Dairy & Plant-Based Dairy

Alternatives (PBDA) in the U.S.:

Market & Industry Practices

Final Report Prepared for:

U.S. Food and Drug Administration (FDA)
Center for Food Safety and Applied Nutrition (CSFAN)
Office of Nutrition and Food Labeling (ONFL)

August 2020

August 2020 Page 1

 Table of Contents
Executive Summary..................................................................................................................................................5
Study Objectives & Scope .......................................................................................................................................6
Research Methodology ............................................................................................................................................7
Source Overview ................................................................................................................................................................................ 7
Retail Sales Datasets ....................................................................................................................................................................... 7
Dairy and PBDA Product Category Comparison: Milk, Yogurt and Cheese ......................................................8
Retail Sales ..............................................................................................................................................................................................8
Dairy Milk and PBDA “Milk” ................................................................................................................................. 11
Market Comparisons ............................................................................................................................................................................ 11
Retail Sales and Household Penetration .................................................................................................................................. 11
Consumer Purchase Behaviors, Perceptions and Opinions .............................................................................................. 13
Nutritional Composition: Dairy Milk and PBDA “Milk” .......................................................................................................... 19
Dairy Milk Market ................................................................................................................................................................................. 21
Sales .................................................................................................................................................................................................... 21
Production ......................................................................................................................................................................................... 23
Leading Refrigerated Milk Brands ............................................................................................................................................ 25
Leading Shelf Stable RTD Milk Brands .....................................................................................................................................29
Current Industry Practices: Fortification ................................................................................................................................ 30
Consumer Demographics, Behavior & Perceptions ............................................................................................................ 30
Selected Recent Product Innovations ...................................................................................................................................... 33
PBDA “Milk” Market ............................................................................................................................................................................ 34
Retail Sales & Household Penetration .................................................................................................................................... 34
Production ......................................................................................................................................................................................... 36
Leading Refrigerated Brands ..................................................................................................................................................... 38
Additional Leading Shelf Stable Brands .................................................................................................................................. 41
Names/Descriptions on Leading Brands’ Product Labels ................................................................................................ 42
Consumer Demographics, Behavior & Perceptions ............................................................................................................ 44
Selected Recent Product Innovations ...................................................................................................................................... 46
Dairy Yogurt and PBDA “Yogurt” ........................................................................................................................ 47
Market Comparisons .......................................................................................................................................................................... 47
Retail Sales & Household Penetration .................................................................................................................................... 47
Consumer Behaviors and Attitudes .......................................................................................................................................... 48
Nutritional Composition................................................................................................................................................................ 50
Dairy Yogurt Market ............................................................................................................................................................................ 51

August 2020 Page 2

 Retail Sales........................................................................................................................................................................................ 51
Production ......................................................................................................................................................................................... 53
Leading Spoonable Brands ......................................................................................................................................................... 54
Leading Drinkable Brands ........................................................................................................................................................... 56
Consumer Demographics, Behavior & Perceptions ............................................................................................................ 57
Timeline of Selected Product Innovations .............................................................................................................................. 58
PBDA “Yogurt” Market........................................................................................................................................................................ 59
Retail Sales & Household Penetration .................................................................................................................................... 59
Production .......................................................................................................................................................................................... 61
Leading Brands ................................................................................................................................................................................62
Names/Descriptions on Leading Brands’ Product Labels ................................................................................................ 64
Consumer Demographics, Behavior & Perceptions .............................................................................................................66
Timeline of Selected Milestones/Product Innovations ....................................................................................................... 68
Dairy Cheese and PBDA “Cheese” ...................................................................................................................... 69
Market Comparisons ...........................................................................................................................................................................69
Sales ....................................................................................................................................................................................................69
Consumer Purchase Behaviors, Perceptions and Opinions ............................................................................................. 70
Nutritional Composition................................................................................................................................................................ 74
Dairy Cheese Market.......................................................................................................................................................................... 75
Sales & Projections........................................................................................................................................................................ 75
Production ..........................................................................................................................................................................................77
Leading Brands ................................................................................................................................................................................ 81
Cheese Standards of Identity: Quantity of Currently-Marketed Products ................................................................... 85
Consumer Demographics, Behavior & Perceptions ............................................................................................................ 86
Timeline of Selected Industry Milestones & Innovation ..................................................................................................... 88
PBDA “Cheese” Market ...................................................................................................................................................................... 89
Retail Sales & Household Penetration .................................................................................................................................... 89
Production .......................................................................................................................................................................................... 91
Leading Brands ................................................................................................................................................................................92
Names/Descriptions on Leading Brands’ Product Labels ................................................................................................ 94
Consumer Demographics, Behavior & Perceptions .............................................................................................................96
Timeline of Selected Milestones/Product Innovations ........................................................................................................97
Dairy Food Standards of Identity (SOI) ............................................................................................................... 98
Summary of Comments from Selected Dairy Industry Stakeholders ............................................................................... 98
References ........................................................................................................................................................... 106
Appendix A: Front Product Images of Leading PBDA “Milk” Brands ........................................................... 110

August 2020 Page 3

Appendix B: Detailed Nutritional Profiles of Selected Dairy Milk and PBDA “Milk” Products.................... 111
Appendix C: Front Product Images of Leading PBDA “Yogurt” Brands ....................................................... 114
Appendix D: Detailed Nutritional Profiles of Selected Dairy Yogurt and PBDA “Yogurt” Products .......... 115
Appendix E: Front Product Images of Leading PBDA “Cheese” Brands ...................................................... 118
Appendix F: Detailed Nutritional Profiles of Dairy Cheese and PBDA “Cheese” ......................................... 119
Appendix G: Commercial Processing of Dairy Protein Ingredients vs. Plant-Based Protein Ingredients. 121

August 2020 Page 4

 Executive Summary
According to retail sales data provider SPINS, plant-based food sales (across multiple retail channels –
conventional multi outlet, natural and specialty gourmet) reached $5 billion in 2019 (↑11% from 2018) and grew
five times faster than total food sales, which were $526 billion (↑2% from 2018).
• In presenting SPINS’ data, the Good Food Institute (GFI) noted plant-based products “that closely match
conventional products’ taste, appearance, and packaging are driving plant-based food growth.”
• The leading plant-based food product category is plant-based “milk” – with $2 billion in 2019 retail sales
and a 40% share of all plant-based foods – followed by “other plant-based dairy” – which includes yogurt,
cheese, ice cream, butter, creamers, ready-to-drink beverages and spreads/dips/sour cream/sauces –
with $1.4 billion in 2019 sales.
• This study focused on three key plant-based dairy alternative (PBDA) product categories and their dairy
counterparts:
o Milk o Yogurt o Cheese
Sources: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited by The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

• During the past two years, the PBDA “milk,” “yogurt” and “cheese” categories grew much more significantly
than their dairy counterparts – particularly yogurt, which nearly doubled its retail sales, and cheese, which
increased its sales by over 50%.

Selected Dairy and

PBDA Product Categories
Two-Year Sales Growth 2017-2019
150%
↑95%
100%
↑51%
50% ↑14%
↑2%
0%
↓4% ↓6%
Milk Yogurt Cheese
-50%

Dairy % Change Plant-Based % Change

• In addition to retail sales data, other key indicators that PBDA dairy will continue its upward trend include:
dairy manufacturers are developing and adding plant-based products to their own portfolios, and consumers
are increasingly seeking dairy alternatives for both dietary reasons and personal preference.

August 2020 Page 5

 Study Objectives & Scope
Allis Information Management (AIM), in consultation with the U.S. Food and Drug Administration (FDA) Center for
Food Safety and Applied Nutrition (CFSAN) Office of Nutrition and Food Labeling (ONFL), developed a study to
analyze and gain a better understanding of the dairy and plant-based dairy alternative (PBDA) industries –
specifically targeting the milk, yogurt and cheese product categories.

The purpose of this study was to inform future CFSAN policy regarding the modernization of standards of identity
(SOI) in the dairy industry, in support of FDA’s Nutrition Innovation Strategy.

ONFL expressed interest in a variety of industry topics/characteristics, including:

• Industry sizes and product segments

• Company/brand market shares
• Production facilities/methods
• Types of plant-based products being marketed as alternatives to dairy foods
• Percentage of plant-based subclasses being marketed as substitutes for their dairy counterparts
• Percentages of plant-based subclasses being marketed with product names that include the name of a
dairy food (e.g., “milk”) versus names that include another term (e.g., “beverage” or “drink”)
• Nutritional profiles of dairy and PBDA products
• Demographics of consumers who purchase dairy and PBDA products
• Industry opinions on dairy SOI, including perceived limitations or restrictions on ingredient use and/or
reformulating products to achieve healthier nutritional profiles
• Quantity of marketed products under each of the dairy SOI

August 2020 Page 6

 Research Methodology
Source Overview
To complete the study, AIM searched, compiled and analyzed information from a variety of publicly available
sources, including retail sales data, market research reports, product and government databases/publications,
company/brand/trade association websites and publications, citizen petitions and public submissions/comments
and consumer surveys. Additionally, AIM incorporated direct feedback from government and trade association
contacts. Note: AIM had planned to attend two in-person trade events – the American Dairy Products Institute
(ADPI) Annual Meeting and Plant-Based World Conference & Expo – to gather a significant amount of primary
intelligence. Unfortunately, due to the COVID-19 pandemic, the ADPI conference was held virtually, which
eliminated natural opportunities for face-to-face contact, and Plant-Based World has been postponed indefinitely.

Retail Sales Datasets

• To quantify the U.S. plant-based food market, the Good Food Institute (GFI) and the Plant Based Foods
Association (PBFA) commission retail sales data from market research firm SPINS.
o SPINSscan sales data covers three retail channels: Natural and Specialty Gourmet – both
measured by SPINS’ proprietary tracking – as well as Conventional Multi Outlet (MULO) –
provided by market research partner Information Resources, Inc. (IRI).
 According to GFI, SPINSscan data “is generally considered the broadest available view
of retail food sales, although not all retailers are represented. Some, such as Whole
Foods, Trader Joe’s and Costco, do not report their scanner data to SPINS or IRI.”

“Powered by IRI”

Source: The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

• Nielsen’s Expanded All Outlet Channel (xAOC) sales do not appear to cover as many natural/specialty
gourmet stores as SPINS, but it does include projections for Whole Foods, Trader Joe’s and Aldi.

Source: Nielsen Retail Measurement Overview, 2017

August 2020 Page 7

 Dairy and PBDA Product Category Comparison: Milk, Yogurt and Cheese
Retail Sales
• According to SPINS data, combined retail sales of PBDA “milk,” “yogurt” and “cheese” reached $2.5
billion in 2019 (↑8% from 2018 and ↑22% from 2017), with “milk” accounting for the majority of sales.
o Nielsen’s reported retail sales of aggregate PBDA “milk,” “yogurt” and “cheese” was slightly lower
at $2.43 billion.
• Combined retail sales of dairy milk, yogurt and cheese continued to be significantly higher than PBDAs in
2019 – earning $40 billion – but their growth rates were still flat (milk ↑0.1%; yogurt ↓1.2%; cheese ↑1.4%).
o Again, Nielsen reported slightly lower retail sales of aggregate dairy milk, yogurt and cheese -
$39.8 billion.
• Plant-based alternatives to milk, yogurt and cheese still generate a relatively small percentage of total
retail sales in their respective categories; however, PBDA sales growth has outpaced that of its dairy
counterparts in recent years – most significantly in “yogurt.”
o PBDA “milk” is the most developed category, accounting for 14% of total milk sales ($12.7 billion).
o PBDA “cheese” is the least developed category, with only 1% of total cheese sales ($19.9 billion).
o Sales of PBDA “yogurt” ↑95% 2017-2019, while dairy yogurt sales ↓6% during the same period.

PBDA "Milk," Yogurt" and "Cheese"

Combined Retail Sales 2019: $2.5 Billion
8%
11% ($189 million)
($283 million)
81%
($2 billion)

Plant-based "milk" Plant-based "yogurt" Plant-based "cheese"

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 and 104
weeks ending 12-29-2019. Cited in The Good Food Institute, 2019 State of the Industry: Plant-Based Meat, Eggs and Dairy, 5/2020

PBDA "Milk," "Yogurt" and "Cheese" :

% Share of Total Category 2019 Retail Sales
14% of total milk
16% ($12.7 bilIion)
14%
12%
10%
8% 4% of total yogurt
6% ($7.5 billion) 1% of total cheese
4% ($19.9 billion)
2%
0%
Milk Yogurt Cheese

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 and 104
weeks ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

August 2020 Page 8

 Selected Dairy and Selected Dairy and
PBDA Product Categories PBDA Product Categories
One-Year Sales Growth 2018-2019 Two-Year Sales Growth 2017-2019
40.0% ↑31% 150%
↑95%
30.0%
↑18% 100%
20.0% ↑51%
↑5% 50% ↑14%
10.0% ↑2%
↑0.1% ↑1%
0.0% 0%
↓1% ↓4% ↓6%
Milk Yogurt Cheese Milk Yogurt Cheese
-10.0% -50%

Dairy % Change Plant-Based % Change Dairy % Change Plant-Based % Change

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 and 104
weeks ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

• In terms of retail channels, PBDA “milk,” “yogurt” and “cheese” each has its largest share of total retail
sales in the Natural channel, followed by Specialty Gourmet and Conventional Multi-Outlet (MULO).

PBDA "Milk," "Yogurt" and "Cheese":

2019 Dollar Share of Total Category in Three Retail Channels
45% 41%
40%
35%
30% 26%
25% 22%
20% 17%
15%
13%
10% 6%
5%
3% 2%
1%
0%
Milk Yogurt Cheese

MULO* Specialty Gourmet** Natural***

*Conventional Multi Outlet (MULO) channel covers >104,000 grocery, drug, mass, dollar, military, and club retail locations (e.g. Publix,
Walmart, Kroger, Target)
**Specialty Gourmet channel covers “full-format supermarkets” with at least $2 million in annual sales and “SPINS-defined specialty items”
comprising at least 25% of overall volume. Retailers are also defined as “high-end” and “experiential.” (e.g. Gelson’s, Heinen’s, Busch’s)
***Natural channel covers “full-format” stores with at least $2 million in annual sales and at least 50% of sales from
natural/organic products (e.g. Sprouts, Erewhon, Earth Fare; exclude Whole Foods and Trader Joe’s)
Source: SPINSscan Natural and Specialty Gourmet (proprietary) plus SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

August 2020 Page 9

 • Household penetration of PBDA “milk” reached 41% in 2019 (refrigerated 39%; shelf stable 10%), while
PBDA “cheese” continues to lag with 3% household penetration.
PBDA "Milk," "Yogurt" and "Cheese":
% Household Penetration 2019 (One-Year Change)
45.0%
38.9% (↑1.9%)
40.0%
35.0%
30.0%
25.0%
20.0%
15.0% 10.3% (↓0.8%) 8.7% (↑2.5%)
10.0%
5.0%
2.9% (↑0.2%)
0.0%
Refrigerated Milk Shelf-Stable Milk Yogurt Cheese

Source: IRI Panel, All Outlets, 52 weeks ending 11/3/2019, NBD Aligned. Cited in IRI, “Understanding the Plant-Based Consumer: A Deeper
Look Into Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

PBDA "Milk," "Yogurt" and "Cheese":

% Households With One vs. Multiple Purchases 2019
100%
48.4% 50.3% 45.10%
75.6%
50%
51.6% 49.7% 54.90%
24.4%
0%
Refrigerated Milk Shelf-Stable Milk Yogurt Cheese

% HH Buying Once % HH Buying Twice+

Source: IRI Panel, All Outlets, 52 weeks ending 11/3/2019, NBD Aligned. Cited in IRI, “Understanding the Plant-Based Consumer: A Deeper
Look Into Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

• In terms of consumer spending, refrigerated PBDA “milk” recorded the highest retail dollar sales per
buyer, followed by cheese, yogurt and shelf stable PBDA “milk.”
PBDA "Milk," "Yogurt" and "Cheese":
$ Sales per Buyer 2019 (One-Year Change)
$40.0 $36.5 (↑$0.5)
$28.4 (↑$2.5)
$30.0
$19.5 (↓$0.5) $17.3 (↑$0.1)
$20.0
$10.0
$0.0
Refrigerated Cheese Yogurt Shelf-Stable Milk
Milk

Source: IRI Panel, All Outlets, 52 weeks ending 11/3/2019, NBD Aligned. Cited in IRI, “Understanding the Plant-Based Consumer: A Deeper
Look Into Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

August 2020 Page 10

 Dairy Milk and PBDA “Milk”
Market Comparisons
Retail Sales and Household Penetration
• According to SPINS, PBDA “milk” accounted for 14% of total retail milk sales ($14.7 billion) in 2019, while
dairy milk comprised the remaining 86%.
o IRI estimates non-dairy milk will continue to gain market share in the next five years – growing
from 14% of total sales in 2019 to 21% by 2024.
• IRI reported that total refrigerated milk sales ↓ annually 2015-2019, but PBDA refrigerated “milk” sales ↑
each year during the same period.
o Similarly, dollar sales per buyer and household penetration of total refrigerated milk ↓ every year
2015-2019, while dollar sales per buyer and household penetration of PBDA refrigerated “milk” ↑
annually during the same period.
Total Refrigerated Milk and PBDA Refrigerated "Milk":
$ Retail Sales 2015-2019
REFRIGERATED "MILK"

TOTAL REFRIGERATED MILK

PLANT-BASED

Plant-Based "Milk" Sales Total Refrigerated Milk Sales

($ BILLIONS)

1.8 17.5
17

($ BILLIONS)
1.6 16.5
16
1.4
15.5
1.2 15
14.5
1 14
2015 2016 2017 2018 2019 (52 weeks
ending 10/6)

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels plus Convenience Stores. Cited in IRI, “The Surge
of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/19/2019

Total Refrigerated Milk: PBDA Refrigerated "Milk":

$ Retail Sales per Buyer 2015-2019 $ Retail Sales per Buyer 2015-2019
140 37
135 36
130 35
125 34
120 33
115 32
2015 2016 2017 2018 2019 (52 2015 2016 2017 2018 2019 (52
weeks weeks
ending ending
11/3) 11/3)

Total Refrigerated Milk: Plant-Based Refrigerated "Milk":

% Households Buying 2015-2019 % Households Buying 2015-2019
98.0% 40.0%
97.5% 38.0%
97.0% 36.0%
34.0%
96.5% 32.0%
96.0% 30.0%
2015 2016 2017 2018 2019 (52 2015 2016 2017 2018 2019 (52
weeks weeks
ending ending
11/3) 11/3)

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 11/3/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club,
excluding Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty gourmet channels. Cited in IRI,
“Understanding the Plant-Based Consumer: A Deeper Look Into Plant-Based Purchase Trends, Demographics, Perceptions and Usage,”
1/16/2020

August 2020 Page 11

 Dairy and Non-Dairy Milk: Share of Total Market Sales 2014-2024

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

• According to SPINS, PBDA “milk” has the highest share of total retail milk sales in the Natural channel:

Plant-Based "Milk" Share of Total Milk Sales

in Retail Channels 2019

MULO* 13%
Specialty Gourmet** 20%
Natural*** 41%

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

*Conventional Multi Outlet (MULO) channel covers >104,000 grocery, drug, mass, dollar, military, and club retail locations
**Specialty Gourmet channel covers “full-format supermarkets” with at least $2 million in annual sales and “SPINS-defined specialty items”
comprising at least 25% of overall volume. Retailers are also defined as “high-end” and “experiential.” (e.g. Gelson’s, Heinen’s, Busch’s)
***Natural channel covers “full-format” stores with at least $2 million in annual sales and at least 50% of sales from
natural/organic products (e.g. Sprouts, Erewhon, Earth Fare; exclude Whole Foods and Trader Joe’s)
Source: SPINSscan Natural and Specialty Gourmet (proprietary) plus SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

“Non-dairy milks are rapidly taking share from the dairy market. In 2014, non-dairy milks made up only 8% of
total milk sales, and currently are expected to nearly triple their market share by 2024. Formerly dominating the
non-dairy milk market, soy-based alternatives are falling victim to cannibalization, as newer options present
more healthful claims… This constant diversification of segments within the market is ultimately beneficial to
overall non-dairy milk growth. Unique non-dairy bases (e.g. bananas, sesame) pique consumers’ interest, while
tried and true dairy alternatives, such as almond and coconut, are beginning to serve as household staples,
particularly for young, affluent consumers…”
- Mintel, Milk and Non-Dairy Milk US, 10/2019
“From cashew to banana ‘milk,’ it seems like nondairy milk alternatives have been popping up in every
imaginable form in recent years. And conventional milk has suffered from the competition…”
- Dairy Foods, 2/6/2020
“Some [dairy] companies are taking an if-you-can’t-beat-'em-join-'em approach. In 2016, New York-based
Elmhurst Dairy shut down after more than 90 years of milk sales. In the wake of the closure, Henry Schwartz,
son of the company’s founder, started Elmhurst 1925 to focus on plant-based milks in partnership with scientist
Cheryl Mitchell. After about three years in business, Elmhurst 1925 has drinks in 6,000 stores, including its
most popular drink, unsweetened almond milk. ‘That’s really the way they should be thinking,’ Elmhurst 1925
chief marketing officer Peter Truby said of traditional milk companies. ‘They should really try to diversify…’”
- USA Today, 2/6/2020
PDBA beverages “are leading the marketing narrative with consumers even though they make up a small
portion of overall sales.”
- Erin Massey, product development manager for Prairie Farms Dairy, quoted in Dairy Foods, 11/4/2019

August 2020 Page 12

Consumer Purchase Behaviors, Perceptions and Opinions
• Of 2,000 U.S. adults responding to Mintel’s August 2019 survey, 90% had purchased dairy milk in the
past three months, and 59% had purchased non-dairy milk:

o The top three uses for dairy milk were added to cereal, as a drink for my child and as an
ingredient in cooking a meal. The top three uses for non-dairy milk were as added to cereal, in
smoothies or shakes and as a drink for my child.
 As noted by Mintel, “The majority of adults buy milks, dairy or non-dairy, to use as an
additive.”

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

August 2020 Page 13

o The top three factors for respondents’ choice of dairy milk were container size, fat content and no
artificial ingredients. In contrast, their three most important factors when choosing a non-dairy
milk were brand, no artificial ingredients and flavored.

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

o 26% of respondents said they had purchased more dairy milk in the past three months compared
to 38% who had purchased more non-dairy milk in the past three months.

