Relevant section in the draft notification on which comments are being provided

Regulation no. 2 (ii) (ea)

Comments/suggestion

I urge you to keep the current nomenclature of milk which applies to both dairy and plant based milk and their products unchanged and withdraw the said Regulation no. 2 (ii) (ea) from the draft notification.

Rationale

Botany defines milk as a kind of juice or sap, usually white in colour, found in certain plants. Linguistically speaking, the Oxford American Dictionary defines milk as “the white juice of certain plants” too.
Non-dairy milk (such as coconut, cottonseed, almond, soy, and flax milk) has been part of the ancient Indian culture. Each type of non-dairy milk offers a unique nutritional profile, with a wide range of values for protein, carbohydrates and fat, along with vitamins and minerals. It is affordable, convenient, desirable, nutritional, and sustainable. Apart from its health and the diet of those who are lactose intolerant.
Any change in the nomenclature of the term "MILK" to exclude plant-based milk and its products will adversely impact the livelihood of thousands of people whose livelihood is dependent on the growing plant-based industry. A growing section of the Indian population has started seeking out plant-based milk and plant-based milk-products to easily obtain nutrients such as protein and calcium while avoiding saturated fat and cholesterol. Studies have shown that most people’s bodies absorb 75 per cent more calcium from soy milk than from cow’s milk.
Consumers are interested in decreasing their consumption of animal products, such as bovine milk, because of health, environmental, and ethical reasons, and it aligns well with FSSAI’s flagship Eat Right India campaign that focuses on promoting plant-based foods.

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