023. To access the platform, the user must register in advance in the Access Request System To access Sisman, the user must register in advance in Access Request System – Mapa Request.
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