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

August 2020 Page 14

 • IPSOS’ October 2018 survey of 2,000 U.S. adults found:
o 91% of respondents had ever purchased dairy milk, with the highest percentages buying 2% and
whole milk products (68% and 67%, respectively).
o 56% of respondents had ever purchased plant-based “milk,” with over 30% buying almond-based
(49%), coconut-based (34%) and soy-based (31%) dairy alternatives.
o Among consumers of dairy milk or plant-based “milk” in the past six months:
 62% consumed only dairy milk
 26% consumed dairy milk and plant-based “milk”
 12% consumed only plant-based “milk”
Frequency of Dairy Milk and Plant-Based “Milk” Purchases
(among total)
Purchase Dairy Milk Buyers Plant-Based “Milk” Buyers
timeframe Total Skim/FF 1% fat 2% fat Whole Total Almond Soy Coconut Cashew Rice Pea Flax Hemp
Ever 91% 46% 54% 68% 67% 56% 49% 31% 34% 24% 17% 12% 14% 13%

Last 6 87% 34% 42% 56% 52% 42% 34% 20% 23% 14% 11% 9% 9% 9%
months
At least 79% 26% 30% 46% 42% 32% 25% 12% 12% 9% 7% 6% 6% 5%
once per
month

Source: Online survey of 2,006 U.S. adults conducted by IPSOS in October 2018; dual dairy and plant-based milk purchasers = 768; exclusive
dairy milk purchasers = 858; exclusive plant-based milk purchasers = 101; Question 1: “Please indicate how frequently you purchase each of
the following…” Results cited in Dairy Management Inc. (DMI), “Consumer Perceptions: Dairy and Plant based Milks Phase II,” 1/14/2019

• According to IRI’s January 2019 survey of 1,250+ U.S. consumers

o Among dual buyers of dairy milk and plant-based “milk”:
 The top three reasons for buying dairy milk were family appeal, flavor/taste and use as an
ingredient.
 The top three reasons for buying plant-based “milk” were special diet, health and buy for
myself.

Dual Buyers of Dairy Milk and Plant-Based “Milk”:

Drivers for Choosing Products in Each Category

Source: IRI, National Consumer Panel Survey, January 2019. Cited in IRI, “Understanding the Plant-Based Consumer: A Deeper Look Into
Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

August 2020 Page 15

• Respondents to a Consumer Reports survey of 1,003 U.S. adults in October 2018 were “completely
divided on their views if plant-based milk has more, the same, or less protein, calcium, vitamin A, and
potassium than cow's milk.”

"Compared to cow's milk, do you think unsweetened plant-based milks have MORE, the SAME,
or LESS nutrients (i.e., protein, calcium, vitamin A, and potassium) than cow's milk?"

Don't Know 20%

Less 26%
Same 25%
More 27%
0% 5% 10% 15% 20% 25% 30%

• IPSOS’ August 2018 survey of 2,010 U.S. adults asked respondents why a manufacturer “would label a
product ‘milk’ even though the product may not contain dairy milk.”
o The most frequent reason selected by exclusive dairy milk purchasers (49%) and dual purchasers
(59%) was “nutrition is similar to dairy milk.”

• Online interviews with 2,200 U.S. adults conducted by Morning Consult in August 2019 – a survey
commissioned by the International Dairy Foods Association (IDFA) – more respondents (39%) said they
prefer 2% milk over other any other milk type, including PBDA “milk,” for themselves and/or their family.
Whole milk was the second most preferred type, for 30% of respondents.
o Additionally, over one third (36%) of respondents believe 2% milk is the most nutritious,
compared to 31% who believe whole milk is the most nutritious.
o 77% of respondents said it is somewhat or very important to have a variety of choices when
purchasing the type of milk they or their family prefers.

August 2020 Page 16

 Source: Morning Consult, IDFA Polling Presentation, 8/2019

• IPSOS’ October 2018 survey solicited opinions on whether PBDA beverages should be labeled as “milk”
if USDA Dietary Guidelines don’t recommend them as dairy milk substitutes. Both the exclusive plant-
based buyers and the dual buyers were significantly more likely to say “yes” than exclusive dairy milk
buyers.

“Should All Plant-Based Milks be Labeled ‘Milk’ if U.S. Dietary Guidelines

Do Not Recommend Most as a Substitute for Dairy Milk?”
Exclusive Dairy Milk Dual Buyers Exclusive Plant-Based
Buyers (n=786) "Milk" Buyers
(n=858) (n=101)
7% 31%
41% 29%
32% 41%
61%

28% 30%

Yes Not Sure No Yes Not Sure No Yes Not Sure No

Source: Dairy Management Inc., “Consumer Perceptions: Dairy and Plant-Based Milks Phase II,” 1/2019

• In terms of overall nutrition perceptions, both exclusive plant-based “milk” purchasers (68%) and dual
purchasers (60%) in IPSOS’ August 2018 survey were significantly more likely than exclusive dairy milk
purchasers (24%) to say plant-based milk has “the same nutritional content” as dairy milk.
o Separately, respondents were told that “dairy milk contains 9 essential nutrients and vitamins”
then were asked: “Would you say that plant-based milk contains…”
 44% of exclusive plant-based “milk” purchasers and 39% of dual purchasers believed
plant-based “milk” contains the same or more essential nutrients as dairy milk.
o Regarding almond, soy and coconut “milk” specifically, the majority of exclusive plant-based
“milk” purchasers and dual purchasers said these PBDA “milks” contain the same or more
amounts of protein, vitamins and key nutrients (e.g., calcium, potassium) as dairy milk.
 Over half of the exclusive dairy milk purchasers thought these plant-based “milks” contain
the same or more levels of protein, vitamins and key nutrients as dairy milk.
 Exclusive PBDA “milk” purchasers and dual purchasers were significantly more likely
than exclusive dairy milk purchasers to think these PBDA “milks” have more protein,
vitamins and key nutrients than dairy milk.

August 2020 Page 17

 Nutrition Perceptions of Almond “Milk” vs. Dairy Milk: Selected Results
Exclusive Dairy Milk Buyers Dual Buyers Exclusive Plant-Based “Milk” Buyers
(n=914) (n=789) (n=110)
Same or More than Same as Same or More than Same as Same or More than Same as
More than Dairy Milk Dairy Milk More than Dairy Milk Dairy Milk More than Dairy Milk Dairy Milk
Dairy Milk Dairy Milk Dairy Milk
Protein 73% 22% 51% 82% 37% 44% 79% 44% 35%
Vitamins 73% 15% 58% 83% 28% 55% 86% 38% 48%
Key Nutrients 58% 9% 49% 78% 24% 54% 74% 33% 41%

Nutrition Perceptions of Soy “Milk” vs. Dairy Milk: Selected Results

Exclusive Dairy Milk Buyers Dual Buyers Exclusive Plant-Based “Milk” Buyers
(n=914) (n=789) (n=110)
Same or More than Same as Same or More than Same as Same or More than Same as
More than Dairy Milk Dairy Milk More than Dairy Milk Dairy Milk More than Dairy Milk Dairy Milk
Dairy Milk Dairy Milk Dairy Milk
Protein 70% 18% 52% 79% 30% 49% 77% 44% 33%
Vitamins 67% 11% 56% 78% 22% 56% 82% 29% 53%
Key Nutrients 57% 9% 50% 72% 20% 52% 76% 29% 48%

Nutrition Perceptions of Coconut “Milk” vs. Dairy Milk: Selected Results

Exclusive Dairy Milk Buyers Dual Buyers Exclusive Plant-Based “Milk” Buyers
(n=914) (n=789) (n=110)
Same or More than Same as Same or More than Same as Same or More than Same as
More than Dairy Milk Dairy Milk More than Dairy Milk Dairy Milk More than Dairy Milk Dairy Milk
Dairy Milk Dairy Milk Dairy Milk
Protein 59% 13% 46% 67% 21% 46% 66% 27% 40%
Vitamins 65% 11% 53% 77% 20% 57% 80% 35% 46%
Key Nutrients 58% 10% 48% 72% 19% 53% 82% 29% 52%
Source: Dairy Management Inc., “Consumer Perceptions: Dairy and Plant-Based Milk Alternatives,” 10/2018

August 2020 Page 18

Nutritional Composition: Dairy Milk and PBDA “Milk”
• A review of dairy milk nutrient ranges* and a sample of 60 PBDA “milks” from leading brands** found that many products meet at least one nutrient
standard for milk substitutes in the USDA National School Lunch Program (NSLP) and School Breakfast Program (SBP); however, only one of
these 60 PBDA beverages – Silk Original Soy Soymilk – appears to meet all nine of the NSLP/SBP nutrient standards for milk substitutes.
o This analysis is consistent with the USDA’s Dietary Guidelines for Americans 2015-2020, Eighth Edition, which states: “…Soy beverages
fortified with calcium, vitamin A, and vitamin D, are included as part of the dairy group because they are similar to milk based on nutrient
composition and in their use in meals. Other products… made from plants (e.g., almond, rice, coconut, and hemp “milks”)… are not
included as part of the dairy group because their overall nutritional content is not similar to dairy milk and fortified soy beverages
(soymilk)…”
• PBDA “milk” nutrient values – particularly protein, calcium, phosphorus, potassium and Vitamins A and D – vary widely between plant bases, within
plant bases, and even within individual brand’s products.
o Some PDBA beverages claim nutrient values at least equivalent to those found in cow’s milk, but other PBDA beverages claim values that
are significantly lower than cow’s milk – including calcium, potassium and vitamin D (three of four nutrients of public health concern).
• See Appendix B for nutrient claims of each of the 60 sample PBDA “milks.”
Product Calories Protein Calcium Magnesium Phosphorus Potassium Riboflavin Vitamin B12 Vitamin A Vitamin D Total Sugar
(kcal) (g) (mg; % of (mg; % of (mg; % of new (mg; % of (mg; % of (mcg; % of (mcg RAE; (mcg; % of (g)
new DV) new DV) DV) new DV) new DV) new DV) % of new DV) new DV)
Cow’s milk: ranges for 4 USDA 83.6-149 8.14- 306-325; 29.4-30.8; 251-263; 374-411; 0.322-0.344; 1.34-1.50; 79.7-203; 2.39-2.77; 12-12.4
Foundation Food fluid white milks*** 8.44 24-25% 7% 20-21% 8-9% 25-26% 56-63% 9-23% 12-14%
Milk substitutes: USDA nutrient NS 8 276; 21% 24; 6% 222; 18% 349; 7% 0.44; 34% 1.1; 46% 150; 17% 2.5; 13% NS
standards in the NSLP / SBP
Almond-based beverages: ranges 35-100 0-4 70-450; 15-20; 20-30; 40-220; NS Claims 50% 0-270; 0-5; 0-19
for 15 sample products 5-35% 4-5% 2%-Claims 20% 1-5% 0-30% 0-25%
Soy-based beverages: 100-110 6-8 390-450; 40-50; 80-250; 300-380; 0.4; 1.2-3; 90-150; 3-6; 6-9
ranges for 4 sample products 30-35% 10-12% 6-20% 6-8% 31% 50-125% 10-17% 15-30%
Coconut-based beverages: 45-90 0-1 16-460; 35; 80-250; 300-380; 0.4; 0.9-3; 90-150; 3-6; 0-8
ranges for 6 sample products 0-35% 8% 6-20% 6-8% 31% 38-125% 10-17% 15-30%
Oat-based beverages: 70-170 1-8 110-595; NS 40-270; 40-475; 0.1-0.6; 0.2-2.4; 90-280; 0-5.1; <1-20
ranges for 10 sample products 8-46% 4-22% 0-10% 8-46% 8-100% 10-31% 0-26%
Cashew-based beverages: 45-120 0-2 21-450; 40; NS 30-130; NS 3; 140-150; 2.5; 0-16
ranges for 4 sample products 2-35% 10% 1-3% 125% 16-17% 13%
Pea-based beverages: 70-140 8-10 450-471; NS NS 330-451; NS 2.5-2.7; 110-112; 4-6; 0-15
ranges for 5 sample products 35-36% 7-10% 105-113% 12% 20-30%
Flax-based beverages: 50-60 0-8 280-310; NS 130-210; 0-20; NS 1.3-1.4; 130-140; 2.2-2.3; 0-7
ranges for 2 sample products 22-24% 10-17% 0% 54-58% 14-16% 11-12%
Plant-based beverage blends: 25-130 1-10 0-470; 10-15; 20; 30-470; 0.35; 3.31; 135-250; 2-5; 0-12
ranges for 8 sample products 0-36% 2-4% 2% 1-10% 27% 138% 15-28% 10-25%
Rice-based beverages: 70-130 1 Claims NS 0-claims 15% NS NS NS 0-claims 10% NS-claims <1-12
ranges for 2 sample products 2-25% 25%
Hazelnut-based beverages: 30-130 1-2 123; NS NS 118-253; NS NS NS 2; 16
ranges for 2 sample products 9% 2-5% 10%
Hemp-based beverages: 60-170 3-4 257-263; 57-67; NS 100-150; NS NS NS 2; 0-15
Ranges for 2 sample products 20% 14-16% Claims 2-3% 10%
*per 8-ounce serving; Calories, Protein, Calcium (new DV 1300 mg), Magnesium (new DV 420 mg), Phosphorus (new 1250 mg), Potassium (new 4700 mg), Riboflavin (new DV 1.3 mg), Vitamin B12 (new DV 2.4 mcg),
Vitamin A (new DV 900 mcg RAE) and Vitamin D (new DV 20 mcg). Sources include Mintel’s Global New Products Database; USDA FoodData Central (note: not all nutrient values provided by LabelInsight are available
and/or current); brand/company websites accessed 7/2020
**IRI, “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/2019; GFI, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020
***USDA FoodData Central, Foundation Food average nutrient values
Additional Notes:
• New FDA Daily Values are rounded percentages for adults and children ≥ 4 years.
• NS = not stated on product’s nutrition label. The U.S. FDA’s new Nutrition Facts Label (NFL) does not require reporting magnesium, phosphorus, riboflavin or vitamins A or B12 levels.
• In 2018, McGill University researchers Vanga & Raghavan analyzed the nutritional content of four plant-
based milk alternatives – PBDA almond, soy, rice and coconut “milks” – in comparison to cow’s milk.
o The authors concluded that “nutritionally speaking, soy milk is [the] best plant-based milk”
compared to almond, coconut and rice-based varieties.
o Vanga & Raghavan also presented the following “pros and cons of plant-based milks” as follows:

Source: Vanga & Raghavan (2018)

“It is quite clear that nutritionally soy milk is the best alternative for replacing cow’s milk in human diet. But,
various issues including the ‘beany flavor’ and presence of anti-nutrients are major hurdles which
encouraged people to look for more alternatives like almond milk, etc., Though, almond milk also has a
balanced nutrient profile and much better flavor, the nutrient density and the total number of calories are not
as rich as that of cow’s milk. Hence, when consuming almond milk care should be taken that various
essential nutrients are available through other sources in the diet in appropriate quantities. Rice milk and
coconut milk cannot act as an ideal alternative for cow’s milk because of limited nutrient diversity, but they
are the options for consumers that are allergic to soybeans and/or almonds.” (Vanga & Raghavan, 2018)

August 2020 Page 20

Dairy Milk Market

Sales
• According to IRI data published in Dairy Foods, whole milk was the only refrigerated dairy milk
subcategory to achieve sales growth in 2019:

Refrigerated* Dairy Milk:

2019 Retail Sales ($ million) by Segment
$1,500 (11%)
↓0.4% YoY

$4,900 (37%)
↑2.7% YoY

$6,900 (52%)
↓3.9% YoY

Whole milk Skim/low-fat milk Flavored milk/eggnog/buttermilk

*Sales of shelf-stable milk subcategory were not provided in the article.

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 12/1/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club,
excluding Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty gourmet channels. Cited in Dairy Foods,
“Retail whole-milk sales reemerge,” 2/2020.

• Refrigerated varieties account for nearly 97% of total retail dairy milk sales, with shelf stable varieties
accounting for the remaining 3%.

Retail Dairy Milk Sales ($ million) 2017 vs. 2019

Breakout by Storage Type
2017 2019
$18,000
$15,634 $15,200
$16,000

$14,000

$12,000

$10,000

$8,000

$6,000

$4,000

$2,000 $528 $500

$-

Refrigerated Milk Shelf Stable

Sources: IRI data cited in Mintel, Milk and Non-Dairy Milk, US, 10/2019 and Dairy Foods, 2/2020

August 2020 Page 21

 • Total sales of retail dairy milk fell nearly 21% from 2014 ($19.2 billion) to 2019 ($15.2 billion).
o IRI forecasts sales will decrease another 21% by 2024, reaching $11.9 billion.

Retail Dairy Milk* Market: Sales and Forecast 2014-2024

$ million at current prices

$25,000

$20,000

$15,000

$10,000

$5,000

$-
2014 2015 2016 2017 2018 2019 2020f 2021f 2022f 2023f 2024f
Dairy Milk $19,191 $17,658 $16,477 $16,162 $15,398 $15,200 $14,254 $13,615 $13,048 $12,501 $11,939

Sources: IRI data cited in Mintel, Milk and Non-Dairy Milk, US, 10/2019 and Dairy Foods, 2/2020

*Refrigerated and shelf stable; excludes cream, creamers, condensed/evaporated milk, and powdered milk.

“The largest segment [of U.S. dairy milk sales], skim/low-fat milks, is also the driver of the weakening sales.
While there is potential in flavored and whole milks, which have seen flat or slightly increased sales in recent
years, the segments lack the universal appeal to earn sales sizable enough to balance out the market’s
losses... [However] As fat comes back into fashion, and flavored milks (e.g., chocolate, strawberry) find new
dayparts and purposes, these more decadent dairy milks may help the dairy industry…”
- Mintel, Milk and Non-Dairy Milk US, 10/2019

August 2020 Page 22

Production
According to data from the U.S. Department of Agriculture, 459 plants in the country produced fluid milk in 2018,
56 produced nonfat dry milk (human) and 42 produced skim, unsweetened condensed milk bulk.

Top Three Milk Product Types: U.S. Plants & Production (2018)

Product Type Number of Plants Production

(million pounds)
Fluid Milk 459 47,672
Nonfat Dry Milk (Human) 56 1,774
Skim, Unsweetened Condensed Milk Bulk 42 1,468
Sources: U.S. Department of Agriculture, Economic Research Service, “Number and average size of U. S. fluid milk product plants,” Updated
8/30/2019; U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019)

• The top three milk-producing states in 2019 were California (18.6%), Wisconsin (14.0%) and Idaho
(7.2%).
• Total beverage milk consumed 47.7 billion pounds in 2018, ↓4.1% from 2016.
• Although the total number of fluid milk manufacturing plants ↑15% between 2008 and 2018, the average
production volume during the same 10-year period ↓24%.

Fluid Milk: Manufacturing Plants & Average Production Volume

2008-2018

Average production volume / plant (million

Plants Average production

480 160
460 140
120
Number of plants

440
100
420

lbs)
80
400
60
380 40
360 20
340 0
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Plants 400 392 404 388 399 414 440 456 446 448 459
Average production 136.4 139.9 136.1 139.9 133.9 126.3 115.4 109.7 111.5 108.6 103.9

Source: USDA Economic Research Service Dairy Data, updated 8/13/2019

Condensed Milk Bulk Products: Plants & Production by Type (2016-2018)

Year Number of Plants Production (million
pounds)
2016 - Skim, sweetened: 5 - Skim, sweetened: 77
- Skim, unsweetened: 44 - Skim, unsweetened: 1,651
- Whole, sweetened: 5 - Whole, sweetened: 117
- Whole, unsweetened: 7 - Whole, unsweetened: 97
2017 - Skim, sweetened: 5 - Skim, sweetened: 90
- Skim, unsweetened: 43 - Skim, unsweetened: 1,571
- Whole, sweetened: 5 - Whole, sweetened: 143
- Whole, unsweetened: 8 - Whole, unsweetened: 62
2018 - Skim, sweetened: 7 - Skim, sweetened: 121
- Skim, unsweetened: 42 - Skim, unsweetened: 1,468
- Whole, sweetened: 5 - Whole, sweetened: 145
- Whole, unsweetened: 10 - Whole, unsweetened: 66
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

August 2020 Page 23

 Skim, Unsweetened Condensed Milk Bulk: Plants & Production by State (2016-2018)
State Number of Number of Number of Production 2016 Production 2017 Production 2018
Plants 2016 Plants 2017 Plants 2018 (million lbs) (million lbs) (million lbs)
California 10 9 10 425 308 289
New York 6 5 5 142 116 95
Other States1 28 29 27 1,084 1,146 1,084
Total 44 43 42 1,651 1,571 1,468
1
Fewer than three plants reported or individual plant operations could be disclosed.
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

Dry Milk Products: Plants & Production by Type (2016-2018)

Year Number of Plants Production (million pounds)
2016 - Dry buttermilk, total: 25 - Dry buttermilk, total: 110
- Dry skim milk, animal: 28 - Dry skim milk, animal: 9
- Dry whole milk: 13 - Dry whole milk: 98
- Milk protein concentrate1, total: 11 - Milk protein concentrate1, total: 126
- Nonfat dry milk, human: 50 - Nonfat dry milk, human: 1,753
- Skim milk powder, total2: 14 - Skim milk powder, total2: 559
2017 - Dry buttermilk, total: 24 - Dry buttermilk, total: 113
- Dry skim milk, animal: 27 - Dry skim milk, animal: 12
- Dry whole milk: 15 - Dry whole milk: 122
- Milk protein concentrate1, total: 12 - Milk protein concentrate1, total: 139
- Nonfat dry milk, human: 52 - Nonfat dry milk, human: 1,835
- Skim milk powder, total2: 15 - Skim milk powder, total2: 530
2018 - Dry buttermilk, total: 24 - Dry buttermilk, total: 118
- Dry skim milk, animal: 28 - Dry skim milk, animal: 14
- Dry whole milk: 13 - Dry whole milk: 144
- Milk protein concentrate1, total: 14 - Milk protein concentrate1, total: 146
- Nonfat dry milk, human: 56 - Nonfat dry milk, human: 1,774
- Skim milk powder, total2: 19 - Skim milk powder, total2: 567
1
Dry milk protein concentrate, 40.0-89.9 percent.
2
Includes protein standardized and blends.
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

Nonfat Dry Milk (Human): Production by State (2016-2018)

State Number of Number of Number of Production 2016 Production 2017 Production 2018
Plants 2016 Plants 2017 Plants 2018 (million lbs) (million lbs) (million lbs)
California 11 11 12 567 562 587
Pennsylvania 3 4 6 184 184 181
Other States1 36 37 38 1,001 1,089 1,005
Total 50 52 56 1,753 1,835 1,774
Fewer than three plants reported or individual plant operations could be disclosed.
1

Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

Canned Milk Products: Plants & Production by Type (2016-2018)

