The American Cheese Society (ACS) supports the definitions of milk, milk products, and cheese, which
clearly express the unique qualities of dairy and dairy products1. These terms reflect longstanding
traditions in dairy farming and cheesemaking, as well as current regulatory and labeling requirements. It
is ACS’s position that these products, and the terms used to define them, must be protected and that they
should always be used accurately in the interest of transparency for consumers.
ACS believes that the U.S. Food and Drug Administration (FDA) should enforce its labeling rules and end
the application of the term “milk” or “cheese” to nutritionally and compositionally different non-dairy
products2.

ACS commends the FDA for addressing this issue and feels the FDA can aid consumers by supporting
this change – one consistent with already existing policy and international practices. Using “milk” as a
descriptor for non-milk products blurs the lines between consumer perceptions of these products’
nutritional content, as well as their usefulness as a cooking ingredient, appropriateness as a source of
protein, and other considerations in which an average consumer may be misled – one of the key findings
of the consumer study conducted by ISPOS on behalf of DMI this October3.

Further evidence of this can be found in the data from research conducted on behalf of The Wisconsin
Cheese Makers Association and Edge Cooperative and Dairy Farmers of Wisconsin. This commissioned
research, conducted by the consumer research firm Ravel, indicates a lack of clarity among consumers
about how traditional cheese names apply to plant-based foods4.

There are nearly 1,000 artisan, farmstead and specialty cheesemakers operating in the United States,
according to the newly published ACS State of the U.S. Artisan/Specialty Cheese Industry Survey Key
Findings Report5. According to the USDA Economic Research Service, per capita cheese consumption in
the U.S. has steadily risen since 1970. In 2015, consumption was estimated to be 35 pounds per person.
According to Euromonitor International, U.S. sales of processed cheese were projected to drop 1.6% for

1 “Cheese Definitions and Categories,” American Cheese Society, accessed January 25, 2019 https://www.cheesesociety.org/events-education/cheese-definitions/.
2 Schuster, Margaret J., Xinyue Wang, Tiffany Hawkins, and James E. Painter. “Comparison of the Nutrient Content of Cow’s Milk and Nondairy Milk Alternatives: What’s the
Difference?” Nutrition Today, 53 no. 4 (July 2018): 153-159. https://doi.org/10.1097/NT.0000000000000284.
3 Dairy Management, Inc., “Consumer Perceptions Dairy and Plant-Based Milk Alternatives,” October 24, 2018, https://www.usdairy.com/~/media/usd/public/dairy-and-plantbased-beverages-research.pdf.
4 Ravel, “Study on Dairy Cheese and Plant-based Foods That Mimic Cheese,” January 2019. https://cdn.ymaws.com/www.voiceofmilk.com/resource/resmgr/docs/alerts/plantbased_cheese_report_su.pdf.
5 American Cheese Society, “U.S. State of the Artisan/Specialty Cheese Industry: Report of Key Finding,” January 2019, https://www.cheesesociety.org/events-education/state-ofthe-industry/ .
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2018 as millennials seek cheeses with fewer preservatives. The number of U.S. cheese factories
increased by 40% between 2000 and 2017, and production increased with the greater number of
facilities6.

Although artisan, farmstead, and specialty cheesemakers contribute a relatively small percentage of total
cheese production in the U.S., analysts believe the growth in U.S. cheese production and consumption is
largely due to artisan and specialty cheesemakers. In order to continue the expansion of this sector and
support the producers and consumers seeking these products, it is essential that there is clarity about
what differentiates these value-added dairy products from non-dairy products in the marketplace.

Submitted by,

Cathy Gaffney, Wegmans Food Markets, American Cheese Society

Nora Weiser, President Executive Director, American Cheese Society