Plant-based

What a plant-based alternative actually is

Updated October 2026

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How it is made The dairy regulations do not reach it Which does not make it easier Separation is the defining problem Nutrition is a formulation decision, not an inherent property Taste the base before you decide the sugar References

An oat or nut beverage is a suspension you built, not a liquid that came out of an animal, and almost every difference follows from that.

How it is made

Plant material is hydrated, broken down, extracted into water and then separated from the solids. What remains is a suspension of fine particles and dissolved material that wants to settle, which is why commercial products contain stabilizers and why homemade ones separate in a day.

The dairy regulations do not reach it

The mandatory pasteurization rule covers milk and milk products. A plant beverage is neither, so it is governed by the general food rules rather than the dairy ones. In practice these products are still heat treated, because a wet, low-acid, nutrient-rich liquid is exactly what spoilage organisms want.

Which does not make it easier

It keeps the cold chain, the short shelf life and the equipment, and it swaps a settled rule for an unsettled naming question. Makers who come to it expecting the simple version of a dairy business are usually surprised by how much of the difficulty was never about the regulations.

Separation is the defining problem

Without a stabilizer these products separate quickly, and a shake-before-use instruction only goes so far with a buyer who poured a glass of water with sediment in it. Deciding whether to stabilize is the central formulation decision and it has a label consequence, because stabilizers appear in the ingredient list.

Nutrition is a formulation decision, not an inherent property

Calcium, vitamin D and protein in these products are usually added rather than present, which is the entire subject of the naming guidance on the next page. A buyer substituting it for milk is making a nutritional assumption the product may not support.

Taste the base before you decide the sugar

Different plant materials give very different base flavors, and much of the sugar in commercial products is covering one. Starting from a base you actually like reduces how much you need to add, which is both a cost and a label advantage.

References

United States Food and Drug Administration. Labeling of Plant-based Milk Alternatives and Voluntary Nutrient Statements: Draft Guidance for Industry, 2023. A draft whose comment period has been reopened, so it represents FDA’s current thinking rather than a settled requirement. fda.gov

21 CFR 1240.61, Mandatory pasteurization for all milk and milk products in final package form intended for direct human consumption, which prohibits delivering such a product into interstate commerce unless it has been pasteurized or is made from pasteurized dairy ingredients. law.cornell.edu

Written from federal regulation and FDA guidance, not from a laboratory. Pasteurization of milk and milk products in final package form for interstate commerce is a federal requirement, and what your state permits inside its own borders is a separate question. Anything here is a starting point for a conversation with your state department of agriculture, not a determination that you comply.