CFA recommends the following revisions to the proposed guidance:
- Modify the guidance document to ensure the common name and brand name of plantbased alternatives to egg products prohibit the use of the term “egg.”2
- Adopt an accurate and transparent approach to common names by implementing a structure that requires plant-based alternatives to egg products to use descriptive naming.
- Implement firm rules to prevent the use of terms typically reserved for and associated with eggs such as omelette, frittata, quiche, scramble and meringue on the label, packaging and
advertising of plant-based alternatives to egg products. - Ensure any plant-based alternatives to egg products that includes “protein” in their common name and/or brand name, achieves a protein quality rating using PER (Protein Efficiency Ratio) of at least 20 to remain compliant with Food and Drug Regulation (FDR) B.01.305.