Year Number of Plants Production (million pounds)
2016 - Evaporated and condensed whole1: 5 - Evaporated and condensed whole1: 457
- Evaporated skim: 3 - Evaporated skim: 17
2017 - Evaporated and condensed whole1: 5 - Evaporated and condensed whole1: 379
- Evaporated skim: 3 - Evaporated skim: 9
2018 - Evaporated and condensed whole1: 7 - Evaporated and condensed whole1: 413
- Evaporated skim: 3 - Evaporated skim: 15
1
Combined to avoid disclosing individual plant operations
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

August 2020 Page 24

Leading Refrigerated Milk Brands
According to IRI data, private label dominates the refrigerated milk segment, accounting for over 50% of U.S.
retail dollar sales as of August 2019 (whole milk sales ↑0.9% from 2018; skim/lowfat milk sales ↓5.9%).
• Private label, combined with the top nine brands, generated approximately 85% of U.S. MULOC $ sales
of refrigerated milk products as of 8/11/2019.
• The brand with the highest market share – Dean Foods’ DairyPure – accounted for just 13% of whole milk
and 10% of skim/lowfat refrigerated milk sales.
• The top nine brands (excluding private label) market 130 refrigerated milk products on their websites.
o 29% of products are whole; 29% are reduced fat; 21% are lowfat; and 21% are fat free/skim.
o Each of these nine brands – except for DairyPure – markets flavored milks.
 Flavored varieties represent 17-50% of the top nine brands’ product portfolios.
o IRI’s database included 518 Universal Product Codes (UPCs) from these nine brands – plus
1,914 private label UPCs – for a total of 2,432 unique UPCs with 2018 retail sales.
• Most of the nine leading brands have diverse product portfolios which include combinations of lactose
free, ultra-filtered, high protein, Omega 3, grassfed and/or flavored varieties.
o Three brands – Horizon Organic, Lactaid and Borden – offer high protein varieties.
o All brands except for Fairlife and Hood sell lactose free varieties.
o Fairlife and Hood market ultrafiltered varieties. Fairlife claims its products have “50% more protein
and 50% less sugar than regular milk,” while Hood states its plain varieties contain “25% more
protein and 20% more calcium than whole milk.”
• Ultra-filtered milk brand Fairlife was the fastest-growing brand in 2019, ↑45.6% from 2018 in whole milk
sales and ↑30.9% in skim/lowfat milk sales.
• HP Hood’s Lactaid was the only other leading brand to experience growth in both whole milk and
skim/lowfat milk sales (↑11.0% and ↑2.3%, respectively).
• DairyPure, Borden, Prairie Farms and Hood brands’ 2019 sales all ↓ in whole and skim/lowfat segments.
o Dean Foods – DairyPure’s brand owner – and Borden Dairy filed for bankruptcy in November
2019 and January 2002, respectively. Both companies were recently acquired by other entities.
• According to a November 2019 Storebrands article, “several grocers like The Kroger Co.,
Publix Super Markets, Albertsons Cos. and Walmart manufacture their own milk and
dairy products, which has impacted dairy companies’ sales. These retailers are also
selling their own brand milk at low prices to increase traffic...”
• In addition to owning leading brand Horizon Organic, Danone leads two PBDA categories through its Silk
and So Delicious Dairy Free “milk” brands and So Delicious Dairy Free and Good Plants “yogurt” brands.
o The top two retailers with dairy milk sales – Walmart and Kroger – also sell PBDA “milk” varieties.
o Hiland Dairy also lists dairy-free options on its website: “almondmilk,” “soymilk” and “oatmilk.”
 According to Hiland, “…these dairy-free drinks are a tasty, nutritious alternative.”
• In terms of new products, from 2009-2019, over 100 companies launched 476 new refrigerated milk
products/varieties (36% private label; 35% flavored) in the U.S.
o From January-June 2020, 16 companies launched 28 new refrigerated milk products/varieties
(64% private label; 7% flavored) in the U.S.

Brand Parent Company Product Portfolio Listed on $ Share of $ Retail Sales** $ Sales
Brand Website* Refrigerated as of 7/2019 Change YoY**
Milk as of
7/2019**
Multiple stores Leading retailer comments • Whole: • Whole: • Whole:
• #1 Walmart sells refrigerated 53.4% $2.59 billion ↑0.9%
dairy milk and “almondmilk”
under its Great Value store • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
56.8% $3.93 billion
brand. ↓5.9%
• #2 Kroger sells refrigerated
dairy milk through its Kroger
store brand and “almondmilk”
and “oatmilk” through its Simple
Truth store brand.
Note: IRI’s database included over
1,900 private label refrigerated
milk products with unique UPCs
and 2018 retail sales***

August 2020 Page 25

 Dean Foods 8 varieties (none flavored)
"
• Whole: • Whole: • Whole:
(Note: In 11/2019, • Whole (2): plain, lactose free 12.7% $616.4 million ↓0.7%
Dean Foods filed • Reduced fat 2% (2): regular,
lactose free • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
for bankruptcy. In 9.9% $685.2 million
5/2020, the • Lowfat 1% (2): plain, lactose ↓10.2%
company sold free
assets to Prairie • Fat free (2): plain, lactose free
Farms Dairy, Dairy Note: IRI’s database included 121
Farmers of Dairy Pure refrigerated milk
America (DFA) and products with unique UPCs and
Producers Dairy 2018 retail sales***
Foods.)
Danone North 17 organic varieties (18% • Whole: • Whole: • Whole:
America flavored) 5.3% $257.1 million ↑10.6%
• Whole (5): plain, grassfed, high
protein, DHA Omega-3, • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
3.9% $272.8 million
“Growing Years” ↓1.4%
• Reduced fat 2% (6): plain,
grassfed, high protein, DHA
Omega-3, lactose-free,
chocolate high protein
• Lowfat 1% (3): plain, chocolate
with DHA Omega-3, eggnog
• Fat free (3): plain, DHA Omega-
3, lactose-free
• Horizon Organic also markets
shelf stable RTD milks and dry
whole milk.
Note: IRI’s database included 70
Horizon Organic Pure refrigerated
milk products with unique UPCs
and 2018 retail sales***
HP Hood 12 lactose free varieties (17% • Whole: • Whole: • Whole:
flavored) 3.4% $166.1 million ↑11.0%
• Whole (5): plain, calcium-
enriched, protein, chocolate, • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
6.0% $416.5 million
eggnog ↑2.3%
• Reduced fat 2% (3): plain,
calcium-enriched, protein
• Lowfat 1% (2): plain, calcium-
enriched
• Fat free (2): plain, calcium-
enriched
Note: IRI’s database included 26
Lactaid refrigerated milk products
with unique UPCs and 2018 retail
sales***
Borden Dairy 14 varieties (50% flavored) • Whole: • Whole: • Whole:
(Note: In January • Whole (4): plain, chocolate, 2.2% $105.1 million ↓3.3%
2020, Borden filed strawberry, buttermilk
• Reduced fat 2% (3): plain, • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
for bankruptcy. In 0.8% $56.2 million
7/2020, the lactose free, high protein ↓8.6%
company was • Lowfat 1% (4): plain, chocolate,
acquired by private strawberry, buttermilk
equity firm Capitol • Lowfat ½% (1): buttermilk
Peak Partners and • Fat free (2): plain, lactose free
investment firm Note: IRI’s database included 49
KKR.) Borden refrigerated milk products
with unique UPCs and 2018 retail
sales***

August 2020 Page 26

Prairie Farms Dairy 23 varieties (30% flavored) • Whole: • Whole: • Whole:
• Whole (7): plain, plain UHT (ultra- 2.1% $100.6 million ↓1.2%
pasteurized), plain lactose free,
chocolate, chocolate UHT (ultra- • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
2.4% $163.7 million
pasteurized), plain organic, ↓5.2%
chocolate lactose free
• Reduced fat 2% (5): plain, plain
UHT (ultra-pasteurized), plain
lactose free, plain organic,
chocolate
• Lowfat 1% (6): plain, plain UHT
(ultra-pasteurized), plain lactose
free, chocolate, strawberry,
buttermilk
• Fat free (5): plain, plain UHT
(ultra-pasteurized), plain lactose
free, plain organic, chocolate
Note: IRI’s database included 81
Prairie Farms refrigerated milk
products with unique UPCs and
2018 retail sales***
Hiland Dairy, 16 varieties (44% flavored) • Whole: • Whole: • Whole:
“incorporated by • Whole (4): plain, plain lactose 2.0% $97.4 million ↑3.1%
Prairie Farms free, plain organic chocolate
Dairy” lactose free, buttermilk • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
1.6% $108.6 million
• Reduced fat 2% (4): plain, plain ↓8.0%
lactose free, plain organic
strawberry, chocolate
• Lowfat 1% (3): plain, chocolate,
buttermilk
• Fat free (5): plain, plain lactose
free, “Skim Extra”, plain extra
calcium lactose free, vanilla
almond lactose free
Note: IRI’s database included 65
Hiland refrigerated milk products
with unique UPCs and 2018 retail
sales***
Fairlife, LLC 11 ultra-filtered varieties (45% • Whole: • Whole: • Whole:
flavored) 1.6% $75.3 million ↑45.6%
• Whole (3): plain, plain with DHA
Omega-3, chocolate with DHA • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
2.8% $196.8 million
Omega-3 ↑30.9%
• Reduced fat 2% (6): plain, plain
with DHA Omega-3, chocolate,
strawberry, cookies and crème,
vanilla
• Lowfat 1% (1): plain
• Fat free (1): plain
Note: IRI’s database included 22
Fairlife refrigerated milk products
with unique UPCs and 2018 retail
sales***
Organic Valley 19 organic, ultra-pasteurized • Whole: • Whole: • Whole:
varieties (21% flavored) 1.4% $68.1 million ↑3.0%
• Whole (6): plain, plain ultra-
filtered, plain lactose free, • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
1.1% $78.6 million
grassfed, Omega 3, eggnog ↓8.4%
• Reduced fat 2% (8): plain, plain
ultra-filtered, plain lactose free,
chocolate, chocolate ultra-filtered,
grassfed, Omega 3, buttermilk
• Lowfat 1% (2): plain, plain lactose
free
• Fat free (3): plain, plain ultra-
filtered, plain lactose free
Note: IRI’s database included 41
Organic Valley refrigerated milk
products with unique UPCs and
2018 retail sales***

August 2020 Page 27

 HP Hood 10 varieties (40% flavored) • Whole: • Whole: $46.4 • Whole:
• Whole (2): plain, chocolate 1.0% million ↓0.3%
• Reduced fat 2% (1): plain
• Lowfat 1% (3): plain, plain Simply • Skim/lowfat: • Skim/lowfat: • Skim/lowfat:
1.1% $77.8 million
Smart ultrafiltered, chocolate ↓8.8%
• Fat free (4): plain, plain Simply
Smart ultrafiltered, chocolate
Simply Smart ultrafiltered,
buttermilk
• Hood’s LightBlock Bottle “protects
your milk so it will be fresh and
delicious, while providing the
nutrients your family needs.”
Note: IRI’s database included 43
Hood refrigerated milk products with
unique UPCs and 2018 retail
sales***

*Brand/company websites, accessed 7/2020

**IRI, U.S. MULOC $ sales for 52 weeks ending 8/11/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding
Costco; Dollar; Military DECA) plus Convenience Stores, cited in Dairy Foods’ 2019 State of the Industry report, 11/4/2019
***IRI’s syndicated retail sales database; dataset extract provided by ONFL

“Private label brands dominate the dairy milk market, accounting for more than half of MULO sales. Most dairy
milk consumers consider dairy milk to be a functional necessity, leading them to purchase low-cost, familiar private
label options. Though, private label also recorded sizable sales declines of more than 3% between 2018 and 2019
($227 million). These losses are rivaled by those seen by Dean Foods, whose annual sales decreased by nearly
$160 million… The majority of the growth in the dairy milk market stems from smaller, more premium brands, or
those with unique ingredients and added nutritional benefits. Indeed, lactose free milks from HP Hood and ultra-
filtered premium options saw significant year-over-year sales increases…”
– Mintel, Milk and Non-Dairy Milk US, 10/2019

Horizon Organic’s new High Protein milk “is a perfect example of how Horizon has kept up on trends and
innovated in the space, contributing to growth in the category, especially against consumer wants and needs…
We’re now seeing high-protein milks being used in households as a complement to regular milk as opposed to
being reserved for more niche consumption moments.”
– Domenic Borrelli, president of premium dairy, Danone North America, quoted in Dairy Foods, 11/2019

“Since [the] skim and 1% milk segments are seeing a decline in consumption, we spent time with these
consumers to better understand their needs... What we found was 27% of dairy buyers and 35% of nondairy
buyers say extra protein will encourage them to drink more milk.”
– Meenakshi Treehan, vp of brand and innovation, Organic Valley, quoted in Dairy Foods, 11/2019

August 2020 Page 28

Leading Shelf Stable RTD Milk Brands
According to IRI, Nestlé Nesquik is the #1 brand in shelf stable ready-to-drink (RTD) dairy milk (excluding cream,
creamers, condensed/evaporated milk, and powdered milk).
• Nesquik accounted for 41% of U.S. retail sales as of July 2019, ↓3.7% from 2018 overall, but its Protein
Power variants ↑75.1%, illustrating growing consumer demand for beverages with added protein.
o In the PBDA category, Nestlé also recently launched Nesquik GoodNes Chocolate Oatmilk “with
a blend of Oat & Pea protein to give you a complete protein your body needs.”
• Horizon Organics, close behind at #2, accounted for 38% of refrigerated milk sales (↓8.4% from 2018).
o Horizon Organic brand owner Danone leads two PBDA categories through its Silk and So
Delicious Dairy Free “milk” brands and So Delicious Dairy Free and Good Plants “yogurt” brands
• Private label products held the #3 market share with 7.7% (↓2.0% from 2018).
• The top two brands currently market 15 shelf stable milks on their brand websites
o All but one of these products are lowfat, and 87% are flavored.
o IRI’s database included 67 Universal Product Codes (UPCs) from these two brands – plus 181
other brand and private label UPCs – for a total of 248 unique UPCs with 2018 retail sales.
• In terms of new products, between 2009 and 2019, over 30 companies launched 63 new shelf stable milk
products/varieties (16% private label; 84% flavored) in the U.S.
o From January-June 2020, two companies launched four new shelf stable RTD milk
products/varieties (75% private label; 50% flavored) in the U.S.
Brand Parent Company Comments Market $ Retail Sales** $ Sales Change
Share of as of 7/2019 YoY**
Shelf Stable
RTD Milk as
of 7/2019**
Nestlé SA 8 varieties (all flavored) 40.7% $101.3 million ↓3.7%
• Lowfat (9): vanilla Protein
Power, chocolate Protein • Nestlé Nesquik: • Nestlé Nesquik:
Power, banana Protein $94.4 million
↓6.9%
Power, vanilla, strawberry,
• Nestlé Nesquik
chocolate, double chocolate, • Nestlé Nesquik
Protein Power:
banana strawberry Protein Plus:
$6.96 million
• Nesquik also markets ↑75.1%
flavored milk powders.
Danone North 7 organic varieties (71% 38.3% $95.4 million ↓8.4%
"

America flavored
• Whole (1): plain
• Lowfat (6): plain, vanilla,
chocolate, strawberry,
vanilla with DHA Omega-3,
chocolate with DHA Omega-
3
• Horizon Organic also
markets refrigerated dairy
milk and dry whole milk.
Multiple stores • Private label products hold a 7.7% $19.3 million ↓2.0%
much smaller market share
of this segment compared to
refrigerated milk, in which
private label accounts for
over half of total sales.
*Brand/company websites, accessed 7/2020
**IRI, U.S. MULOC $ sales for 52 weeks ending 7/142019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding
Costco; Dollar; Military DECA) – excluding Cream, creamers, condensed/evaporated milk, and powdered milk – cited in Mintel’s Milk and Non-
Dairy Milk – US, 10/2019
***IRI’s syndicated retail sales database; dataset extract provided by ONFL

“Like the refrigerated dairy milk segment, shelf-stable dairy is struggling… Protein is an added benefit that
continues to excel across food and drink products. While milks are naturally high in protein, adding additional
protein sources may help brands compete with high-protein non-dairy substitute, while clear messaging about
the added health benefits can help brands stand out in the saturated space.”
– Mintel, Milk and Non-Dairy Milk US, 10/2019

August 2020 Page 29

Current Industry Practices: Fortification
• In response to an email inquiry sent in May 2020, the National Agricultural Library (NAL) responded that
“most cow’s milk sold in stores in the U.S. is fortified” with vitamins A and D.
• Looking ahead, Rebecca Heagney, director of marketing at Dairy Farmers of America’s Kemps brand,
commented in a 2019 interview with Dairy Foods: “Added value benefits are a big space for product
development opportunities — consumers across the board are looking to their food and beverages to do
more… so benefits like probiotics, added protein, calcium and new, exciting taste experiences will be
important opportunities.”

Consumer Demographics, Behavior & Perceptions

• Mintel’s August 2019 survey of 2,000 U.S. adults found that 91% had purchased any dairy milk in the past
three months, with 2% fat (45%) and whole milk (35%) the most popular varieties.
o Among the more targeted varieties, both men and women were most likely to purchase flavored
milk (23% and 19%, respectively).

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

August 2020 Page 30

 o The #1 uses for dairy milk by type were as follows:
 Whole milk: As an ingredient in cooking a meal and as an ingredient in baking
 Skim/low-fat milk: As an ingredient in cooking a meal and as a drink with a meal for
myself
 Flavored milk: As a drink with a meal for myself and on the go

o Parents and adults without children purchased 2% milk and whole milk more than any other
variety.

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

“Parents are a primary purchaser of dairy milks; they are more likely than adults without children to purchase
each type of dairy milk. This is particularly true for dairy milks with unique claims (e.g. organic, flavored,
lactose-free)… Adults without children are less invested in their dairy milk choices… but tend to prefer
fundamental, functional dairy milk, as opposed to more niche options. These limited-interest purchasing
habits indicate that they may be more likely to leave the dairy market, perhaps switching to non-dairy milks
instead… Digestive health is one of the primary reasons that consumers are switching away from dairy milks,
with 27% agreeing that they are buying less dairy milk because they are consuming less lactose, and 13%
stating that they’ve developed an intolerance to dairy milk…”
- Mintel, Milk and Non-Dairy Milk, 10/2019

August 2020 Page 31

o Among the 26% of respondents who purchased more dairy milk this year than last year,
millennials said they were purchasing more than any other age group.

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

.
o Among the 11% of respondents who purchased less dairy milk this year than last year, the top
reason was due to “consuming less lactose.”

August 2020 Page 32

Selected Recent Product Innovations
• According to Dairy Foods’ latest State of the Industry report, new product introductions in 2019 included:
o Organic Valley’s “new Ultra line of ultrafiltered organic milk has 50% more protein and 50% less sugar
than regular milk.”
o Danone North America’s Horizon Organic brand “joined the trend by introducing Horizon Organic
High Protein in Reduced Fat Chocolate, Reduced Fat Plain and Vitamin D varieties. It includes 12
grams of organic protein per serving…”
o Darigold’s new Darigold Fit line is “ultafiltered and lactose-free, contains 75% more protein and 40%
less sugar than regular 2% milk. The farmer-owned cooperative’s ultrafiltration process naturally
concentrates protein and removes sugars, resulting in milk packed with nutrition. Darigold also is
offering Fit Chocolate, with more protein, less sugar and fewer ingredients than its competitors.”

August 2020 Page 33

PBDA “Milk” Market
Retail Sales & Household Penetration
• Dollar retail sales of PBDA “milk” reached $2.0 billion in 2019, ↑5% from 2018 and ↑14% from 2017.
o Refrigerated “milk” accounted for 89.5% of sales, and shelf stable “milk” accounted for 10.5%.
o 91% of total PBDA “milk” sales were recorded in IRI’s conventional multi outlet (MULO) channel,
compared to 9% in SPINS’ natural and specialty gourmet channels.
o Almond was the top-selling plant base in 2019, with $1.3 billion in sales and a 65% share.
 Sales of almond “milk” topped the 2nd highest seller – soy “milk” – by >600%.
o Dollar sales of almond, oat, pea and “other” plant bases ↑ from 2018.
 Oat was the fastest-growing plant base, with dollar sales ↑686% from 2018.
 The “other” category included emerging plant bases like hemp and flax.
o Dollar sales of soy, coconut, cashew, rice and blend plant bases ↓ from 2018.
• According to The Good Food Institute’s 2019 Good Food Retail Report, “Retailers as a whole excel at
providing plant-based milk products. Leading assortments [at retailers including Whole Foods and
Kroger’s King Sooper supermarkets] boast 70–90 SKUs.”
• Refrigerated PBDA “milk” sales grew in each of IRI’s eight U.S. regions in 2019, with four of the regions
accounting for 65% of total refrigerated PBDA “milk” sales: North East (21%), South East (16%),
California (15%) and West (13%).
o Nearly 40% of households bought refrigerated PBDA “milk” in the past six months (↑1.9% y-o-y),
with 76% purchasing at least twice.
o Only 10% of households bought shelf-stable PBMDA “milk” (↓0.8% y-o-y), with 52% purchasing
at least twice.

Note: The “other” category included emerging plant bases like hemp and flax.
Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

August 2020 Page 34

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

PBDA “Milk”: Household Penetration and Single vs. Multiple Purchasers

Source: IRI, National Consumer Panel Survey, January 2019. Cited by IRI, “Understanding the Plant-Based Consumer: A Deeper Look Into
Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

August 2020 Page 35

Production

Note: See Appendix G for additional information on protein processing.

