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Selling it

Naming it, and the words that carry a standard

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Three different regimes sit on one shelf: a defined name, an undefined one, and one that is actively being argued about.

Yogurt commits you to numbers

Not less than 3.25 percent milkfat, not less than 8.25 percent milk solids not fat, and a pH of 4.6 or lower within 24 hours of filling. Lowfat and nonfat versions are provided for separately. A cultured milk product outside those is a legitimate product that may not carry the name.

Kefir and most cultured products are descriptive

No standard of identity, so you name them for what they are and the general rules apply. The test is whether a buyer reading the name would be surprised by the contents, and the freedom comes with no external check on whether you held your own specification.

Plant-based names are unsettled

FDA’s draft guidance recommends qualifying the term with the plant source and adding a voluntary nutrient statement where the composition differs from milk. It is a draft, its comment period has been reopened, and a sensible maker designs a label that can accommodate a change.

Qualifiers carry meaning even when undefined

Live, active, raw, grass-fed, cream top and natural each set an expectation. Some are claims you can support with documentation and some are claims about somebody else’s farm. Treat each one as something you might be asked to prove.

Check the name is available

A name already registered in this category is one you will be asked to stop using, usually once you are visible enough to be worth asking. The search belongs at the shortlist stage, not after a print run.

The name sets the price comparison

Yogurt puts your pot next to the cheapest one in the aisle in a buyer’s mind. A more specific name, naming the style, the milk or the method, moves the comparison to products in your own price range, which matters in a category where the commodity version costs a fraction of yours.

References

21 CFR 131.200, Yogurt: not less than 3.25 percent milkfat and not less than 8.25 percent milk solids not fat, with “a pH of 4.6 or lower measured on the finished product within 24 hours after filling.” law.cornell.edu
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 Labeling of Plant-based Milk Alternatives and Voluntary Nutrient Statements: Draft Guidance for Industry, 2023.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
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.