The main argument of the note is that using terms such as meat and plant-based milk can confuse the consumer. However, research shows that the choices are conscious
By Vinicius Gallon and Victoria Gadelha
The Ministry of Agriculture, Livestock and Supply (MAPA) sent a letter at the beginning of the month asking for information from the Ministry of Health, to which Anvisa is linked, and the Ministry of Justice, where the National Consumer Secretariat (Senacon) is located, regarding the labeling of products made from plants (plant based). The letter was based on a technical note from the Ministry itself, which analyzes the current standard and concludes that vegetable protein products are not in compliance.
As a result, a lot of misinformation began to circulate on the internet, causing confusion and concern in the alternative protein sector. Gustavo Guadagnini, president of The Good Food Institute Brazil, assures that this is an expected move: “The GFI is fully involved in the regulatory process and this official letter does not represent a drastic change in position, nor a new decision. The technical note is not a decree or a change in legislation, it is just part of an official letter, that is, part of a conversation initiated between ministries regarding the need to regulate a new sector.”
The president of GFI Brazil states that there is no evidence that the government would try to apply rules created years ago, before the sector even existed: “if MAPA were to enforce the current legislation, they would have fined and charged companies that produce plant products. Everyone already knew that the sector plant based It is not covered by current legislation because it did not exist at the time it was created. Therefore, we expect specific rules to be created for this new industry. What we need to do now, as a sector, is to intensify communication with regulatory agents and share facts and data so that they can make the right decisions, including during this time of transition.
Global context
Similar discussions have already taken place globally and it is clear that the arguments against the use of animal terms by the plant-based industry have not held up. Most decisions against the sector have been overturned. Here are some examples:
In 2021, the European Union rejected Amendment 171, which would make the rules for marketing plant-based dairy products even more restrictive, and the European Parliament also voted against a motion that sought to ban plant-based products from using terms such as burger, steak and sausage. In France, the decree that was to come into effect in October this year banning “meat” terms on plant-based products ended up being suspended.
In the United States, initiatives try unsuccessfully ban the use of terms like “milk” and “burger.” In Mississippi, the lawsuit was dismissed after the two sides reached an agreement on product labeling, and in Arkansas, a judge granted a preliminary injunction, rendering the law unenforceable. This year, Tofurky won a major victory in Louisiana, when the judge found the law unconstitutional. With legal representation from the Animal Legal Defense Fund and The Good Food Institute USA, the lawsuit filed by Tofurky proved the state, which argued that terms like hamburger and sausage on products plant based confuse the consumer, did not present any evidence proving this and, therefore, could not prove that the law promotes the State's interest in avoiding consumer confusion.
Already in India, the requirements imposed in July by the regulatory agency do not concern “borrowed” terminology and nomenclature: the concern is to ensure that the product sold as “plant-based” is truly vegan.
Let's get to the facts: what does research say about whether consumers know what they are buying?
The rules created to restrict the use of names by the plant-based product sector are based on the claim that consumers buy these products by mistake, since they have similar names and sometimes feature images of animals. However, the evidence points to the opposite and indicates that, in fact, these terms help to accurately convey the flavor, texture and function of the plant-based product. Most research indicates that it would not be clearer to the consumer if, instead of “pea burger”, the product packaging said “pea disc”. Similarly, terms such as “vegetable tube” instead of “vegetable sausage” only make it difficult for the consumer to understand the real application of the product.
To answer this question using real data from Brazilian consumers, GFI Brazil conducted a survey with 2500 respondents distributed throughout the country, in order to obtain statistically representative data. According to this survey, conducted between May and June 2022, only 3% of consumers say they have purchased a plant-based product believing it to be a food of animal origin among the main reasons for the first purchase of plant-based alternatives. In other words, 97% of Brazilian consumers purchased similar plant-based products for the first time by their own choice, consciously.
A research “Are Consumers Really Confused by Plant-Based Food Labels? An Empirical Study” A 2020 study by Cornell University showed that consumers are no more likely to think that plant-based products come from animals if the product name incorporates words traditionally associated with animal products. Furthermore, it also concluded that omitting these words from plant-based product labels causes consumers to be confused about the product's taste and use. research A 2020 Dutch survey found that 96% of the 22.770 people surveyed were fully aware that plant-based sausages did not contain meat.
Already a research A 2021 Australian study found that 91% of Australians have never mistakenly purchased a plant-based product thinking it was made from meat. In fact, there was more confusion from consumers looking to buy a plant-based product and unintentionally buying one with animal ingredients. The study analyzed more than 250 plant-based meat alternatives available in Australian supermarkets and found that 100% of front-of-pack labels used at least one term to clearly indicate that they are meat-free. 85% used two or more terms to indicate that they are completely plant-based, and more than half used three or more terms.