• Oatly depicts its PBMA oat-based “milk” process as follows:

Source: Oatly website

• David McClements from the University of Massachusetts Amherst authored a 2020 Foods article titled
“Development of next-generation nutritionally fortified plant-based milk substitutes: structural design
principles.” The article contained the following visuals depicting common PBDA “milk” manufacturing
processes:

August 2020 Page 36

Source: McClements et al. (2019)

August 2020 Page 37

Leading Refrigerated Brands
The top nine refrigerated (RFG) PBDA “milk” brands (according to IRI retail sales data, as of October 2019)
currently market 136 products – 32% of which are shelf stable – on their brand websites.
• Products from these nine brands, plus aggregate private label products, generated 98% of U.S. MULOC
$ sales of refrigerated PBDA “milk” products as of 10/6/2019.
• IRI’s database included a significantly higher number of individual PBDA “milk” products from these
leading brands plus private label: 242 branded Universal Product Codes (UPCs) and 332 private label
UPCs, for a total of 574 unique UPCs with 2018 retail sales.
o Additionally, IRI’s database included 426 PBMA “milk” products from 179 more brands, for a
total of 1,000 unique UPCs from 188 brands and private label manufacturers.
• The top two brands – Danone North America’s Silk and Blue Diamond Growers’ Almond Breeze – had a
combined market share of 70.6% (39.8% and 30.8%, respectively).
o In addition to #1 brand Silk, Danone North America’s U.S. brands in the top 10 PBDA “milk”
brands include So Delicious Dairy Free and Silk Oat Yeah. Group Danone acquired these plant-
based brands from WhiteWave Foods in 2017.
• Danone North America’s brands also include Horizon Organic dairy milk, which it also acquired from
WhiteWave Foods in 2017. Other leading dairy milk processors such as HP Hood and Dean Foods have
begun participating in the plant-based “milk” space.
o In 2019, HP Hood launched Planet Oat Oatmilk, and in 2018, Dean Foods became majority
shareholder of Good Karma Foods.
o Danone North America launched Silk Oat Yeah in 2019.
• Oatly’s Oatly! brand had the highest sales growth in 2019, ↑727.1% from 2018.
• Product labels for half of the top 10 brands – including Silk – include direct comparisons to dairy milk
nutrient(s), primarily calcium.
• Private label brands collectively had the 3rd highest market share (16.4%) in 2019, ↑14.8% from 2018.
• Seven of the top nine brands list at least one unsweetened product on their websites. Silk lists 15
unsweetened or less sugar flavors (42% of its PBMA “milks”) and Almond Breeze lists 14 unsweetened or
reduced sugar flavors (56% of its PBMA “milks”).
• In terms of new products, between 2009 and 2019, approximately 100 companies launched 457 new
liquid PBDA “milk” products/varieties (29% private label; 70% refrigerated) in the U.S.
o From January-June 2020, 13 companies launched 24 new PBDA “milks” (42% private label; 75%
refrigerated) in the U.S.
o According to Mintel’s Global New Products Database, 8% of the 24 products launched in 2009
listed claims of low/reduced sugar or no added sugar, compared to 38% of the 55 products
launched in 2019 that listed the same claims.
Brand Parent Current Product Portfolio Currently Listed on $ Share** $ Retail Change
Company Brand Website* (% unsweetened or reduced of RFG Sales** of YoY**
sugar varieties) “milk” as RFG
of 10/2019 “milk”
as of
10/2019
Danone North 43 varieties (44% unsweetened or less sugar) 39.8% $664.7 ↓2.5%
America • “Almondmilk”: 10 chilled flavors (4 unsweetened, 2 million
less sugar); 6 shelf stable flavors (2 unsweetened;
1 less sugar); “50% more calcium than dairy milk”
• “Soymilk”: 8 chilled flavors (2 unsweetened); 5
shelf stable flavors (1 unsweetened)
• “Coconutmilk”: 2 chilled flavors (1 unsweetened)
• “Cashewmilk”: 3 chilled flavors (2 unsweetened)
• “Almondmilk coconutmilk blends”: 2 chilled flavors
(1 unsweetened)
• “Protein” blends: 5 chilled flavors with “pea,
almond and cashewmilk” (2 unsweetened)
• “DHA Omega-3” blends: 2 chilled flavors with
“pea, almond and cashewmilk”; “50% more
calcium than dairy milk” (1 unsweetened)
• See Silk “Oat Yeah” Oatmilk brand below.
Note: IRI’s database included 116 Silk PBMA “milk”
products (chilled and shelf stable) with unique UPCs
and 2018 retail sales***

August 2020 Page 38

Blue Diamond 25 varieties (56% unsweetened or reduced sugar) 30.8% $514.0 ↑6.3%
Growers • “Almondmilk”: 10 chilled flavors (3 unsweetened; 2 million
reduced sugar); 6 shelf stable flavors (3
unsweetened)
• “Almondmilk coconutmilk blends”: 3 chilled flavors
(2 unsweetened); 3 shelf stable flavors (2
unsweetened)
• “Almondmilk cashewmilk blends”: 2 chilled flavors
(2 unsweetened)
• “Almondmilk blended with real bananas”: 1 chilled
flavor
Note: IRI’s database included 49 Almond Breeze
PBMA “milk” products (chilled and shelf stable) with
unique UPCs and 2018 retail sales***
Multiple stores At least 130 products, including: 16.4% $274.7 ↑14.8%
• Target Good & Gather “Almondmilk”: 4 chilled million
flavors (2 unsweetened); “50% more calcium than
dairy milk”
• Target Simply Balanced “Coconutmilk non-dairy
beverage”: 1 shelf stable flavor (1 unsweetened)
• Wal-Mart Great Value “Almondmilk”: 5 chilled
flavors (2 unsweetened); “50% more of the daily
value of calcium than regular milk”
• Trader Joe’s “Non-Dairy Oat Beverage”: 1 chilled
flavor; 1 shelf stable flavor
• Trader Joe’s “Simply Almond Beverage”: 1 chilled
flavor
• Whole Foods Market 365 Everyday Value
“Coconutmilk Beverage”: 1 shelf stable flavor (1
unsweetened)
• Costco Kirkland Signature “Organic Soy Non-
Dairy Beverage”: 2 shelf stable flavors
Note: IRI’s database included 332 private label
PBMA “milk” products (chilled and shelf stable) with
unique UPCs and 2018 retail sales***
Califia Farms 17 varieties (41% unsweetened or no sugar added) 5.3% $88.8 ↑14.9%
• “Almondmilk”: 8 chilled flavors (4 unsweetened); 1 million
shelf stable flavor (1 unsweetened); “40% more
calcium than milk”
• “Coconut almondmilk blends”: 2 chilled flavors;
“50% more calcium than milk”
• “Oatmilk”: 3 chilled flavors; 1 shelf stable flavor;
“45% more calcium than dairy milk”
• Oatmilk almondmilk blend: 1 chilled flavor (1 no
sugar added)
• “Coconut milk coconut water blend”: 1 chilled
variety (1 no sugar added); “50% more calcium
than milk”
• Three flavors were given a “5-plant rating” on The
Cornucopia Institute’s Scorecard of “top rated
plant based beverages – organic with few or no
additives.”
Note: IRI’s database included 19 Califia Farms
PBMA “milk” products (chilled and shelf stable) with
unique UPCs and 2018 retail sales***
Danone North 18 varieties (50% unsweetened or sugar-free) 1.7% $27.6 ↓19.6%
America • “Almondmilk beverage”: 2 shelf stable flavors (1 million
unsweetened)
• “Almondmilk with cashew beverage”: 2 chilled
flavors (1 unsweetened)
• “Coconutmilk beverage”: 5 chilled flavors (2
unsweetened); 7 shelf stable flavors (2
unsweetened; 1 sugar-free)
• “Cashewnutmilk beverage”: 2 shelf stable flavors
(2 unsweetened)
Note: IRI’s database included 29 So Delicious PBMA
“milk” products (chilled and shelf stable) with unique
UPCs and 2018 retail sales***

August 2020 Page 39

 Ripple Foods 8 varieties (25% unsweetened) 1.3% $22.4 ↑27.4%
• “Nutritious plant-based milk”: 5 pea protein-based, million
chilled flavors (2 unsweetened); 3 pea protein-
based shelf stable flavors; “Half the sugar of milk”;
“Half the sugar of flavored milk”; “40% less sugar
than chocolate milk”; “50% more calcium than
milk”
Note: IRI’s database included 12 Ripple PBMA “milk”
products (chilled only) with unique UPCs and 2018
retail sales***
HP Hood 4 varieties (no unsweetened) 0.9% $15.2 New
• “Oatmilk”: 4 chilled flavors million
Note: IRI’s database included 4 Planet Oat PBMA
“milk” products (chilled only) with unique UPCs and
2018 retail sales***
Oatly 8 varieties (no unsweetened) 0.6% $10.8 ↑727.1%
• “Oatmilk”: 5 chilled flavors; 3 shelf stable flavors million
Note: IRI’s database included 4 Oatly PBMA “milk”
products (chilled only) with unique UPCs and 2018
retail sales***
Danone North 4 varieties (25% unsweetened) 0.6% $10.3 New
America • “Oatmilk”: 4 chilled flavors (1 unsweetened) million
Note: IRI’s database included 3 Oat Yeah PBMA
“milk” products (chilled only) with unique UPCs and
2018 retail sales***
Good Karma 9 varieties (67% unsweetened or lightly sweetened) 0.5% $8.9 ↓0.5%
Foods (Note: • “Flaxmilk”: 3 chilled flavors (1 unsweetened); “As million
Dean Foods much calcium and vitamin D as dairy milk”
acquired a • “Flaxmilk + Protein”: 2 chilled flavors with pea
majority stake protein (2 unsweetened)
in Good • “Flaxmilk Omega-3 + Protein”: 4 shelf stable
Karma Foods flavors with pea protein (1 unsweetened; 2 lightly
in 2018.) sweetened)
Note: IRI’s database included 6 Good Karma PBMA
“milk” products (chilled only) with unique UPCs and
2018 retail sales***
*Brand/company websites, accessed 7/2020
**IRI, refrigerated PBMA “milk,” U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass;
Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty gourmet channels. Cited by
IRI, “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/19/2019
***IRI’s syndicated retail sales database; dataset extract provided by ONFL

“Plant-based milk began to gain popularity in the early 2000s due to a mix of product innovation and a
strategic change in merchandising. Indeed, the greatest factor in the growth of plant-based milk was probably
selling it in traditional gable-top packaging alongside cow’s milk in the refrigerated dairy case, as opposed to
aseptic cartons in a segregated center-of-store section. In 2019, retail sales of plant-based milk reached $2
billion, which equates to 14% of the total U.S. retail milk market. Household penetration is currently 41%,
meaning more than four out of 10 U.S. households purchase plant-based milk…”
- The Good Food Institute, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020

August 2020 Page 40

Additional Leading Shelf Stable Brands
A recent Good Food Institute (GFI) market report* listed the top 10 plant-based “milk” brands of 2019 based on its
SPINS dataset of U.S. retail sales.
• GFI’s list of top brands mirrors that of IRI’s, except:
o GFI excluded private label products “because it represents an aggregate of smaller store brands;”
GFI noted, however, that private label products comprised 13.9% of the total refrigerated and
shelf stable PBDA “milk” category
o GFI combined Danone’s Silk and Silk Oat Yeah brands into one Silk brand
o GFI covered both refrigerated and shelf stable products – its list included Hain Celestial’s Dream
and Campbell’s Pacific Foods brands, whose offerings are summarized below.
• Hain Celestial is a player in the PBDA “milk” space through its Dream brand and in the dairy yogurt space
with its The Greek Gods brand.
Brand Parent Current Product Portfolio Currently Listed on Brand Website** (% $ Retail Sales
Company unsweetened or reduced sugar varieties) 2018***
Hain Celestial 17 shelf stable varieties (29% unsweetened or reduced sugar) $21.9 million
• “Dream® Oat Beverages”: 4 shelf stable flavors (1 unsweetened); “Higher
in fiber vs. cow’s milk, almond and soy”
• “Rice Dream® Rice Drinks”: 6 shelf stable flavors (1 unsweetened)
• “Sprouted Rice Dream® Rice Drink”: 1 shelf stable flavor (1 unsweetened)
• “Soy Dream® Soymilks”: 2 shelf stable flavors (none unsweetened)
• “Almond Dream® Almond Drink”: 1 shelf stable flavor (none unsweetened)
• “Coconut Dream® Coconut Drinks”: 3 shelf stable flavors (1 unsweetened)
Note: IRI’s database included 40 Dream shelf stable PBMA “milk” products
with unique UPCs and 2018 retail sales***
Campbell Soup 22 shelf stable varieties (45% unsweetened or reduced sugar) $11.8 million
Company • “Almond Plant-Based Beverages”: 5 shelf stable flavors (2 unsweetened)
• “Oat Plant-Based Beverages”: 3 shelf stable flavors (1 reduced sugar)
• “Cashew Plant-Based Beverages”: 2 shelf stable flavors (1 unsweetened)
• “Coconut Plant-Based Beverages”: 3 shelf stable flavors (2 unsweetened)
• “Hazelnut Plant-Based Beverages”: 3 shelf stable flavors (1 unsweetened)
• “Hemp Plant-Based Beverages”: 4 shelf stable flavors (2 unsweetened)
• “Soy Plant-Based Beverages”: 2 shelf stable flavors (1 unsweetened)
Note: IRI’s database included 50 Pacific Foods shelf stable PBMA “milk”
products with unique UPCs and 2018 retail sales***
*GFI, 2019 U.S. State of the Industry Report: Plant-Based Meat, Eggs, and Dairy, 5/2020
**Brand/company websites, accessed 7/2020
***IRI’s syndicated retail sales database; dataset extract provided by ONFL

August 2020 Page 41

Names/Descriptions on Leading Brands’ Product Labels
• All of the leading branded PBDA “milk” products – except for Pacific Foods – include the term “milk” in at
least one of their product name(s) and/or label(s).
• Some private label products – including Trader Joe’s – also exclude the term “milk” in their product
name/label.

Name/Label Includes the Term Leading Brand(s) with Examples from Front Product Labels
“Milk” Applicable Product(s)
One word: plant base combined with Blue Diamond Almond Breeze
“milk”, e.g., almondmilk, coconutmilk, Califia Farms
flaxmilk, oatmilk, soymilk Dream
Good Karma
Oatly
Planet Oat
Private Label (e.g., Target, Wal-Mart)
Silk
Silk Oat Yeah

Two words: compound word with “milk” Private Label (e.g., Whole Foods
plus “beverage” qualifier e.g., coconutmilk Market)
beverage, almondmilk beverage, dairy- So Delicious Dairy Free
free oatmilk Silk Oat Yeah

Two words: plant base plus “milk,” e.g., Califia Farms

coconut milk

August 2020 Page 42

 Name/Label Includes the Term Leading Brand(s) with Examples from Front Product Labels
“Milk” AND Qualifier(s) Applicable Product(s)
Three words: compound word with “milk” Private Label (e.g., Target, Whole
plus qualifier(s) e.g. coconutmilk non- Foods Market)
dairy beverage, coconutmilk beverage

Plant-based milk alternative Good Karma

Plant-based milk OR Non-dairy plant Ripple

protein milk Bolthouse Farms

Name/Label Excludes the Term Leading Brand(s) with Examples from Front Product Labels
“Milk” Applicable Product(s)
Two words: plant base plus “beverage” Dream
qualifier e.g., almond beverage, oat Private Label (e.g., Trader Joe’s)
beverage

Three words: plant base plus “non-dairy” Pacific Foods

AND “beverage” qualifier e.g., non-dairy Private Label (e.g., Trader Joe’s)
oat beverage, soy non-dairy beverage,
coconut plant-based beverage

Sources: Brand/company websites, accessed 7/2020; Information Resources Inc. (IRI), U.S. MULOC $ sales for 52 weeks ending 10/6/2019
in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience Stores.
Excludes natural and specialty gourmet channels. Cited by IRI, “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the
Growth of Plant-Based Foods,” 11/2019; GFI, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020

• In July 2018, the Plant Based Foods Association (PBFA) released Voluntary Standards for the Labeling of
Plant-based Milks in the United States “to promote consistency in labeling across the category.” Adoption
of the voluntary standards was recommended within one year. They include:
o “The statement of identity should indicate that the milk is plant-based by either:
 Including the characterizing ingredient(s) in conjunction with the word ‘milk,’ presented as
a single word (e.g., ‘almondmilk’) or two words (e.g., ‘almond milk’). If the product is
made from more than one characterizing ingredient, this may be indicated through
hyphenation (e.g., ‘almond-cashew milk’), or
 The product may be labeled as ‘plant-based milk’ (with or without the hyphen) as long as
the characterizing ingredient(s) is/are also clearly stated on the principal display panel
and the information panel.
o For either option, where feasible, all words in the statement of identity should be in the same type
size, the same font and color, and appear on the same line.
o All plant-based milks should clearly be labeled as ‘dairy-free’ (preferable) or ‘nondairy’ in a
prominent position on the principal display panel.”

August 2020 Page 43

Consumer Demographics, Behavior & Perceptions
• In Mintel’s August 2019 survey, over half of respondents who purchased non-dairy milk in the past three
months indicated they had purchased “any non-dairy milk,” followed by 42% who purchased almond milk.

Source: Mintel, Milk and Non-Dairy Milk in the US, 10/2019

o Almond milk was the top purchase choice among all respondents across race/ethnicity, followed
by soy milk and coconut milk.

Source: Mintel, Milk and Non-Dairy Milk in the US, 10/2019

August 2020 Page 44

 o Respondents indicated most frequently that they drink non-dairy milk themselves (78%) and least
frequently that a child aged 5 and younger in the household drinks non-dairy milk (33%).

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

o Among the 38% of respondents who were purchasing more non-dairy milk than last year, the top
three reasons were the perception that it is healthier than dairy milk, taste and it “makes me feel
better.”

Source: Mintel, Milk and Non-Dairy Milk US, 10/2019

• According to IPSOS’ October 2018 survey of U.S. adults, 56% had ever purchased plant-based “milk.”
o Among plant-based “milk” buyers, the top plant bases purchased in the past six months were:
 Almond (71%)
 Coconut (49%)
 Soy (43%)
 Cashew (30%)

August 2020 Page 45

 • IRI’s January 2019 survey of U.S. consumers showed that the top purchasers of refrigerated PBDA “milk”
(determined by cohort’s dollar index* ≥100) were:
o Millennial and Generation X households with incomes ≥$50,000
o Households with 3+ people and 1+ child
o Hispanic households

*Dollar index = (% dollars / % households) x 100

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 11/3/2019 in Multi Outlet Channels plus Convenience Stores. Cited by IRI,
“Understanding the Plant-Based Consumer: A Deeper Look Into Plant-Based Purchase Trends, Demographics, Perceptions and Usage,”
1/16/2020

• Twelve FDA-commissioned focus groups were conducted by RTI International in three U.S. cities in April-
May 2019. Interviews with the 112 participants revealed themes including:
o Participants in 11 of the 12 groups liked that PBDA “milk” does not cause issues with lactose
intolerance compared to cow’s milk.
o Participants in nine groups believed PBDA “milk” was a healthier alternative (e.g., less calories,
fat, sugar); however, participants in eight of the groups said it is less nutritious than cow’s milk.
o Participants in 11 groups said they like PBDA “milk” because it “tastes better” or has “more flavor
than [cow’s] milk,” but participants in eight of the groups said they dislike the flavor compared to
cow’s milk.
o Participants in seven groups noted the high price of plant-based products.
o Participants in nine groups liked the longer expiration or shelf-life of PBDA “milk” compared to
cow’s milk.
o Participants in six groups said PBMA “milks” are processed or contained a lot of unclear
ingredients.
 Additionally, participants in four of eight groups who were asked what ingredients PBMA
“milks” contain said they did not know.

Selected Recent Product Innovations

Dairy Foods’ 2018 State of the Industry Report quoted Irina Gerry, Silk brand manager, as saying: “With more
choices than ever before in plant-based, consumers are not willing to accept compromises in taste or
nutrition... Continuous taste improvements in plant-based beverages have brought broader taste appeal,
expanding consumer acceptance and growing household penetration for the category to over 35% in the last
three years.” Gerry reportedly “noted that Silk Soy underwent a major improvement in taste and nutrition in
2014, with Silk Almond following in 2017. And in 2016, Silk Protein Nutmilk — featuring pea protein blended
with the brands almond and cashew milks — made its debut in original and vanilla flavors; a chocolate flavor
was added in 2017. The line delivers 10 grams of plant-based protein per serving.”

August 2020 Page 46

 Dairy Yogurt and PBDA “Yogurt”
Market Comparisons

Retail Sales & Household Penetration

• According to SPINS, the plant-based share of the overall yogurt market was just 4% in 2019.
• Total yogurt sales ↓ 2015-2019, while plant-based “yogurt” sales ↑ during the same period.
o Similarly, dollar sales per buyer and household penetration of total yogurt ↓ 2015-2019, while
dollar sales per buyer and household penetration of plant-based “yogurt” ↑ during the same
period.

Total Yogurt Retail Sales Plant-Based "Yogurt" Retail Sales

($ Billions) 2015-2019 ($ Millions) 2015-2019
$7.7 $250.0
$7.6
$7.5 $200.0
$7.4
$150.0
$7.3
$7.2 $100.0
$7.1
$7.0 $50.0
$6.9
$6.8 $0.0

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart;
Club, excluding Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty gourmet channels. Cited by
IRI, “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/19/2019

Total Yogurt: Plant-Based Yogurt:

$ Retail Sales Per Buyer 2015-2019 $ Retail Sales Per Buyer 2015-2019
$78.0 $25.0
$77.0 $20.0
$76.0
$15.0
$75.0
$10.0
$74.0
$73.0 $5.0
$72.0 $0.0
2015 2016 2017 2018 2019 2015 2016 2017 2018 2019

Total Yogurt: Plant-Based "Yogurt":

% Households Buying 2015-2019 % Households Buying 2015-2019
87.0% 10.0%
86.0% 8.0%
85.0% 6.0%
84.0% 4.0%
83.0% 2.0%
82.0% 0.0%
2015 2016 2017 2018 2019 2015 2016 2017 2018 2019

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 11/3/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club,
excluding Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty gourmet channels. Cited by IRI,
“Understanding the Plant-Based Consumer: A Deeper Look Into Plant-Based Purchase Trends, Demographics, Perceptions and Usage,”
1/16/2020

August 2020 Page 47

 • SPINS also reported that the plant-based “yogurt” share of total yogurt sales varied by channel.
o PBDA “yogurt” accounts for 22% of total yogurt sales in the Natural channel but only 3% of total
yogurt sales in the largest (MULO) channel:

Plant-Based "Yogurt" Share of Total Yogurt Sales

in Three Retail Channels 2019:
MULO, Specialty Gourmet and Natural Retail

Natural*** 22%
Specialty Gourmet** 6%
MULO* 3%
0% 5% 10% 15% 20% 25%

*Conventional Multi Outlet (MULO) channel covers >104,000 grocery, drug, mass, dollar, military, and club retail locations
**Specialty Gourmet channel covers “full-format supermarkets” with at least $2 million in annual sales and “SPINS-defined specialty items”
comprising at least 25% of overall volume. Retailers are also defined as “high-end” and “experiential.” (e.g. Gelson’s, Heinen’s, Busch’s)
***Natural channel covers “full-format” stores with at least $2 million in annual sales and at least 50% of sales from
natural/organic products (e.g. Sprouts, Erewhon, Earth Fare; exclude Whole Foods and Trader Joe’s)
Source: SPINSscan Natural and Specialty Gourmet (proprietary) plus SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited by The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

Consumer Behaviors and Attitudes

• A September 2019 survey found that among respondents who had purchased any yogurt in the past
three months, over half were purchasing the same or less yogurt now compared to the previous year:

• Over half of respondents had purchased spoonable dairy yogurt for themselves in the past three months
compared to 25% who had purchased spoonable non-dairy yogurt:

Source: Mintel, Yogurt and Yogurt Drinks US, 11/2019

August 2020 Page 48

• Nearly one-third of 2,000 U.S. adults are not interested in any yogurt innovations that would encourage
them to buy more yogurt:

Source: Mintel, Yogurt and Yogurt Drinks US, 11/2019

“Yogurt fatigue is kicking in. The yogurt market is oversaturated. Attempts to fend off declining sales with
consistent innovation and diversification of product lines has led to crowded shelves that consumers struggle
to navigate. As a result, consumers are becoming apathetic toward innovations. Indeed, nearly a third of
consumers report that they are not interested in yogurt innovations… Indeed, the majority of consumers have
not changed their yogurt purchases year-over-year despite consistent product launches...
Spoonable and drinkable yogurt formats are both popular for children, with 53% of consumers with kids
buying spoonable yogurt and 41% buying yogurt drinks (dairy or non-dairy). Despite the successful launches
of several mass-market nondairy brands, dairy products continue to dominate. However, 18% of parents
wish that there were more non-dairy options targeted toward children; this increases with younger Millennial
parents…”
- Mintel, Yogurt and Yogurt Drinks US, 11/2019

August 2020 Page 49

Nutritional Composition
• Nutrient values posted on brand websites and Mintel’s Global New Products Database were identified for two samples of product types:
o Plain/unsweetened: 12 dairy yogurt and nine PBDA “yogurts” – categorized by traditional and Greek varieties
 The Greek varieties in the sample contain significantly more protein than their traditional counterparts; the traditional PBDA
“yogurts” contain less sugar than the traditional dairy yogurts; and the traditional PBDA “yogurts” have a wider range of calcium
and potassium levels than dairy yogurts.
o Sweetened: Nine dairy yogurt and 13 PBDA “yogurts” – categorized by traditional and Greek varieties
 These Greek varieties also contain significantly more protein than their traditional counterparts; several of the traditional PBDA
“yogurts” contain less sugar than the traditional dairy yogurts; and these traditional PBDA “yogurts” also have a wider range of
calcium and potassium levels than dairy yogurts.
o Each of the PBDA “yogurts” analyzed – 22 products across eight brands – claim live and active cultures on their product labels, with S.
Thermophilus, L. Bulgaricus, L. Acidophilus, and Bifidobacteria among the most common strains.

