This article provides insights into regulatory provisions regarding dairy analogues, addressing the use of dairy-relate
A. IDENTITY OF “ANALOGUES IN THE DAIRY CONTEXT”
1. What is an “Analogue in the Dairy Context”?An “analogue” refers to a product that includes non-milk-derived ingredients partially or wholly replacing milk constituents. The end product resembles, either in taste, texture, or function, traditional milk or milk products.
2. Which products qualify as dairy analogues?Any milk or composite milk product where primary milk components (like milk fat or protein) are replaced with non-milk ingredients, such as vegetable oil or protein, falls under dairy analogues. Examples include lookalike products that mimic traditional dairy.
3. What products are not considered dairy analogues?
Composite milk products: These contain both dairy and non-dairy ingredients (like flavored yogurts) and adhere to specific dairy standards.
Modified milk products: These include products altered for fat or lactose content (like lactose-free milk).
Non-dairy products: Exclusively non-dairy items, such as coconut milk or soy beverages, are outside the analogue classification.
Other food categories with dairy ingredients: Items like milk chocolate or butter cookies, where dairy is essential for product identity, are also excluded from analogue status.
4. Can all milk products have analogues?No, certain products—like ghee and butter—cannot legally have non-milk components added, per the Food Safety and Standards (FSS) regulations.
5. Are analogues recognized as dairy products?Analogues are not classified as dairy products according to current regulations.
6. Can analogues be standardized?Yes, standardization may apply to ensure quality and regulatory compliance. Certain analogues, such as frozen desserts and mixed fat spreads, already have defined standards.
7. Can analogues be licensed as proprietary foods?No, analogues are licensed under the “General Manufacturing” business category, aligned with their corresponding dairy counterparts, for regulatory purposes.
B. USE OF DAIRY TERMS IN FOOD PRODUCT NOMENCLATURE
8. What are “dairy terms”?“Dairy terms” include words, symbols, or images that directly or indirectly suggest milk or milk products. Examples include terms like “milk,” “cheese,” or “butter.”
9. What guidelines govern the use of dairy terms in product names?
Allowed: Dairy terms are permitted for products that meet dairy standards.
Not Allowed: Non-dairy products cannot use dairy terms, except for some traditional exceptions (e.g., coconut milk, peanut butter) that are not intended to replace dairy products.
Other Food Categories: Certain foods (e.g., milk chocolate or cheesecake) containing dairy ingredients may use dairy terms.
10. Can analogues use dairy terms?No, since analogues are not recognized as dairy products and do not qualify under non-dairy exceptions, they cannot use dairy terms.
C. LABELING PROVISIONS FOR ANALOGUES
11. What labeling requirements apply to analogues?
Partial replacement of milk components: Label must state the ingredient used as a substitute (e.g., “Contains Soy Protein”).
Full replacement of milk components: Labels should state “Contains no Milk Fat” or “Contains no Milk Protein,” as applicable.
Unstandardized analogues: Must include the term “Analogue” along with a food category identifier (e.g., “Analogue -1.6.5” for cheese analogues).
12. Are there specific labeling requirements for standardized analogues?Yes, analogues with established standards must follow the specific labeling regulations for those products.
D. USE OF MILK LOGO
13. Which products are allowed to use the Milk Logo?Only milk, milk products, and composite milk products listed in FSS regulations qualify for the Milk Logo, including items like milk, yogurt, butter, and ice cream. Its use is mandatory for eligible products.
14. Which products are prohibited from using the Milk Logo?The Milk Logo cannot be used for:
Analogues.
Products with dairy ingredients included only as a characteristic component (e.g., milk chocolate).
Proprietary and non-dairy foods.
15. How is the Milk Logo text displayed?The terms “Milk” and “दूध” can be used independently or together within the logo.
16. Are there specific requirements for Milk Logo dimensions and color?These specifications will be finalized and published on the FSSAI website, with compliance required by December 31, 2022.
This FAQ guide clarifies regulatory distinctions between traditional dairy and analogue products, the careful use of dairy-related terminology, and essential labeling guidelines to aid compliance with food safety standards
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