Other study A 2022 Australian survey showed that 96% of respondents have never mistakenly purchased a plant-based alternative, and of the remaining 4%, over 67% admitted that the mistake happened because they were in a hurry and didn’t read it correctly or didn’t pay attention. On the other hand, confusion is much more common: 41% of respondents said they had already purchased a product thinking it was completely plant-based, only to later discover that it contained ingredients of animal origin. This type of error is possibly caused by animal-based products using green labels to claim to be healthier or more sustainable. It was found that 64% of respondents said that terms such as “meat-free” help to differentiate products, and 57% responded that they prefer even more specific terms (such as “plant-based chicken” and “meat-free mince”) to identify the plant-based product.
It is worth mentioning that the percentage of consumers who are misled by other types of information is much higher than the 3% found in Brazil. Experts suspect that a large portion of consumers do not know how to differentiate terms that have already been approved for labeling, such as the difference between milk and dairy compound, or between cream and culinary mix. The national media has even made campaigns to clarify the issue for consumers. It is important to contextualize the margin of error presented here, comparing it with others that are already considered acceptable by law. Research in Brazil and around the world indicates that the plant-based food sector is not, and will not be, a real problem for consumers.
The truth is that consumers are not buying plant-based products by mistake. They are buying them because they are part of the increasing global movement of people who are looking for more ethical, healthy, sustainable products that promote the same sensory experience as their analogues.
Another point that has been raised in recent claims is the healthiness of plant-based products. According to a recent nutritional study conducted by GFI Brazil comparing plant-based products with their animal-based counterparts, it was possible to observe that plant-based foods are more beneficial to health. The analysis was conducted based on data collected from the labels of meatballs, breaded products, hamburgers, sausages and kibes of animal and plant-based origin, taking into account the update of ANVISA's criteria for labeling packaged foods. Among the new guidelines that come into effect in October 2022, it will be mandatory to inform on the front label when the product has high levels of sodium and saturated fat.
By establishing parallels with the concepts of the NOVA Classification, a parameter that groups foods according to the level of processing, it was revealed that the products plant based Processed foods provide a healthy and adequate nutritional experience, especially in terms of fiber content, caloric density, sugars and protein content. Some of the results found were:
- Only 33% of plant-based products were high in saturated fat and sodium, while 50% of animal-based products were high in fat and 58% in sodium;
- 76% of meat products plant based may contain a nutritional claim of fiber source, compared to just 4% of traditional meat products;
- The average occurrence of food additives was higher in traditional meat products, reaching an average value of five additives per product analyzed. On the other hand, plant-based meat products presented an average value of only three additives for each product analyzed.
Along the same lines, research indicates benefits of adopting a plant-based diet, highlighting advantages related to reducing obesity and controlling blood pressure and cholesterol. Franca et al. (2022) evaluated the nutritional composition and processing nature of plant-based products. By establishing parallels with the concepts of the NOVA Classification, the authors revealed that processed plant-based products (mainly 2nd generation: meat substitutes obtained from high-moisture extrusion) provide a healthy and adequate nutritional experience, mainly regarding fiber content, caloric density, sugars and protein content. Additionally, Messina et al. (2022) reported that the composition of the plant-based product and its impact on health and sustainability are the most important aspects to be considered when evaluating nutritional attributes, rather than the processing involved in its preparation.
Trying to prevent plant-based products from using terms that are already widely known does not benefit consumers or the market. In Brazil, the plant-based meat and seafood sector generated R$573 million in retail sales last year and has already placed Brazilian products in more than 30 countries around the world. Not only are new companies emerging to serve this market, but giants in the animal protein sector are investing heavily in plant-based products. Primary producers (of grains, legumes and vegetables) will also benefit from this rapidly expanding sector; supermarkets will be able to offer an increasingly wide variety of foods and cater to all audiences. Not to mention the countless opportunities to create jobs in various areas.
Brazil, which is a leader in exporting animal products, can take advantage of the full potential of its industry and agribusiness to also lead in the alternative protein sector. For the president of GFI Brazil, this seems to be just a matter of time: “our dialogue with the government today is very good and the debate between different ministries is part of the regulatory process, as is the public procurement of subsidies and the idea of a National Plan for Alternative Proteins, things that have already happened. We are confident that the Brazilian regulatory process will be in favor of innovation and will launch Brazilian agriculture as a leader in the global alternative protein sector.”