• See Appendix D for nutrient claims for all 43 yogurts in the samples.

PLAIN/UNSWEETENED Yogurt Calories Fat (g) Protein Calcium Potassium Riboflavin Vitamin Vitamin A Vitamin D Total Claimed
Product (kcal) (g) (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg RAE; (mcg; % of Sugar (g) Live &
new DV) new DV) new DV) % of new % of new new DV) Active
DV) DV) Cultures
Dairy yogurt: ranges for 6 sample 70-120 0-6 6-8 220-320 290-390 NS NS NS 0-1.9 7-10 Yes (100%)
products (170 mg serving)
GREEK Dairy yogurt: ranges for 6 90-170 0-9 14-17 90-190 110-240 NS NS NS 0-2 2-5 Yes (100%)
sample products (170 mg serving)
PBDA “yogurt”: ranges for 7 sample 80-190 4-15 0-8 64-488 0-440 NS 0.9-1.7 NS 0-8 0-6 Yes (100%)
products (170 mg serving)
GREEK PBDA “yogurt”: ranges for 2 160 10 11 121 87 NA NS NS 0 2 Yes (100%)
sample products (150 mg serving)

SWEETENED Yogurt Product Calories Fat (g) Protein Calcium Potassium Riboflavin Vitamin Vitamin A Vitamin D Total Claimed
(kcal) (g) (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg RAE; (mcg; % of Sugar (g) Live &
new DV) new DV) new DV) % of new % of new new DV) Active
DV) DV) Cultures
Dairy yogurt: ranges for 4 sample 100-140 0-7 5-7 180-200 240-280 NS NS 0 1.4-1.6 14-22 Yes (100%)
products (150 mg serving)
GREEK Dairy yogurt: ranges for 5 110-140 0-4.5 11-15 150 200 NS NS NS 0-1.6 12-16 Yes (100%)
sample products (150 mg serving)
PBDA “yogurt”: ranges for 11 sample 80-190 0-7 <1-6 40-350 0-270 NS 1.27-1.30 NS 0-6 4-18 Yes (100%)
products (150 mg serving)
GREEK PBDA “yogurt”: ranges for 2 180-190 9 10 104-105 77-81 NS NS NS 0 12 Yes (100%)
sample products (150 mg serving)

August 2020 Page 50

Dairy Yogurt Market

Retail Sales
• According to IRI data cited by Mintel, the total yogurt and yogurt drinks market was estimated to achieve
$8.2 billion in retail sales in 2019, with spoonable varieties accounting for 87% of sales and the
supermarket channel accounting for 60% of sales.
o Mintel commented: “Forecasts show that total yogurt market sales will fall to $7.4 billion by 2024,
a 10.5% decrease from 2019’s estimated sales.”
o A May 2020 Dairy Foods article reported total refrigerated yogurt sales were $7.1 billion for the 52
weeks ending 1/26/2020 (↓0.7%).

Total Yogurt and Yogurt Drinks: Retail Sales by Segment ($ million)

2014-2024
Spoonable Yogurt drinks/kefir

$9,000
$8,000
$7,000
$6,000
$5,000
$4,000
$3,000
$2,000
$1,000
$-
2014 2015 2016 2017 2018 2019e 2020f 2021f 2022f 2023f 2024f
Spoonable $7,840 $8,057 $7,915 $7,633 $7,293 $7,144 $6,965 $6,726 $6,481 $6,261 $6,058
Yogurt drinks/kefir $723 $802 $909 $1,054 $1,078 $1,098 $1,149 $1,208 $1,254 $1,291 $1,319

Total Yogurt and Yogurt Drinks:

Retail Sales by Channel ($ million)
2014-2019
Supermarkets Other

$6,000

$5,000

$4,000

$3,000

$2,000

$1,000

$-
2014 2015 2016 2017 2018 2019e

Source: Mintel, "Yogurt and Yogurt Drinks - US, November 2019"

August 2020 Page 51

 All Yogurt and Yogurt Drinks: Market Share, 2019
Private Label
7.8%
($560.7
million)

Others
17.8% Groupe Danone SA
($1.28 billion) 33.0%
($2.38 billion)

Parmalat SpA
5.8%
($416.1 million)
General Mills Inc Chobani LLC
17.3% 18.4%
($1.24 billion) ($1.32 billion)

Source: Mintel, "Yogurt and Yogurt Drinks - US, November 2019

“According to [Danone’s Pedro] Silveira, lower-sugar options are the fastest growing segment in yogurt
today. Danone North America recently invested in sugar reduction with its Two Good Greek yogurt line. The
yogurt is slow-strained with a patent-pending process down to 2 grams of sugar per 5.3-ounce cup…
Building on Two Good’s success, Danone North America debuted Activia Less Sugar & More Good at the
beginning of this year. The line contains only 9 grams of sugar, 40% less than regular Activia Greek nonfat
yogurt; its sweetness comes from honey and fruits instead...”
- Pedro Silveira, president, U.S. yogurt, Danone North America, cited in Dairy Foods, 4/9/2020

Yogurt brands “have attempted to compensate for poor performance with increased innovation, ultimately
crowding the marketplace and leading to cannibalization as consumers try product after product without
increasing total purchases… Yogurt is a popular snack choice for children, as it is a convenient source of
key nutrients. Major brands have seen strong growth from their kid-centric lines, particularly in the drinkable
segment…”
- Mintel, Yogurt and Yogurt Drinks US, 11/2019

“Strong brand names, such as the Dannon Company (Dannon), Yoplait and Fage USA Dairy Industry Inc.
have long dominated the US industry. Industry newcomer Chobani LLC (Chobani) made waves by
launching its Greek-style yogurt, which boasts more protein and fewer calories than other yogurt varieties.
Although Chobani still holds the largest share of that segment, the company has forfeited some ground to
Dannon after its introduction of a Greek-style yogurt. As Chobani launches its new brand of child-focused
products, it is expected to take some of Dannon’ s market share for that market segment…”
- IBISWorld, Yogurt Production in the US, 12/2018

August 2020 Page 52

Production

According to data from the U.S. Department of Agriculture, there were 162 dairy yogurt production plants in the
country in 2018.
• Total yogurt production, excluding frozen yogurt, was 4.4 billion pounds in 2018, ↓2.0% from 2016.
o The top two yogurt-producing states were New York (15.7%) and California (9.5%).
o According to IBISWorld, top manufacturer Dannon “runs the world’s largest yogurt manufacturing
plant, located in Minster, Ohio, producing more than three million cups of yogurt per day.”

Yogurt (Plain & Flavored; Excludes Frozen Yogurt): Production by State (2016-2018)
State Number of Number of Number of Production Production Production
Plants Plants Plants 2016 (million 2017 (million 2018 (million
2016 2017 2018 lbs) lbs) lbs)
California 21 20 20 395 442 415
New York 37 39 38 677 707 690
Oregon 3 3 3 52 49 42
Texas 4 3 3 51 34 32
Other States1 97 105 98 3,283 3,245 3,209
Total 162 170 162 4,458 4,478 4,388
1
Fewer than three plants reported or individual plant operations could be disclosed.
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

“Over the next five years, industry growth may be spurred onward by technological advancements in the
yogurt production process. Companies will look to new technologies to streamline their operations and
produce a variety of yogurts without overhauling their production systems. For example, Arla Foods
Ingredients, a Sweden-based company, has introduced a variety of proteins that enable yogurt manufacturers
to produce Greek-style yogurt without employing customary filtration systems. This new technique is expected
to enable traditional yogurt manufacturers to compete on the basis of quality and price… many manufacturers
have begun producing protein-enriched blends of yogurt that have similar consistencies and textures as
Greek-style yogurt, without the filtration or whey removal process… as demand for Greek-style yogurt
continues increasing, new filtration systems and thickening agents are likely to appear on the market that
enables low-cost production of Greek-style yogurt…”
- IBISWorld, Yogurt Production in the US, 12/2018

August 2020 Page 53

Leading Spoonable Brands
Danone, Chobani and General Mills are the top three companies with branded dairy yogurt sales.
• Collectively, they accounted for 65% of U.S. MULOC $ sales of spoonable dairy yogurt (as of August
2019) through their Dannon, Chobani and Yoplait brands.
• These brands currently market 396 dairy yogurt products on their top brand websites, 76% which are
spoonable, 15.5% drinkable and 8.5% “squeezable.”
o Of the 302 spoonable dairy yogurts:
 17% contain whole milk, 40% contain lowfat milk and 43% contain nonfat milk
 18.5% contain no added sugars or reduced sugar
o With a 26.6% market share, Danone is the sales leader in spoonable dairy yogurts through its
multiple Dannon brands (Dannon, Dannon Light & Fit, Dannon Activia, Dannon Oikos and
Dannon Danimals).
 Dannon Activia recently added “almondmilk yogurt alternatives” to its product line.
 Danone is also market leader in PBDA “yogurt” and PBDA “milk” with its Silk brand.
o Unlike Dannon (↓5.7%) and #3 brand Yoplait (↓1.5%), #2 brand Chobani was the only top three
brand to record slight sales growth in spoonable yogurt in 2019 (↑0.2%).
 Chobani is also a top 10 player in the PBDA “yogurt” and PBDA “milk” markets.
o Yoplait oui recently added “coconutmilk dairy alternatives” to its product line.
o IRI’s database included 827 Universal Product Codes (UPCs) from these top brands.
• Private label held the #4 market share of spoonable dairy yogurt as of 8/11/2019 but only accounted for
8.8% segment sales (↓0.3% from 2018).
• In terms of new products, between 2009 and 2019, over 100 companies launched 2,090 new spoonable
dairy yogurt products/varieties in the U.S. Of these, 27% were private label.
Brand Parent Current Spoonable Product Portfolio Currently $ Share $ Retail $ Sales
Company Listed on Brand Website* (% with no added as of Sales** Change
sugars) 8/2019** as of YoY**
8/2019
Danone North 128 total varieties: 16 with whole milk; 26 with lowfat 26.6% $1.68 ↓5.7%
America milk; 86 with nonfat milk billion
14 Dannon varieties (29% with no added sugars)
• Plain: 3 varieties – 1 whole; 1 lowfat; 1 nonfat (all
no added sugars)
• Lowfat: 3 lowfat flavors (1 no added sugars)
• Creamy: 1 nonfat flavor
• Fruit on the Bottom: 7 lowfat flavors
53 Dannon Light & Fit varieties (7.5% with no
added sugars)
• Original Regular: 13 nonfat flavors
• Original Greek: 22 nonfat flavors (1 no added
sugars)
• Carb & Sugar Control: 2 nonfat flavors (both no
added sugars)
• Collagen & Antioxidants: 4 nonfat flavors
• Greek Crunch: 8 nonfat mix-in flavors
• Icelandic Style SKYR: 4 nonfat flavors (1 no added
sugars)
27 Activia probiotic varieties (33% with no added
sugars or reduced sugar)
• Greek: 3 nonfat flavors
• Less Sugar & More Good: 4 whole flavors (“at least
40% less sugar than our regular Activia Greek
nonfat yogurt”)
• Lactose Free: 1 lowfat flavor
• 60 Calories: 5 nonfat flavors (all no added sugars)
• Fiber: 2 lowfat flavors
• Fruit: 9 lowfat flavors
• Fruit on the Bottom: 3 lowfat flavors
• Activia also sells four “almondmilk yogurt
alternative” flavors.

August 2020 Page 54

 30 Oikos Greek varieties (47% with no added
sugars)
• Traditional: 13 flavors – 11 whole, 2 nonfat (1 no
added sugars)
• Triple Zero: 13 nonfat flavors (all no added sugars)
• Protein Crunch: 4 nonfat mix-in flavors
4 Danimals varieties (none with no added sugars)
• Nonfat: 4 nonfat flavors
Danone markets additional spoonable dairy yogurt
brands: Two Good, Wallaby Organic and YoCrunch.
Additionally, it sells three PBDA “yogurt” brands: Silk,
So Delicious Dairy Free and Good Plants.
Note: IRI’s database included 339 Dannon brands’
yogurt products with unique UPCs and 2018 retail
sales***
Chobani 85 Greek varieties: 9 with whole milk; 66 with lowfat 19.9% $1.25 ↑0.2%
milk; 10 with nonfat milk (24% with no added sugars billion
or reduced sugar)
• Plain: 3 varieties – 1 whole; 1 lowfat; 1 nonfat (all
no added sugars)
• Complete: 6 lactose free, lowfat flavors (all no
added sugars)
• Less Sugar: 11 lowfat flavors (all with “45% less
sugar than other yogurts")
• Fruit on the Bottom: 13 flavors (6 lowfat, 7 nonfat)
• Blended: 8 flavors (1 whole, 5 lowfat, 2 nonfat)
• Creamy Blended: 7 whole flavors
• Flip: 23 mix-in, lowfat flavors
• Oatmeal on the Bottom: 4 lowfat flavors
• Nut Butter: 5 lowfat flavors
• Gimmies: 5 lowfat mix-in flavors
Chobani also markets PBDA “yogurt” products.
Note: IRI’s database included 190 Chobani yogurt
products with unique UPCs and 2018 retail sales***
General Mills 89 total varieties: 27 with whole milk; 29 with lowfat 18.9% $1.19 ↓1.5%
Inc. milk; 33 with nonfat milk (3% with no added sugars or billion
reduced sugar)
68 Yoplait varieties: (3% with no added sugars or
reduced sugar)
• Original: 8 lowfat flavors
• Light: 13 nonfat flavors
• Just 3: 4 whole flavors
• Lactose Free: 2 lowfat flavors
• Greek: 12 nonfat flavors
• FruitSide: 4 whole flavors
• Whips!: 9 flavors – 4 whole, 5 lowfat
• Starburst: 4 lowfat flavors
• Dunkin’ (Limited Edition): 4 flavors – 2 whole, 2
lowfat
• Kids Cups: 8 lowfat flavors (2 with reduced sugar)
13 oui varieties: (none with no added sugars or
reduced sugar)
• French Style: 13 whole flavors
• oui also sells four “coconut dairy alternatives.”
8 YQ varieties: (12.5% with no added sugars or
reduced sugar)
• Protein: 8 ultra-filtered, nonfat flavors (1 with no
added sugars)
Note: IRI’s database included 298 Yoplait brands’
dairy yogurt products with unique UPCs and 2018
retail sales***
*Brand/company websites, accessed 7/2020
**IRI, U.S. MULOC $ sales for 52 weeks ending 8/11/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding
Costco; Dollar; Military DECA). Cited in Mintel, Yogurt and Yogurt Drinks US, 11/2019
***IRI’s syndicated retail sales database; dataset extract provided by ONFL

August 2020 Page 55

 “Nearly all companies in the spoonable [yogurt] segment saw falling total sales. However, most major players
were able to temper losses by operating smaller, niche brands that align closely with emerging diet trends.
Groupe Danone’s flagship Dannon brands’ losses were partially offset by the continued success of its non-
dairy brand, So Delicious, as well as the launch of a new Greek-style yogurt, Two Good, which uses a slow
filtering method to reduce sugar content…”
– Mintel, Yogurt and Yogurt Drinks US, 11/2019

Leading Drinkable Brands

Danone, LALA and Chobani are the top three companies with branded dairy yogurt sales.
• Collectively, they accounted for 62% of U.S. MULOC $ sales of drinkable dairy yogurt (as of August 2019)
through their Dannon, LALA and Yoplait brands.
o These brands currently market 52 dairy yogurt drinks on their brand websites.
o 85% contain lowfat milk, 15% contain nonfat milk and 8% have no added sugar.
• Private label held the lowest market share of drinkable dairy yogurt as of 8/11/2019, only accounting for
$6.2 million in segment sales (↓7.5% from 2018).
• In terms of new products, between 2009 and 2019, 12 companies launched 86 new drinkable dairy yogurt
products/varieties in the U.S. Of these, only 1 product was private label.
Parent Current Spoonable Product Portfolio Currently $ Share $ Retail $ Sales
Brand Company Listed on Brand Website* (% with no added as of Sales** Change
sugars) 8/2019** as of YoY**
8/2019
Danone North 33 total varieties: 25 with lowfat milk; 8 with nonfat 42.0% $380.7 ↑2.1%
America milk million
4 Dannon Light & Fit varieties (all with no added
sugars)
• Protein Smoothies: 4 nonfat flavors
9 Activia probiotic varieties (none with no added
sugars or reduced sugar)
• Probiotic Drinks: 5 reduced fat flavors
• Dailies Probiotic Drinks: 4 reduced fat flavors
• Activia also sells three Probiotic Smoothies with
“fruit, veggies and seeds”

4 Oikos varieties (none with no added sugars)

• Pro Fuel “Caffeinated & Cultured Dairy Drinks”: 4
flavors with nonfat milk
13 Danimals varieties (none with no added sugars)
• Organic Smoothies: 2 lowfat flavors
• Smoothies: 8 lowfat flavors
• Wild Smoothies: 3 lowfat flavors

3 DanActive varieties (none with no added sugars)

• Probiotic Dailies: 3 reduced fat flavors
Danone also markets spoonable dairy yogurt and
PBDA “yogurt.”
Lala U.S. 14 total varieties: all with lowfat milk 11.6% $105.2 ↓0.6%
• Yogurt Smoothies: 11 lowfat flavors million
• Frusion Yogurt Smoothie: 1 lowfat flavor
• Probiotic Yogurt Smoothies: 2 lowfat flavors

Chobani 5 total Greek varieties: all with lowfat milk 7.9% $71.6 ↑2.3%
• Blended Drinks: 5 lowfat flavors million
• Chobani also sells four lactose free shakes and
PBDA coconut drinks.

“Yogurt drinks, including kefir, are taking share from the spoonable yogurt segment... However, while growing, the
year-over-year increases of drinkable yogurt sales have started to slow.”
- Mintel, Yogurt and Yogurt Drinks US, 11/2019

August 2020 Page 56

Consumer Demographics, Behavior & Perceptions

• In a September 2019 survey, 1,500 U.S. adults who had purchased dairy yogurt in the past three months
chose Greek more than any other style, and flavored varieties more than any other.
o Kefir was the least purchased style, and full-fat was the least purchased variety.
o Among these respondents, 67% said they were purchasing the same amount or less of dairy
yogurt compared to last year.

August 2020 Page 57

Timeline of Selected Product Innovations

• 1942: Dannon Milk Products was established in New York.

• 1947: Dannon added a layer of strawberry was added to the bottom of its yogurt.
• 1965: Two French dairy cooperatives two co-operatives, Yola and Coplait, merged, becoming Yoplait.
• 1971: Yoplait launched its products in the U.S., and General Mills began marketing them in 1977.
• Mid-1980s: Dannon added several yogurt lines – light, blended and varieties for children
• 1998: Yoplait launched Go-Gurt yogurt tubes; Fage USA launched the first Greek-style yogurt in the U.S.
• 2003: Dannon launched Activia brand probiotic yogurt in the U.S.
• 2005: Chobani was established. The company launched its line of Greek yogurt in 2007.
• 2010: Dannon launched a line of Greek yogurt. It was rebranded as Dannon Oikos in 2011.
• 2013: General Mills introduced blended Greek yogurt; Danone introduced Silk soy-based PBDA “yogurt.”
• 2018: General Mills launched Yoplait Oui French-style yogurt and YQ lower sugar Greek yogurt.
• 2019: Dannon launched Two Good Greek lowfat yogurt with 2 grams of total sugar; Siggi’s, a brand of
lower sugar dairy yogurt, added a line of PBDA “yogurt,” which is made with a coconut, macadamia and
pea protein blend; Chobani introduced Chobani Oat “yogurt” and Chobani Greek yogurt with nut butters,
which reportedly have “more protein and less sugar than many other yogurts.”

