COMMITTEE ON ANIMAL LAW CHRISTOPHER WLACH CHAIR November 26, 2018 PHONE: (917) 747-7297
[email protected] SEJAL SANGHVI SECRETARY PHONE: (917) 968-6251
[email protected] Submitted Electronically Scott Gottlieb, Commissioner c/o Dockets Management Staff (HFA–305) Food and Drug Administration 5630 Fishers Lane, Rm. 1061 Rockville, MD 20852 Re: Docket No. FDA–2018–N–3522, Use of the Names of Dairy Foods in the Labeling of Plant-Based Products Dear Commissioner Gottlieb: The Animal Law Committee (“Committee”) of the New York City Bar Association writes in response to the FDA’s request for comments on the topic of the “Use of the Names of Dairy Foods in the Labeling of Plant-Based Products.” As background, the New York City Bar Association is an independent non-governmental organization of more than 24,000 lawyers, law professors, and government officials, principally from New York City but also from throughout the United States and 50 other countries. Its Animal Law Committee is the first committee of its kind in the United States. In 2018, we presented a public program that explored issues relating to plant-based milks with an attorney who represents a plant-based food organization, an attorney who represents dairy farmers, and the past chair of the Committee.1 We also submitted a comment to Congress opposing the DAIRY PRIDE Act2 and a letter to the FDA in response to a request from 32 members of 1 Say It Ain’t Soy! The Labeling of Plant-Based Alternative Foods (Mar. 22, 2018), https://www2.nycbar.org/mp3/Podcasts/media/say_it_aint_soy_-_the_labeling_of_plant-based_alternative_foods- _3.22.2018.mp3.