August 2020 Page 58

PBDA “Yogurt” Market

Retail Sales & Household Penetration

• PBDA “yogurt” sales reached $283 million in 2019 – ↑31% from 2018 and ↑95% from 2017.
o Approximately 75% of total sales were in IRI’s conventional multi outlet (MULO) channel,
compared to nearly 25% in SPINS’ natural and specialty gourmet channels.
o Coconut and almond “yogurts” were the top-selling plant bases in 2019:
 Coconut “yogurt” recorded $127 million in sales (↑42% from 2018) and a 45% category
share, while almond “yogurt” achieved $87 million in sales (↑39% from 2018) and a 31%
category share.
o Dollar sales of coconut, almond and “other” plant bases ↑ from 2018, while soy “yogurt” slightly ↓.
o Coconut and almond were the fastest-growing plant bases.
• PBDA “yogurt” sales grew in each of IRI’s eight U.S. regions in 2019, with four regions accounting for
67% of total refrigerated PBDA “yogurt” sales: North East (25%), South East (15%), Great Lakes (14%)
and West (13%).
o Almost 9% of households bought PBDA “yogurt” in the past six months (↑2.5% y-o-y), and nearly
50% purchased at least twice.

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

August 2020 Page 59

 PBDA "Yogurt": $ Sales by Retail Channel 2019
(% of Total Yogurt Sales)
$250 $214m (75.5%)
$200

$150

$100
$56m (20%)
$50 $13m (4.5%)
$0
MULO Specialty Gourmet Natural

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

Plant-Based “Yogurt”: Household Penetration and Single vs. Multiple Purchasers

Source: IRI, National Consumer Panel Survey, January 2019. Cited in IRI, “Understanding the Plant-Based Consumer: A Deeper Look Into
Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

“Non-dairy yogurts provide a much-needed opportunity for growth in the market. Though total sales are
declining, the percentage of consumers buying yogurt has increased between 2018 and 2019 with the launch
of mass-market non-dairy yogurt lines. Brands may be able to recover some of the sales lost by major
segments as dairy-free products become more accessible…”
- Mintel, Yogurt and Yogurt Drinks US, 11/2019

August 2020 Page 60

Production
• Most manufacturers do not publicly disclose their manufacturing processes on their websites.
• Three recently-published non-dairy yogurt patent applications:
o “Manufacturing of plant-based yogurt,” US20190274324A1, Califia Farms
o “Non-dairy yogurt product prepared from coconut water,” US20170347676A1, Abzz Snacks LLC
o “Plant-based yogurt product and method of making same,” US20180271126A1, Novare Food
Products LLC

Source: Novare Food Products LLC patent application

• In a recently-published article titled “A Novel Approach to Structure Plant-Based Yogurts Using High
Pressure Processing,” researchers from Singapore stated:
o “Current plant-based yogurts are made by the fermentation of plant-based milks. Although this
imparts fermented flavors and probiotic cultures, the process is relatively longer and often leads
to textural issues. The protein content of these plant-based yogurts is also lower than their dairy
counterparts. To overcome these challenges, this paper explores the high pressure processing
(HPP) of plant protein ingredients as an alternative structuring strategy for plant-based yogurts…”

Source: Sim, S. Y. J. et al., Foods, 2020

August 2020 Page 61

Leading Brands
The top 10 PBDA “yogurt” brands (as of October 2019) currently market 117 products – 89% of which are
spoonable varieties – on their brand websites.
• As is the case with PBDA “milk,” Danone leads the PBDA “yogurt” market in retail sales.
o According to IRI, two of Danone’s brands – Silk and So Delicious Dairy Free – collectively
accounted for 74% of U.S. MULOC $ sales as of 10/5/2019, and the top 10 brands together
generated 97% of $ category sales.
o Danone also markets PBDA “yogurt” products through its Good Plants brand (#8 in the top 10)
and through four dairy-free, probiotic varieties in its Activia brand.
o In addition to its PBDA “yogurt” products, Danone manufactures dairy yogurt under multiple
brands, including Dannon, Activia, DanActive, Light & Fit and Oikos.
• Three of the top brands – Chobani, Good Plants and Blue Diamond Almond Breeze – launched in 2019.
• Califia Farms’ drinkable yogurts recorded the highest sales growth in 2019, ↑324.9% from 2018.
• Unlike in the PBDA “milk” category, private label sales of PBDA “yogurt” did not make IRI’s top 10 list.
o According to the Good Food Institute’s 2019 Good Food Retail Report, plant-based yogurt “is also
a large white space [in addition to plant-based cheese]. Many stores stock 40–60 plant-based
branded products, and next to none offer private-label plant-based yogurt… This category
represents an enormous opportunity for private-label launches.”
• Only four of the top 10 PBDA “yogurt” brands list an unsweetened product on their websites, and they
market much fewer unsweetened varieties than the top PBDA “milk” brands.
• In terms of new products, between 2009 and 2019, approximately 35 companies launched 155 new
PBDA spoonable “yogurt” products/varieties in the U.S.
Brand Parent Current Product Portfolio Currently Listed on $ Share $ Retail Change
Company Brand Website* (% unsweetened or reduced sugar as of Sales** YoY**
varieties) 10/2019** as of
10/2019
Danone North 21 varieties (all spoonable; 5% unsweetened) 41.5% $83.6 ↑21.0%
America • “Almondmilk Dairy-free Yogurt Alternative”: 7 million
flavors + 4 mix-in flavors (10 sweetened; 1
unsweetened)
• “Soymilk Dairy-free Yogurt Alternative”: 6 flavors
(all sweetened)
• “Oatmilkgurt Oatmilk Dairy-free Yogurt Alternative”:
4 flavors (all sweetened)
Note: IRI’s database included 19 Silk PBMA “yogurt”
products with unique UPCs and 2018 retail sales***
Danone North 19 varieties (all spoonable; 11% unsweetened) 32.3% $65.0 ↑31.2%
America • “Oatmilk Yogurt Alternative”: 4 flavors (all million
sweetened)
• “Coconutmilk Yogurt Alternative”: 11 flavors + 4
mix-in flavors (13 sweetened; 2 unsweetened)
Note: IRI’s database included 21 So Delicious PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***
Lyrical Foods 21 varieties (19 spoonable; 2 tubes; 14% 6.6% $13.3 ↑26.9%
unsweetened) million
• “Almond Milk Yogurt”: 8 flavors (7 sweetened; 1
unsweetened)
• “Almond Milk Greek Style Almond Yogurt”: 5 flavors
(3 sweetened; 2 unsweetened)
• “Kids Almond Milk Yogurt Tube”: 2 flavors (both
sweetened)
• “Blissful Coconut Milk Yogurt”: 6 flavors (all
sweetened)
Note: IRI’s database included 19 Kite Hill PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***

August 2020 Page 62

 Chobani Global 15 varieties (12 spoonable; 3 drinkable; none 4.9% $9.9 NEW
Holdings, Inc. unsweetened) million
• “Coconut Non-Dairy Blend”: 5 flavors (all
sweetened); 3 drink flavors (all sweetened)
• “Plant-Based Oat Blend”: 4 flavors (all sweetened);
3 mix-in flavors (all sweetened)
Note: IRI’s database included 11 Chobani PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***
Califia Farms 3 varieties (all drinkable; none unsweetened) 4.3% $8.6 ↑324.9
• “Probiotic Dairy Free Yogurt Cultured Nutmilk million
Drink”: 3 flavors (all sweetened)
Note: IRI’s database included no Califia Farms PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***
Forager Project, 13 varieties (8 spoonable; 5 drinkable; 23% 3.3% $6.6 ↑22.7%
LLC (Note: unsweetened) million
Danone • “Organic Dairy-free Cashewmilk Yogurt / Probiotic
Manifesto Plant-based Yogurt Alternative”: 6 flavors (5
Ventures has a
sweetened; 1 unsweetened)
minority stake.)
• “Organic Dairy-free Probiotic Cashewmilk Yogurt /
Drinkable Plant-based Yogurt Alternative”: 5 flavors
(4 sweetened; 1 unsweetened)
• “Organic Dairy-free Plant-based Protein Yogurt /
Coconut & Cashew Yogurt Alternative”: 2 flavors (1
sweetened; 1 unsweetened)
Note: IRI’s database included 14 Forager PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***
Danone North 4 varieties (all spoonable; none unsweetened) 1.5% $3.0 NEW
America • “Almondmilk Probiotic Yogurt Alternative”: 4 flavors million
(all sweetened); “40% fewer calories and 70% less
sugar than most almondmilk yogurt alternatives”
Note: IRI’s database included 5 Good Plants PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***
Otsuka 10 varieties (all spoonable; none unsweetened) 1.1% $2.3 ↓9.4%
Holdings Co., • “Coconut Yogurt Alternative”: 6 flavors + 4 mix-in million
Ltd. flavors (all sweetened); “blueberry, strawberry,
black cherry and peach include pieces of real fruit,
and have 50 percent less sugar per serving than
the average dairy-free brand”
Note: IRI’s database included 11 Daiya PBMA
“yogurt” products with unique UPCs and 2018 retail
sales***
Blue Diamond 7 varieties (all spoonable; none unsweetened) 0.8% $1.7 NEW
Growers • “Almondmilk Yogurt Alternative”: 7 flavors (all million
sweetened)
Note: IRI’s database included no Blue Diamond
Almond Breeze PBMA “yogurt” products with unique
UPCs and 2018 retail sales***
Stonyfield Farm 4 varieties (all spoonable; none unsweetened) 0.8% $1.6 ↓16.5%
Inc. (Note: • Dairy Free Soy Yogurt: 4 flavors (all sweetened) million
French owner Note: IRI’s database included 4 Stonyfield Organic
Lactalis
PBMA “yogurt” products with unique UPCs and 2018
acquired retail sales***
Stonyfield
from Groupe
Danone in
2017.)
*Brand/company websites, accessed 7/2020
**IRI, U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding
Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty gourmet channels. Cited by IRI, “The Surge of Plant-
Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/2019
***IRI’s syndicated retail sales database; dataset extract provided by ONFL

August 2020 Page 63

 Source: Mintel GNPD Analysis, 8/2020

Names/Descriptions on Leading Brands’ Product Labels

• Each of the top 10 PBDA “yogurt” brands – except Chobani – includes the term “yogurt” in at least one of
its product name(s) and/or label(s).

Name/Label Includes the Term Leading Brand(s) with Examples from Front Product Labels
“Milk” and/or “Yogurt” Applicable Product(s)
One or more words: plant base combined Silk Oat Yeah
with “milk” and/or “yogurt”, e.g., Forager Project
oatmilkgurt, cashewmilk yogurt

Name/Label Includes the Term Leading Brand(s) with Examples from Front Product Labels
“Yogurt” AND Qualifier(s) Applicable Product(s)
Multiple words: plant base, “yogurt” and Silk
qualifier(s) e.g. almondmilk yogurt So Delicious Dairy Free
alternative, dairy-free yogurt alternative Califia Farms
made with soy, oatmilk yogurt alternative, Forager Project
coconutmilk yogurt alternative, dairy free Good Plants
yogurt cultured nutmilk drink, probiotic Daiya
plant-based yogurt alternative, coconut & Blue Diamond Almond Breeze
cashew yogurt alternative, plant-based Stonyfield Organic
protein yogurt, almondmilk probiotic
yogurt alternative, yogurt alternative, dairy
free soy yogurt

August 2020 Page 64

 Multiple words: plant base, “milk,” “yogurt” Kite Hill
and qualifier(s) e.g. almond milk yogurt
dairy free, coconut milk yogurt dairy free

Name/Label Excludes the Term Leading Brand(s) with Examples from Front Product Labels
“Yogurt” Applicable Product(s)
Plant-based oat blend (no dairy), Coconut Chobani
non-dairy blend

Sources: Brand/company websites, accessed 7/2020; Information Resources Inc. (IRI), U.S. MULOC $ sales for 52 weeks ending 10/6/2019
in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience Stores.
Excludes natural and specialty gourmet channels. Cited by IRI, “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the
Growth of Plant-Based Foods,” 11/19/2019; GFI, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020

• In May 2020, the Plant Based Foods Association (PBFA) released Voluntary Standards for the Labeling of
Plant-based Yogurt in the United States “to promote consistency in labeling across the category.” Adoption
of the voluntary standards was recommended within one year. Labeling standards include:
o “Qualifiers: The statement of identity should clearly indicate that the product is plant-based by the
use of one or more following phrases, or a comparable qualifier:
 Plant-Based Yogurt
 Dairy-Free Yogurt
 Non-Dairy Yogurt
 Characterizing Ingredient) Yogurt (e.g. Soymilk Yogurt)
o Identification of Plant-Based Characterizing Ingredient: All plant-based yogurts should indicate the
characterizing ingredient(s) used to produce the yogurt on the principal display panel or the
informational panel on the product package by using at least one of the following options:
 Placing the name of the characterizing ingredient(s) in front of the word yogurt…
o Identifying that the product is ‘made with’ or ‘made from’, followed by the characterizing ingredient,
such as ‘made with soy’, ‘made from coconut’, ‘made from almonds’; or by using the common
plant-based milk names such as ‘soymilk’, ‘almondmilk’, or ‘cashewmilk’. If the product is made
from more than one characterizing ingredient, this may be indicated through hyphenation (e.g.,
‘almond-cashew milk’).
o The product may be also labeled as ‘plant-based yogurt’ (with or without the hyphen) as long as
the characterizing ingredient(s) is (are) also clearly stated on the principal display panel or the
information panel.
o All plant-based yogurts should clearly be labeled as ‘dairy-free’ (preferable) or ‘non-dairy’ in a
prominent position on the principle display panel.”

August 2020 Page 65

Consumer Demographics, Behavior & Perceptions
• Identical to PBDA “milk” buyers, IRI’s January 2019 survey of U.S. consumers found that the top
purchasers of PBDA “yogurt” (determined by cohort’s dollar index* ≥100) were:
o Millennial and Generation X households with incomes ≥$50,000
o Households with 3+ people and 1+ child
o Hispanic ethnicity

*Dollar index = (% dollars / % households) x 100

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 11/3/2019 in Multi Outlet Channels plus Convenience Stores. Excludes natural and
specialty gourmet channels. Cited by IRI, “Understanding the Plant-Based Consumer: A Deeper Look Into Plant-Based Purchase Trends,
Demographics, Perceptions and Usage,” 1/16/2020

• A 2019 survey found that almond and coconut were the top two purchased plant bases, and more
respondents purchased flavored varieties than plain.
o Mintel notes that “while brands were slower to capitalize on oat milk as a beverage, it has already
been used as a base in numerous yogurt launches and will likely continue to grow in popularity.”

Source: Mintel, Yogurt and Yogurt Drinks US, 11/2019

August 2020 Page 66

• Among the 34% of respondents who reported they were buying more non-dairy yogurt than the previous
year, the top two reasons cited were “I like the taste” and “It makes me feel better”:

Source: Mintel, Yogurt and Yogurt Drinks US, 11/2019

• A 2017 Comax Flavors survey of 250 U.S. adults also found that the top two purchase drivers for PBDA
yogurt were health benefits and flavor:

Non-Dairy Yogurt: Top Five Purchase Drivers

50%
40%
45% 42%
30% 36%
20% 28% 26%
10%
0%
Health Benefits Flavor All Natural Ingredient Price
Source

Source: Comax Flavors, 2017

“The non-dairy yogurt market is still developing. Penetration is low, with only 40% of consumers having
made a purchase in the past three months, compared to the 75% that purchased dairy yogurt…

Non-dairy products are perceived to be healthful, though they fall short of consumers’ high expectations for
nutritional values; instead non-dairy yogurts depend on natural, organic, and free-from claims. Dairy
yogurts, on the other hand, boast higher protein content and digestive health benefits. Reformulating and
repositioning non-dairy yogurts to include these added-value benefits could encourage active consumers to
increase their purchases…”
- Mintel, Yogurt and Yogurt Drinks US, 11/2019

August 2020 Page 67

Timeline of Selected Milestones/Product Innovations

• 1977: Swan Foods/The Soybeanery developed and launched the first soy yogurt with fermented soymilk,
coining the term “Soyogurt.”
• 1985: Tomsun Food International created Jofu, a non-fermented product made from silken tofu.
• 1991: White Wave introduced “Dairyless” line of non-fermented soy yogurts.
• 2001: Stonyfield Farm launched O’Soy cultured organic soy yogurt.
• 2008: Turtle Mountain, part of White Wave, launched So Delicious Dairy Free soy yogurt.
• 2012: Turtle Mountain launched So Delicious Dairy Free Greek style coconut yogurt; Hain Celestial
introduced Almond Dream non-dairy yogurt
• 2013: WhiteWave Foods launched Silk soy yogurt.
• 2015: Kite Hill launched its artisan almond milk yogurt; Hain Celestial launched Coconut Dream non-dairy
yogurt.

• 2016: Daiya Foods introduced dairy- and soy-free Greek style yogurt; Forager Project launched organic
dairy-free yogurt.
• 2017: Good Karma Foods launched dairy-free yogurt.
• 2018: WhiteWave Foods launched Vega Protein yogurt alternatives.
• 2019: Danone’s Dannon launched Good Plants almondmilk probiotic yogurt alternatives, Silk introduced
Oat Yeah “oatmilk” yogurt alternatives and So Delicious Dairy Free introduced a line of Oatmilk Yogurt
Alternatives; Blue Diamond added PBDA “yogurt” to its Almond Breeze product line; Daiya Foods
launched dairy-free yogurt mix-ins; Chobani launched coconut-based yogurt.
• 2020: Yoplait launched Oui coconut dairy alternative yogurt; Kite Hill introduced coconut milk yogurt;
Chobani introduced oat blend PBDA yogurt; Danone’s So Delicious Dairy Free introduced coconut milk
yogurt alternative mix-ins, and Activia launched almondmilk probiotic yogurt alternative.

August 2020 Page 68

 Dairy Cheese and PBDA “Cheese”
Market Comparisons

Sales

• According to SPINS, the plant-based share of the total cheese market was 1% in 2019.
• Plant-based “cheese” sales ↑51% 2017-2019, while dairy cheese sales only ↑2% 2017-2019.
• SPINS reported that the plant-based “cheese” share of total cheese sales varied by channel:

Plant-Based "Cheese" Share of Total Cheese Sales

in Three Retail Channels 2019:
MULO, Specialty Gourmet and Natural Retail

Natural*** 17%

Specialty Gourmet** 2%

MULO* 1%

0% 5% 10% 15% 20%

*Conventional Multi Outlet (MULO) channel covers >104,000 grocery, drug, mass, dollar, military, and club retail locations (e.g. Publix,
Walmart, Kroger, Target)
**Specialty Gourmet channel covers “full-format supermarkets” with at least $2 million in annual sales and “SPINS-defined specialty items”
comprising at least 25% of overall volume. Retailers are also defined as “high-end” and “experiential.” (e.g. Gelson’s, Heinen’s, Busch’s)
***Natural channel covers “full-format” stores with at least $2 million in annual sales and at least 50% of sales from
natural/organic products (e.g. Sprouts, Erewhon, Earth Fare; exclude Whole Foods and Trader Joe’s)
Source: SPINSscan Natural and Specialty Gourmet (proprietary) plus SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited by The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

In its 2020 Key Players publication, Cheese Market News noted that “These [49] companies are innovating and
adapting to meet the needs and demands of consumers – many are adding plant-based alternatives into their
product offerings, experimenting with new flavors and offering more variety in on-the-go dairy product options.”
• In early 2020, Schuman Cheese “launched a plant-based line, Vevan Foods… the line was developed
by artisan dairy cheesemakers. ‘People incorporate plant-based options into their diet for a wide range
of reasons, but that doesn’t mean they want to sacrifice the ability to enjoy their favorite foods,’ says
Keith Schuman, business unit lead for Vevan Foods. ‘Market data proves that plant-based eaters miss
familiar flavors like cheese, and that’s what Vevan delivers.’ Initially being offered to foodservice and
ingredients customers, the line spans three flavors, all offered in shred, slice and block formats – Vevan
Ched, Vevan Mozza and Vevan P’Jac. The line was launched for retail customers in mid-May.”
• In 2019, Whitehall Specialties’ new CEO established “a new division, NewFields plant-based cheese,
to focus exclusively on good-tasting, plant-based cheese alternative products both for direct sale and
as a co-manufacturing partner with selected industry players… these alternative cheese products are
currently available in a Cheddar flavor and will soon be available in a range of other flavors such as
Mozzarella, Blue cheese, Pepper Jack and Parmesan. The company is making products in block, shred
and chunk formats for both retail and foodservice… the company looks to launch a broad plant-based
product range directly and in support of its co-manufacturing and private label partners… NewFields
plant based interest has grown significantly in line with consumer trends towards plant-based diets…”
• Winona Foods “is expanding its footprint in plant-based cheese substitutes… ‘More of the cream
cheese-style spreads, dips and quesos are now available in plant-based.’…”

August 2020 Page 69

Consumer Purchase Behaviors, Perceptions and Opinions
• Findings from an August 2019 Lightspeed/Mintel online survey of 2,000 U.S. adults include:
o 12% said they had eaten dairy-free cheese in the past three months.
 Four times as many respondents ages 18-44 (20%) had eaten dairy-free cheese than
those 45+ (5%).
 Dairy-free cheese “has a small base… but they are a dedicated base: seven in 10
consume non-dairy cheese at least once a week...”
 Overall, 25% agreed that non-dairy cheese “is healthier than dairy-based cheese” (38%
ages 18-44) compared to 28% who disagreed.
 The top three factors when purchasing dairy-free cheese were organic, high-protein
options and brand.
o 70% of respondents had eaten natural cheese, 56% consumed cream cheese and 55%
consumed processed cheese in the past three months.
 35% agreed that they “worry about the impact of dairy consumption” on their personal
health compared to 39% who disagreed.
 The top three factors when purchasing natural cheese were brand, bolder flavors and no
additives/preservatives.

August 2020 Page 70

Source: Mintel, Cheese US, 10/2019

Source: Mintel, Cheese US, 10/2019

August 2020 Page 71

 Source: Mintel, Cheese US, 10/2019

“Non-dairy cheese posts largest gaps in consumer perception against its dairy equivalent, compared to other
dairy subcategories… Vegan/dairy-free cheese falls far short of dairy cheese on the two highest priority
attributes: tasty and good value. Dairy-free cheese taste likely continues to suffer from early generation
products that compromised taste for the sake of a passable alternative.”
- Jane Hurh, Mintel, 4/2019

August 2020 Page 72

• Among the findings of a December 2018 online survey of 450 U.S. adults – conducted by Ravel, LLC and
commissioned by the Wisconsin Cheese Makers Association, Edge Dairy Farmer Cooperative and Dairy
Farmers of Wisconsin:
o “About one-third of consumers indicate that the plant-based food that mimics mozzarella slices
has protein (34%) and calcium (37%), [and a] significantly greater percentage of consumers
indicate that they don’t know which nutrients are in the plant-based foods, perhaps indicating that
the front labeling does not clearly reveal the product nutrients...”

Source: Ravel, 1/2019

August 2020 Page 73

Nutritional Composition
• A review of nutrient values* in selected dairy cheeses and a sample of 20 PBDA “cheeses” from leading brands** revealed that dairy and plant-
based varieties contain similar calorie ranges and no Vitamin D.
o Overall, dairy varieties tend to contain higher protein, calcium and Vitamin A levels than non-dairy varieties.
o The sampled dairy and non-dairy varieties contain a similar range of sodium levels, except for cashew “cheese,” which contains less.
Product Calories Protein Calcium Magnesium Phosphorus Potassium Riboflavin Vitamin Vitamin A Vitamin D Sodium
(kcal) (g) (mg; % of (mg; % of (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg (mcg; % (mg; % of
new DV) new DV) new DV) new DV) new DV) % of new RAE; of new new DV)
DV) % of new DV)
DV)
Dairy cheese: ranges for 6 45-110 6-9 180-250; NS NS 0; NS NS 60-100; 0; 180-280;
products from leading brands** 14-19% 0% 4-11% 0% 8-12%
Kraft and Sargento
Cashew-based “cheese”: 70-110 1-4 0-10; NS NS 30-90; NS NS NS 0; 75-120;
ranges for 4 sample products 0% 0-2% 0% 3-5%
Almond-based “cheese”: 70 2-6 28; NS NS 72; NS NS NS 0; 200-210;
ranges for 2 sample products 0-Claims 1.5% 0% 9%
(1 contains casein) 20%
Soy-based “cheese”: 70-90 1-5 9; NS NS 41; NS NS NS 0; 150-290;
ranges for 3 sample products 0-Claims 1% 0% 7-13%
(1 contains casein) 20%
Rice-based “cheese”: 60-70 5-6 Claims 20- NS NS NS NS NS NS NS 190-210;
ranges for 2 sample products 31% 8-9%
(both contain casein)
“Cheese” with multiple 60-90 0-1 0-Claims 0 NS 0-27; NS 0.7; 0; 0; 95-280;
plant-based ingredients: 30% 0% 29% 0% 0% 4-12%
ranges for 9 sample products

*per serving; Calories, Protein, Calcium (new DV 1300 mg), Magnesium (new DV 420 mg), Phosphorus (new 1250 mg), Potassium (new 4700 mg), Riboflavin (new DV 1.3 mg), Vitamin B12
(new DV 2.4 mcg), Vitamin A (new DV 900 mcg RAE), Vitamin D (new DV 20 mcg) and Sodium (new DV 2300 mg). Sources include Mintel’s Global New Products Database; brand/company
websites accessed 7/2020
**IRI, U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience
Stores. Excludes natural and specialty gourmet channels. Cited by IRI in “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/2019; The
GFI, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020

Additional Notes:
• New FDA Daily Values are rounded percentages for adults and children ≥ 4 years.
• NS = not stated on nutrition label. The U.S. FDA’s new Nutrition Facts Label (NFL) does not require reporting magnesium, phosphorus, riboflavin or vitamins A or B12 levels

August 2020 Page 74

Dairy Cheese Market
Sales & Projections
• According to SPINS data, dairy cheese retail sales in 2019 reached $19.7 billion, ↑1.4% from 2018.
o Dairy cheese accounted for 99% of total category sales.
o Natural cheese was by far the largest product segment – earning over 70% of sales – and is
projected to continue dominating the category through 2024.
o Within natural cheese, shredded was the top-selling product type, followed by chunks and slices.
• Dairy Foods’ 2019 State of the Industry Report noted that “expanded usage of cheese within foodservice
has been one of the growth drivers.”
• IBISWorld notes the top two cheese flavors are Italian (43.9% of sales) and American (38.9% of sales).
o IBISWorld projects total cheese sales 2019-2024 will grow faster than 2014-2019. “Per capita
disposable income is expected to keep growing, continuing to motivate consumers to eat out at
restaurants and increasing demand from the food service sector…”

Total Cheese Retail Sales 2019:

Breakout by Product Segment
Cream cheese/cream cheese Cottage Cheese
spreads 4.9%
8.2%

Processed cheese
15.4%
Natural cheese
71.5%

Source: IRI Infoscan data cited in Mintel, Cheese US, 10/2019

Total Natural Cheese Retail Sales 2019 ($ million):

Breakout by Product Form
$6,000,000
$5,000,000
$4,000,000
$3,000,000
$2,000,000
$1,000,000
$-

Source: IRI, U.S. MULOC $ sales for 52 weeks ending 8/11/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass;
Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience Stores. Excludes natural and specialty
gourmet channels. Cited in Dairy Foods, 11/2019

August 2020 Page 75

 Source: IBISWorld, Cheese Industry Production in the US, 7/2019

Total Cheese Retail Sales ($ million)

2014-2024
$25,000

$24,000

$23,000

$22,000
2014 2015 2016 2017 2018 2019e 2020f 2021f 2022f 2023f 2024f

Source: IRI Infoscan data cited in Mintel, Cheese US, 10/2019

Total Cheese Retail Sales by Product Segment ($ million)

2014-2024
Natural cheese Processed cheese Cream cheese/cream cheese spreads Cottage cheese

$20,000
$18,000
$16,000
$14,000
$12,000
$10,000
$8,000
$6,000
$4,000
$2,000
$-
2014 2015 2016 2017 2018 2019e 2020f 2021f 2022f 2023f 2024f
Source: IRI Infoscan data cited in Mintel, Cheese US, 10/2019

Mintel’s evaluation of new product launches “shows a distinct interest in white cheddar cheeses. As a group,
these launches have considerably outperformed cheese launches overall… Furthermore, the emergence of
white cheddar options appears to be growing the category as a whole. Of the consumers who would likely or
definitely buy white cheddar cheese, 63% would make it an additional purchase to other cheeses…”
- Mintel, Cheese US, 10/2019

August 2020 Page 76

Production
According to data from the U.S. Department of Agriculture, there were 553 cheese production plants in the
country in 2018.
• Kraft Heinz – the #1 manufacturer of branded dairy cheese –– had nine U.S. cheese production plants,
and Sargento – the #2 branded manufacturer – had three, according to Cheese Market News’ 2020 Key
Players publication.
• Total cheese production, excluding cottage cheese, in 2018 was 13 billion pounds, ↑6.9% from 2016
• The U.S. manufactures more cheese than any other country
• Top cheese product types:
o Italian varieties (42.7% of total cheese; ↑4.8% from 2016), including mozzarella (78.3% of Italian
types; ↑5.7% from 2016)
o American varieties (40.3% of total cheese; ↑10.2% from 2016), including cheddar (72.4% of
American types; ↑10.7% from 2016).
• Top three cheese-producing states:
o Wisconsin (26.3% of total cheese; 26.2% of mozzarella cheese; 18.8% of cheddar cheese)
o California (19.5% of total cheese; 34.6% of mozzarella cheese; 8.8% of cheddar cheese)
o Idaho (7.6% of total cheese; 6.5% of mozzarella cheese; 12.7% of cheddar cheese)

Total Cheese (excluding cottage cheese): Production by Type (2016-2018)

Type Number of Number of Number of Production Production 2017 Production 2018
Plants 2016 Plants 2017 Plants 2018 2016 (million (million pounds) (million pounds)
pounds)
American 245 261 266 4,769 5,072 5,254
- includes - Cheddar: - Cheddar: - Cheddar: - Cheddar: - Cheddar: 3,722 - Cheddar: 3,803
Cheddar, 230 240 244 3,434 - Other - Other
Colby, washed - Other: 149 - Other: 160 - Other: 161 - Other American: 1,351 American: 1,451
curd, stirred American:
curd, Monterey 1,334
and Jack
Blue and 47 54 55 91 91 95
Gorgonzola
Brick 19 23 17 3 2 2
Cream and 33 36 38 909 918 915
Neufchatel
Feta 47 48 46 127 123 130
Gouda 68 79 84 59 65 65
Hispanic 61 61 61 265 287 312
Italian 203 209 209 5,304 5,395 5,557
- includes - Mozzarella: - Mozzarella: - Mozzarella: - Mozzarella: - Mozzarella: - Mozzarella:
Mozzarella, 128 134 133 4,118 4,167 4,351
Parmesan, - Parmesan: - Parmesan: - Parmesan: - Parmesan: - Parmesan: 451 - Parmesan: 424
Provolone, 45 52 49 407 - Provolone: 394 - Provolone: 398
Ricotta, - Provolone: - Provolone: - Provolone: - Provolone: - Ricotta: 246 - Ricotta: 249
Romano and 39 39 40 402 - Romano: 58 - Romano: 58
other Italian - Ricotta: 57 - Ricotta: 58 - Ricotta: 56 - Ricotta: 252 - Other Italian: 79 - Other Italian: 76
types - Romano: 26 - Romano: 27 - Romano: 26 - Romano: 52
- Other - Other Italian: - Other - Other Italian:
Italian: 50 56 Italian: 56 73
Muenster 38 40 44 181 189 191
Swiss 59 63 63 312 317 332
All other 221 215 218 162 181 172
(excluding
cottage
cheese)
Total 553 553 553 12,182 12,640 13,025
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

August 2020 Page 77

 Total Cheese (excluding cottage cheese): Production by State (2016-2018)
State Number of Number of Number Production Production Production
Plants Plants 2017 of Plants 2016 (million 2017 (million 2018 (million
2016 2018 pounds) pounds) pounds)
California 59 59 61 2,515 2,513 2,543
Idaho 9 9 9 955 959 991
Illinois 11 11 11 82 82 82
Iowa 10 10 11 254 257 296
Minnesota 11 11 11 657 713 741
New Jersey 14 16 15 58 58 59
New Mexico 4 4 4 776 767 896
New York 63 64 62 826 829 802
Ohio 20 19 19 215 222 239
Oregon 8 8 8 201 207 210
Pennsylvania 41 44 46 404 412 434
South Dakota 7 7 7 276 282 293
Vermont 34 32 38 132 143 147
Wisconsin 128 120 118 3,248 3,377 3,423
Other States1 134 139 133 1,582 1,820 1,867
Total 553 553 553 12,182 12,640 13,025

Cheddar Cheese: Production by State (2016-2018)

State Number of Number of Number of Production Production Production
Plants Plants Plants 2016 (million 2017 (million 2018 (million
2016 2017 2018 lbs) lbs) lbs)
California 18 17 18 344 356 335
Idaho 5 5 5 480 483 484
Iowa 7 7 8 96 94 114
Minnesota 8 8 8 493 561 589
Oregon 6 6 6 174 173 172
Vermont 10 10 12 92 101 101
Wisconsin 66 69 69 661 704 715
Other States1 110 118 118 1,094 1,250 1,293
Total 230 240 244 3,434 3,721 3,803

Mozzarella Cheese: Production by State (2016-2018)

State Number of Number of Number of Production Production Production
Plants Plants Plants 2018 2016 (million 2017 (million 2018 (million
2016 2017 lbs) lbs) lbs)
California 24 25 26 1,492 1,472 1,504
Idaho 3 3 3 256 263 282
New York 13 13 13 196 189 190
Pennsylvania 6 8 8 213 218 229
Wisconsin 38 37 35 1,092 1,110 1,138
Other States1 44 48 48 869 915 1,009
Total 128 134 133 4,118 4,167 4,351
1
Fewer than three plants reported or individual plant operations could be disclosed.
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

August 2020 Page 78

 Cottage Cheese: Production by Type (2016-2018)
Type Number Number Number Production Production 2017 Production
of Plants of Plants of Plants 2016 (million (million lbs) 2018 (million
2016 2017 2018 lbs) lbs)
Creamed (fat > 4%) 54 52 54 329 330 353
Lowfat (fat < 4%) 53 54 53 368 344 342
Curd (mostly used 53 53 54 406 390 402
for processing into
creamed or lowfat
cottage cheese)
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

Cottage Cheese – Creamed (fat > 4%): Production by State (2016-2018)

State Number of Number of Number of Production 2016 Production Production
Plants Plants Plants (million lbs) 2017 (million 2018 (million
2016 2017 2018 lbs) lbs)
Colorado 3 3 3 7 7 7
Illinois 4 4 4 44 46 46
New York 6 6 7 85 84 90
Ohio 4 5 5 20 23 29
Oregon 4 3 3 2 1 1
Other States1 33 31 32 171 171 179
Total 54 52 54 329 330 353

Cottage Cheese – Lowfat (fat < 4%): Production by State (2016-2018)

State Number of Number of Number of Production Production Production
Plants Plants Plants 2016 (million 2017 (million 2018 (million
2016 2017 2018 lbs) lbs) lbs)
Colorado 3 3 3 10 10 9
New York 6 6 7 111 97 89
Ohio 4 5 5 14 12 12
Other States1 40 40 39 232 226 231
Total 53 52 54 368 344 342
1
Fewer than three plants reported or individual plant operations could be disclosed.
Sources: U.S. Department of Agriculture, National Agricultural Statistics Service, “Dairy Products: 2018 Summary” (May 2019) and “Dairy
Product: 2017 Summary” (April 2018)

August 2020 Page 79

 Figure 26.1. Basic steps in traditional cheese manufacture.

Source: Legg et al., 2017

“Although exceptional progress has been made in the mechanization and automation of cheese making, there
is still a need to refine the cheese making process to consistently produce cheese with the desired
characteristics. Membrane processing of milk and whey will offer excellent opportunities to manufacture cheese
with consistent functionality and use for milk components in an economically sound manner, but only if all the
fractions of milk are used. Membrane processing also offers a means to recover water, and there is great
potential for this water to be recycled in the cheese plant.
Changes to Code of Federal Regulations Title 21 (CFR, 2017) will be necessary to allow the use of milk
separated through membrane processing for cheese making, and it will be a priority for the cheese industry. A
point of concern is the necessity of using terms on the labels of cheese that was produced from milk using
membrane processing (i.e., UF, diafiltration, and microfiltration). These terms are not well understood by
consumers and may lead to apprehension about cheeses made using milk concentrated or separated by these
processes...”
- M.E. Johnson, Center for Dairy Research, University of Wisconsin, Madison, in Journal of Dairy Science, 2017

August 2020 Page 80

Leading Brands

As of July 2019, private label products held the highest market share of cheese, accounting for 39% of total retail
sales (↑3.3% from 2018) and 46% of natural cheese retail sales (↑5.3% from 2018).
• Kraft Heinz was the top seller of branded retail cheese across four main segments (natural, processed,
cream cheese and cottage cheese), with a 25.1% share of total cheese sales.
o Kraft Heinz owns four top brands – Kraft, Philadelphia, Cracker Barrel and Breakstone’s. Of these
four brands, only Philadelphia cream cheese recorded sales growth in 2019 (↑5.2%).
o In late 2019, Kraft Heinz's $100 million venture capital fund – Evolv Ventures – led a $3.5 million
seed investment round in New Culture, a New Zealand-based start-up that is using fermentation
to produce proteins for dairy-free cheese.
• The #2 and #3 branded dairy cheese companies, Sargento Foods (Sargento brand) and Saputo Cheese
USA (Frigo brand), earned only 5.8% and 2.8% shares of sales, respectively.
o According to Cheese Market News’ 2020 Key Players publication, Saputo “is committed to
diversifying its product portfolio by pursuing more plant-based opportunities... Saputo will look to
increase its presence in this category through a series of investments in manufacturing, sales and
distribution. To lead its plans, the company has appointed a senior vice president, business
development, Plant-Based Food.”
• Collectively, the top three companies market 350 dairy cheese products on their brand websites.
o IRI’s database included over 650 Universal Product Codes (UPCs) from these top companies.
• Of the leading brands, BelGioioso recorded the highest sales growth in 2019 (↑12.8%).
Brand Parent Current Product Portfolio Currently $ Share as of $ Retail $ Sales
Company Listed on Brand Website* 7/2019** Sales** Change
as of YoY**
7/2019
Multiple stores Selected retailer comments 39% total $4.23 billion ↑3.3%
• Whole Foods sells dairy cheese and cheese
vegan “cheese alternative” under its ↑5.3%
365 store brand. (46% natural
(natural)
• Aldi sells dairy cheese through its cheese
Emporium Selection and Happy segment; 17% ↓6.7%
Farms brands and “vegan processed (processed)
mozzarella style shreds” under its cheese
Earth Grown Vegan store brand. segment)
Note: IRI’s database included over
5,300 private label natural cheese
products with unique UPCs and 2018
retail sales***
Kraft Heinz 201 natural and processed cheese Kraft Heinz $2.74 billion ↓3.4%
products 25.1% total ($1.26 (natural)
• Shredded: 70 products with flavors cheese billion ↓3.1%
including Hot Habanero, Italian with natural; (processed)
a Touch of Philadelphia Creamy (Kraft Cheese $1.48 billion
Melt, Parmesan and Pepper Jack brand 9.8% processed)
• Slices: 54 products with flavors natural cheese
including White American, Smoky segment;
Bacon Cheddar and Extra Sharp 53.2%
White Cheddar processed
• Blocks: 38 products with flavors cheese
including Monterey Jack Cheese segment)
Cracker Cuts, Chipotle and Jalapeño
• Cubes: 5 products including 2% Milk
Cheddar & Monterey Jack
• String & Twists: 16 products
including Jalapeño String Cheese
and Mozzarella & Cheddar Twists
• Parmesan: 18 products including
Shredded Parmesan and Grated
Parmesan & Romano Cheese
Note: IRI’s database included 263
Kraft natural cheese products and 102
processed cheese products with
unique UPCs and 2018 retail sales***

August 2020 Page 81

Kraft Heinz 41 cream cheese products Kraft Heinz $1.17 billion ↑5.2%
• Bricks: 5 products (Original and 1/3 25.1% total
Less Fat) cheese
• Dips: 7 products with flavors
including Buffalo Style with Celery (Philadelphia
and Spinach Artichoke brand 66.9%
• Spreads & Whips: 29 products with cream
flavors including Honey Pecan, Plain cheese/spreads
2x Protein and Smoked Salmon segment)
• Philadelphia also sells packaged
Cream Cheese Snacks, e.g., Bagel
Chips & Strawberry Cream Cheese,
and Ready to Eat Cheesecake /
Cheesecake Filling
Note: IRI’s database included 10
Philadelphia natural cheese products
with unique UPCs and 2018 retail
sales***
Sargento 40 natural cheese products 5.8% total $1.07 billion ↓8.4%
Foods Inc. • Shredded: 12 products with flavors cheese
including Sharp Cheddar, Monterey
Jack, 6 Cheese Italian and Aged (8.3% natural
Parmesan cheese
• Sliced: 12 products with flavors segment)
including Garlic & Herb Jack,
Reduced Fat Colby, Swiss and Aged
Gouda
• Reduced Fat Sticks: 2 products
(Colby Jack and Cheddar)
• String: 2 products (Natural and
Mozzarella)
• Sticks: 3 products (Smokehouse
Cheddar, Pepper Jack and Extra
Sharp Natural Cheddar)
• Snack Bites: 4 products with flavors
including Colby, Monterey Jack and
Rustic Gouda & Mild Yellow
Cheddar
• Grated: 2 products (Parmesan and
Parmesan & Romano)
• Ricotta: 3 products (Light, Part-Skim,
Whole Milk)
• Sargento also sells packaged
Balanced Breaks snacks (cheese
pieces, fruit, nut, and seed)
Note: IRI’s database included 220
Sargento natural cheese products with
unique UPCs and 2018 retail sales***
Tillamook 56 natural cheese products 2.2% total $409 million ↑5.2%
County • Specialty: 13 products with flavors cheese
Creamery including Maker’s Reserve 2010
Association Extra Sharp White Cheddar, (3.2% natural
Specialty Garlic Chili Pepper cheese
Cheddar and Specialty Hot segment)
Habanero Jack
• Loaf: 12 products with flavors
including Colby Jack, Kosher
Medium Cheddar and Vintage Extra
Sharp White Cheddar
• Shredded: 10 products with flavors
including Italian Blend, Mexican 4
Cheese and Triple Cheddar
• Sliced: 13 products with flavors
including Extra Sharp White
Cheddar, Provolone, Swiss and
Muenster
• Snack Portions: 4 products with
flavors including Smoked Black
Pepper White Cheddar and Colby
Jack

August 2020 Page 82

 • Curds: 2 products (White Cheddar
and Cheddar)
• Sticks: 2 products (Colby Jack and
Medium Cheddar)
• Tillamook also sells packaged
Cheeseboards (cheese, fruit spread,
and crackers
Note: IRI’s database included 127
Tillamook natural cheese products with
unique UPCs and 2018 retail sales***
BelGioioso 32 natural cheese products 2.2% total $372 million ↑12.8%
Cheese Inc. • Classic Cheeses: 21 products cheese
including Asiago, Fontina, Parmesan
and Romano (2.9% natural
• Artisan Cheeses: 11 products cheese
including Provolone Extra, segment)
Gorgonzola and American Grana
Note: IRI’s database included 10
Belgioioso natural cheese products
with unique UPCs and 2018 retail
sales***
Saputo Cheese 16 natural cheese products 2.8% total $318 million ↓2.2%
USA Inc. • Ricotta Cups: 3 products (Light, cheese
Part-Skim and Whole Milk)
• Blocks: 5 products, with flavors (2.5% natural
including Light Mozzarella, Fresh cheese
Mozzarella and Whole Milk segment)
Mozzarella
• Wedges: 2 products (Parmesan and
Romano)
• Crumbled: 2 products (Blue Cheese
and Feta)
• Grated Parmesan: 1 product
• Shaved Parmesan: 1 product
• Shredded: 2 products (Parmesan
and 3-Cheese Italian)
Note: IRI’s database included 59 Frigo
natural cheese products with unique
UPCs and 2018 retail sales***
Kraft Heinz 43 natural cheese products Kraft Heinz $251 million ↓0.9%
• Blocks: 14 products, with flavors 25.1% total
including Sharp Cheddar, Baby cheese
Swiss, Gouda and Havarti
• Slices: 6 products, with flavors (Cracker Barrel
including Vermont Sharp White, brand 1.9%
Heartland Aged Swiss and California natural cheese
Smoked Provolone segment)
• Cracker Cuts: 6 products, with
flavors including Jalapeno Cheddar,
Sharp White Cheddar and Gouda
• Cubes: 7 products, with flavors
including Cheddar Jack, Aged
Reserve Cheddar and Cheddar Jack
• Spreadables: 3 products, Extra
Sharp Yellow Cheddar, Garlic &
Herb Cheddar and Sharp White
Cheddar
• Sticks: 6 products, with flavors
including Jalapeno White Cheddar,
Reduced Fat Extra Sharp Yellow
Cheddar and Cheddar Jack
• Bars: 1 product (Extra Sharp Yellow
Cheddar)
• Cracker Barrel also sells packaged
Bites and Pairing Boards.
Note: IRI’s database included 51
Cracker Barrel natural cheese
products with unique UPCs and 2018
retail sales***

August 2020 Page 83

 Lactalis 59 natural cheese products Less than 2% $233 million ↑1.4%
American Dairy Aisle Cheeses overall
Group • Fresh Mozzarella: 5 products,
including Logs, Sliced Logs and (1.8% natural
Balls cheese
• Grated: 3 products (Parmesan, segment)
Romano and Asiago & Parmesan)
• Blocks: 3 products, Reduced Fat
Mozzarella, Great for Slicing
Mozzarella and Great for Shredding
Mozzarella
• Ricotta: 6 products, including
Classic, Low Fat, Fat Free and Part
Skim
• String Cheese: 6 products, with
flavors including Provolone, Lactose
Free Mozzarella and Whole Milk
Mozzarella
• Stick Cheese: 4 products, with
flavors including Colby Jack, Pepper
Jack and Cheddar
• Sliced: 6 products, with flavors
including Provolone, Asiago and
Mozzarella
Specialty Cheeses
• Fresh Mozzarella: 21 products,
including Logs, Sliced Logs, Balls,
Pearls and Snacks
• Mascarpone: 2 products
(Mascarpone and Mascarpone
Imported Italian)
• Ricotta: 3 products (Classic, Whole
Milk and Low Fat)
Note: IRI’s database included 70
Galbani natural cheese products with
unique UPCs and 2018 retail sales***
Kraft Heinz 9 cottage cheese products Kraft Heinz $141 million ↓5.1%
• Small Curd: 3 products (2%, 4%, 25.1% total
and Fat Free) cheese
• Large Curd: 2 products (2% and 4%)
• Small Curd Snack Packs: 4 products (Breakstone’s
(2%, 4%, Fat Free, and Live Active) brand 13.4%
• Breakstone’s also sells Cottage cottage cheese
Doubles (cottage cheese with fruit) segment)

*Brand/company websites, accessed 7/2020

**IRI, multi-outlet retail cheese sales, 52 weeks ending 7/14/2019, cited in Mintel, Cheese US, 11/2019

“While most name brands failed to make gains, collectively private label brands outpaced the growth of the
category. Two leading brand bright spots for the category were Tillamook and BelGioioso, both of whom are
leveraging natural, artisan and quality as distinct selling points. These companies definitely lean more
gourmet, particularly BelGioioso. Tillamook, meanwhile, is capitalizing on a natural promise…”
- Mintel, Cheese US, 10/2019

“Snackability is one of the most significant ongoing trends [in natural cheese]… Sargento launched its
Balanced Breaks cheese snack line… in 2015, and the line ended up being the company’s most successful
launch ever… And [in 2019], Sargento expanded on that launch with its Sargento Sunrise Balanced
Breaks…
• Snacking isn’t the only trend playing out in the cheese segment… A growing assortment of varieties
also is drawing consumers in… The trend toward variety fits in with the increasingly adventurous
American palate…
• Going hand-in-hand with the trend toward variety is the trend centering on flavors… Sargento is
seeing growing interest in bold flavors – think peppers and smoked and aged formulations – for
natural cheese snacks…”
- Dairy Foods’ 2019 State of the Industry Report, 11/2019

August 2020 Page 84

Cheese Standards of Identity: Quantity of Currently-Marketed Products
• According to an August 2020 telephone conversation with the American Cheese Society, the cheese
standards of identity (SOI) are viewed and applied through production, consumer and regulatory lenses.
They are not aware of any source that quantifies the amount of each individual SOI cheese produced in
the U.S.
o As an alternative estimation method, searches for selected cheese SOI terms in over 15,000
natural and processed cheese product names with 2018 retail sales were completed in IRI’s
database, with the following results:
 The three types with the most unique UPCs were cheddar (3,982); mozzarella/scamorza
(2,036) and Colby (1,015).
 No products were found with caciocavallo siciliano, gammelost, Neufchatel, nuworld,
samsoe or sap sago in the name.

SOI Cheese Type Number of unique UPCs

with selected cheese SOIs
in product name
Asiago 80
Blue 293
Caciocavallo siciliano None
Cheddar 3,982
Colby 1,015
Cook / Koch 1
Edam 37
Gammelost None
Gorgonzola 71
Gouda 332
Gruyere 32
Limburger 9
Monterey 795
Mozzarella / Scamorza 2,036
Muenster / Munster 291
Neufchatel None
Nuworld None
Parmesan / Reggiano 465
Processed / Process 357
Provolone 319
Romano 153
Roquefort 3
Samsoe None
Sap Sago None
Swiss / Emmentaler 688
Source: IRI retail sales database

August 2020 Page 85

Consumer Demographics, Behavior & Perceptions

• According to an August 2019 Lightspeed/Mintel survey of U.S. adults, the top three varieties of natural
cheese consumed in the past three months were cheddar, mozzarella and parmesan.
o The three least popular varieties were brie, gouda and blue cheese.
o Respondents who ate cheese at least once per week chose natural dairy cheese more frequently
than processed, cottage or cream types.
o The most popular way to eat or use natural cheese was on a sandwich, while the least popular
way was as a dessert.

Source: Mintel, Cheese US, 10/2019

August 2020 Page 86

Source: Mintel, Cheese US, 10/2019

“Among younger consumers in particular, who are the most frequent snackers, bold and more diverse flavors
and product portfolios are likely to help brands connect and build a sense of loyalty.”
- Mintel, Cheese US, 10/2019

August 2020 Page 87

Timeline of Selected Industry Milestones & Innovation

Source: Johnson, ME, 2017

August 2020 Page 88

PBDA “Cheese” Market

Retail Sales & Household Penetration

• According to SPINS, PBDA “cheese” retail sales reached $189 million in 2019 – ↑51% from 2017.
o Shredded/grated was the leading product types, with $67 million in sales and a 35.5% share,
followed closely by sliced/snack, with $65 million in sales and a 34% share.
o Spreads were the fastest-growing product type, with approximately 25% growth y-o-y.
o 67% of total PBDA “cheese” sales were in IRI’s conventional multi outlet (MULO) channel,
compared to 33% in SPINS’ natural and specialty gourmet channels.
o Only 3% of households bought PBDA “cheese” in the past six months (↑0.2% y-o-y), but over
50% purchased twice or more.
 Household penetration of PBDA “cream cheese” was even lower at 1% (↑0.3% y-o-y), but
over 40% purchase the product twice or more.

• According to the latest SPINSscan data commissioned by the Plant Based Foods Association (PBFA) in
May 2020, U.S. retail sales of plant-based foods “have considerably outpaced total food sales during the
pandemic, demonstrating that more consumers are turning to plant-based foods amid the crisis.
o The Plant Based Foods Association (PBFA) analyzed data in several “fast-growing categories,”
including “cheese,” for the 16 weeks ending April 19, 2020. Retail sales of PBMA “cheese”
“spiked at 95% (compared to last year) during peak panic buying and grew 54% over four weeks
post panic buying.”

August 2020 Page 89

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

PBDA "Cheese": $ Sales by Retail Channel 2019

(% of Total Cheese Sales)
$150 $127m (67%)

$100
$54m (28%)
$50
$9m (5%)
$0
MULO Specialty Gourmet Natural

Source: SPINSscan Natural and Specialty Gourmet (proprietary) + SPINSscan Conventional Multi Outlet (powered by IRI) for 52 weeks
ending 12-29-2019. Cited in The Good Food Institute, “Plant-Based Food Retail Market Overview” webinar, 4/2020

Plant-Based “Cheese” and “Cream Cheese”:

Household Penetration and Single vs. Multiple Purchasers

Source: IRI, National Consumer Panel Survey, January 2019. Cited in IRI, “Understanding the Plant-Based Consumer: A Deeper Look Into
Plant-Based Purchase Trends, Demographics, Perceptions and Usage,” 1/16/2020

"Fully plant-based cheese doesn't work, and we know why… It lacks the crucial component that gives dairy
cheese its signature properties, and that is the casein micelle... We are developing the technology to make those
casein micelles without involving animals in the process."
- Inja Radman, New Culture co-founder and chief sustainability officer, quoted in Food Business News, 9/2019
(Note: Kraft Heinz’ venture capital fund – Evolv Ventures – invested in New Culture in late 2019.)

August 2020 Page 90

Production

• Most manufacturers do not publicly disclose their manufacturing processes on their websites. One
exception is a biotech start-up:
o Real Vegan Cheese “is not a cheese substitute! It all starts with regular old yeast. Through
synthetic biology, we engineer our yeast to become milk-protein factories. Our milk proteins are
then combined with water and vegan oil to make vegan milk, which is ultimately converted into
Real Vegan Cheese through standard cheese-making processes - just like cheese made from
cow or goat milk!”

• Three recently-published non-dairy cheese patent applications that describe ingredients and production
processes:
o “Hard non-dairy cheese composition and process for preparation thereof,” WO2020089384A1,
Nestlé
o “System and method for producing a non-dairy cheese product,” WO2018191205A1, Groupe
Danone
o “Soy-based cheese,” WO2015127388A1, Impossible Foods

August 2020 Page 91

Leading Brands
• According to The Good Food Institute (GFI), the top 10 brands in the “emerging” plant-based cheese
category generated 94% of retail sales in 2019, “holding steady from 2018.”
o The top 10 brands currently market 126 products on their brand websites.
• Daiya is the market leader, with $37.1 million in 2018 retail sales according to IRI data.
• Go Veggie offers both vegan and lactose-free products, and Lisanatti Foods’ products all contain casein.
• Go Veggie markets most aggressively the nutritional comparisons between its products and both dairy
cheese and other dairy free cheese alternatives, providing comparisons on an individual product basis on
its website.
• GFI reported that private-label products account for just 2% of total PBDA “cheese” sales.
o In its 2019 Good Food Retail Report, GFI commented: “Very few retailers offer private-label plant-
based cheese, despite the availability of branded products in multiple types and formats,
including block, sliced, and shredded.”
• GFI hosts a searchable Plant-Based Product Database that includes multiple “cheese” products
“available in foodservice distribution” from Daiya and Follow Your Heart. The database does not currently
list any PBDA “milk” or “yogurt” products.
Brand Parent Current Product Portfolio Currently Listed on Brand Website** $ Retail Sales
Company 2018***
Otsuka 27 varieties with multiple plant-based ingredients $37.1 million
Pharmaceutical • Shreds: 8 flavors (4 Original; 4 Cutting Board Collection
Co. Ltd. “improved recipe; best taste & texture; made with chickpea”)
• Slices: 6 flavors
• Blocks: 4 flavors
• “Deluxe Cheeze Sticks”: 2 flavors
• “Cream Cheeze Style Spreads”: 4 flavors
• “Deluxe Cheeze Sauces”: 3 flavors

Follow Your 17 varieties with multiple plant-based ingredients $15.4 million

Heart • Slices: 7 flavors
• Shreds: 4 flavors; “Finally, a non-dairy cheese with real cheese
taste, melt, and texture! Use it as you would any dairy cheese for
a healthier indulgence.”
• Blocks: 2 flavors
• Cream Cheese: 1 flavor
• Shredded: 1 flavor
• Grated: 1 flavor
• Crumbles: 1 flavor
Maple Leaf 3 coconut- and fermented tofu-based varieties $13.1 million
Foods • Slices: 3 flavors
“What makes our plant-based, dairy-free cheeses so creamy,
complex and satisfying? The secret is our fermented tofu, which
adds a buttery texture and umami bite to all of our Chao cheeses.”

GreenSpace 18 varieties with multiple plant-based ingredients $12.8 million

Brands • “Vegan Shreds”: 3 potato starch-based flavors; Mexican: “90%
less saturated fat; 55% more calcium; No cholesterol, lactose or
gluten (compared to ordinary cheese)”
• “Vegan Cream Cheese”: 3 coconut-based flavors (contains soy);
Classic Plain: “Made with healthy coconut; 25% less saturated
fat; No cholesterol, lactose or gluten (compared to ordinary
cheese)”
• “Vegan Spread & Dip Minis”: 2 coconut-based flavors
• “Vegan Grated Parmesan Style Topping”: 2 coconut-based
flavors (1 soy-free); “30% less fat; Double the calcium; No soy,
cholesterol, lactose or gluten (compared to ordinary cheese)”
• “Lactose-Free Singles”: 5 flavors (contain milk and soy); Cheddar:
“40 less calories; 50% less fat; Double the calcium; No
cholesterol, lactose or gluten (compared to ordinary cheese)”
• “Lactose-Free Shreds”: 3 flavors (contain milk and soy);
Mozzarella: “6 g protein; 25% less fat; 65% more calcium; No
cholesterol, lactose or gluten (compared to ordinary cheese)”
“Any way you slice it, we’re The Healthier Way to Love Cheese™.”
“Cheesy bliss”

August 2020 Page 92

 Miyoko’s 17 cashew-based varieties $2.2 million
Creamery • “Organic Cultured Vegan Cheese Wheels”: 9 flavors
• “Organic Cultured Vegan Mozzarella”: 2 flavors
• “Organic Cultured Vegan Cream Cheese”: 3 flavors
• “Organic Cultured Vegan Cheese Spreads”: 3 flavors
“Cashew cream fermented with live cultures”
Lisanatti Foods 11 almond, rice and soy-based varieties (all contain casein) $1.8 million
• The Original Almond® Chunks: 4 flavors
• The Original Almond® Shreds: 2 flavors
• RiceCheeze® Chunk: 1 flavor
• RiceCheeze® Sticks: 1 flavor
• SoySation® Slices: 1 flavor
• SoySation® Shreds: 2 flavors
“The Good Health Cheese Alternative”
“Lisanatti vegetarian cheese alternatives are known for their
exceptional texture, flavor, and melting performance.”
Gardener 9 cashew-based varieties $1.1 million
Cheese • “Soft French-Style Nut Cheeses”: 4 flavors
Company • “Cashew Cream Cheese”: 3 flavors
• “Aged Nut Cheeses”: 2 flavors
“Like dairy cheese, it is made by a process of fermentation, using a
probiotic culture. It contains no dairy milk, so it’s both good for you
and cruelty-free.”
Tofutti 7 soy-based varieties $0.5 million
• “Dairy Free Cheese Slices”: 2 flavors
• “Better than Cream Cheese”: 4 flavors
• “Better Than Ricotta Cheese”: 1 flavor

Upfield Group 13 varieties with multiple plant-based ingredients $0.08 million

B.V. • “Just Like” Shreds: 3 flavors
Note: Upfield • “Just Like” Slices: 3 flavors
acquired Violife • “Just Like” Blocks: 3 flavors
from Arivia S.A. • “Just Like” Creams: 3 flavors
in January 2020. • “Just Like” Wedge: 1 flavor
“Violife is the alternative that tastes and cooks just like cheese!”
“Healthy food, free from allergens that you, personally, need to
avoid. Soy, nuts, gluten and lactose. Because you care about your
health.”
Kite Hill 4 almond-based varieties N/A
• “Ricotta Alternative”: 1 flavor
• “Cream Cheese Alternatives”: 3 flavors
“As with traditional dairy cheesemaking, we inoculate almond milk
with our proprietary enzymes and cultures, then rest it overnight to
transform it into curds and whey. We’ve found this is the best way to
get the amazing flavor and character of our cheese.”
*GFI, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020
**Brand/company websites, accessed 7/2020
***IRI, 2018 U.S. $ sales in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus
Convenience Stores. Excludes natural and specialty gourmet channels.

At the 2019 Natural Products Expo West event, Miyoko’s “debuted organic vegetable-based, nut-free block
“cheeses” fermented with live cultures. The products are made with potatoes and legumes and are said to
have tangy and delicious flavors resembling traditional dairy-based cheddar and pepper jack cheeses.”
- Dairy Foods’ 2019 State of the Industry Report, 11/2019

August 2020 Page 93

Names/Descriptions on Leading Brands’ Product Labels

• Unlike PBDA “milk” and “yogurt” brands, none of the top 10 PBDA “cheese” brands uses the term
“cheese” without qualifiers as its product name or on its front product label.
o A commonly-used qualifying phrase is “cheese alternative.”
o Daiya and Lisanatti Foods use the spelling variation “cheeze” on multiple product offerings.

Name/Label Includes the Term Leading Brand(s) with Examples from Front Product Labels
“Cheese” AND Qualifier(s) Applicable Product(s)
Multiple words: e.g., Dairy Free Cheese Follow Your Heart
Alternative, Cheese Alternative, Cream Go Veggie
Cheese Alternative, Cheese Wheel Made Miyoko’s Creamery
From Plants, Cultured Vegan Cream Lisanatti Foods
Cheese 100% Crafted From Plants, Treeline
Treenut Cheese, Cashew Cream Cheese, Tofutti
Nut Cheese, Better Than Cream Cheese, Kite Hill
Dairy Free Cheese Slices, Cheese
Alternative With Coconut Oil and Vitamin
B12, Cream Cheese Alternative Made
With Almond Milk

Name/Label Includes an Alternate Leading Brand(s) with Examples from Front Product Labels
Spelling of the Term “Cheese” Applicable Product(s)
Deluxe Cheeze Sticks, Deluxe Cheeze Daiya
Sauces, Cream Cheeze Style Spread, Lisanatti Foods
RiceCheeze, SoySation

August 2020 Page 94

 Name/Label Excludes Term Leading Brand(s) with Examples from Front Product Labels
“Cheese” Applicable Product(s)
Mozzarella Style Shreds, American Style Daiya
Slices, Chao Slices, Cheddar Style Field Roast
Shreds, Fresh Vegan Mozz Made from Go Veggie
Plants, Just Like Shreds Violife

Sources: Brand/company websites, accessed 7/2020; Information Resources Inc. (IRI), U.S. MULOC $ sales for 52 weeks ending 10/6/2019
in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience Stores.
Excludes natural and specialty gourmet channels. Cited in IRI, “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the
Growth of Plant-Based Foods,” 11/2019; GFI, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020

August 2020 Page 95

Consumer Demographics, Behavior & Perceptions
• 65% of survey respondents ages 23-40 respond positively to PBDA “cheese,” followed by 42% of
consumers ages 18-22 and 41-52.

Source: Mintel, 4/2019

Source: Mintel, 4/2019

Among dairy-free cheese consumers, two drivers clearly stand out in importance: organic claims and the
promise of protein, indicating that these consumers seek cleaner offerings that can still deliver on the
nutritional benefits of cheese.”
- Mintel, Cheese US, 10/2019

August 2020 Page 96

Timeline of Selected Milestones/Product Innovations

• 1970s: Fermented tofu begins to be imported into the United States from countries including China, Hong
Kong and Singapore.
• 1980: Galaxy Foods (Go Veggie brand owner) is founded; company claims it is “the first and finest maker
of better-for-you cheese.”
• 1985: Swan Gardens launches Soya Kaas, “a meltable cheese alternative that contained both tofu and
casein (a protein from cow’s milk).”
• 1986: Brightsong Foods introduces Mozzarella Style Tofu-Rella.
• 1988: Two co-founders of the Follow Your Heart health food store launch Earth Island to manufacture its
proprietary products, including cheese alternatives.
• Mid-2000s-2015: According to a 2015 Xinhua article, “For a long time in the past, vegan cheese had
been mostly a rubbery, tasteless pale chunk that resembled tofu, making it far from pleasurable on the
palate for many consumers. Last decade saw a steady rise in the quality and taste of these products,
thanks to the growing popularity of veganism worldwide…”
• 2008: Daiya Foods is founded.
• 2011: Gardener Cheese Company (Treeline brand owner) is founded.
o “Popular vegan cheeses in the United States are made by Daiya, Galaxy Nutritional Foods, and
Chicago Soydairy (Teese)... Most melt, some stretch, the last two are soy-based. But whereas
most Chinese love and use fermented tofu, very few vegans or vegetarians are even aware of it
or even think of it."
• 2012-2015: Miyoko’s Kitchen, Kite Hill and Real Vegan Cheese, a “biohacker” start-up “are spearheading
the change through innovation while at the same time retrieving traditional cheese-making methods…”
• 2014: Kite Hill and Miyoko’s Kitchen are founded.
• 2017: A Washington Post article noted: “There's a revolution happening in the cheese world, and it
doesn't have anything to do with dairy. For decades, vegan cheese has had a bad rap. It was well
deserved. Rubbery and often with an aftertaste compared to pencil erasers or Play-Doh, the plant-based
varieties just did not stand up to the real thing. Now, a new generation of vegan chefs and food
entrepreneurs has figured out what was missing: fermentation…”
• 2019: Fuji Plant Protein Labs (Savannah, GA) launched Nozzarella “plant-based cheese for the
commercial foodservice and pizza markets. The non-GMO soy-based product is produced with the
company’s patented Ultra Soy Separation process.” (Dairy Foods’ 2019 State of the Industry Report)

“Consumer suspicion around dairy's healthfulness, together with growing interest in plant-based eating and
ethically responsible consumption, suggest tremendous opportunity for non-dairy cheese products. For
mainstream omnivores, non-dairy cheese has a long way to go before being regarded as a better choice or an
occasional addition alongside dairy, the way that well-established plant-based milks are now regarded...”
- Jane Hurh, Mintel, 4/2019

August 2020 Page 97

 Dairy Food Standards of Identity (SOI)
Summary of Comments from Selected Dairy Industry Stakeholders

A review of recent public submissions to the FDA from 20 companies/organizations with interest in the dairy
industry revealed:
• At the macro level, the majority of these stakeholders – including manufacturers Blue Diamond Almonds,
Kraft Heinz and Nestlé USA and trade associations IDFA and PBFA – support a horizontal approach to
food SOI modernization.
o Two stakeholders – NMPF and NFFC – are opposed to a horizontal approach.
o One stakeholder – CSPI – expressed both support for and opposition to a horizontal approach,
depending on the circumstances.
• At the micro level, multiple stakeholders advocated for:
o Allowing salt substitutes to manufacture lower sodium cheese (CSPI, IDFA)
o Permitting use of ultra-filtered (UF) and micro-filtered (MF) milks in cheese and/or yogurt (IDFA,
GFI, Wisconsin Cheese Makers Association)
o Allowing flexible use of mold inhibitors in cheese (IDFA, Kraft Heinz, NYA)
o Removing milkfat minimums for yogurt (IDFA, NMPF, NYA)
o Requiring a qualifying term with an established term for foods that are distinct from the
standardized food, e.g. the qualifying term “soy” in front of the established term “milk” or the
compound word “soymilk” (Blue Diamond Almonds, Danone North America, GFI)

“As one of the largest producers of both dairy and plant-based products, such as soymilk and almondmilk, we believe that
dairy and plant-based products can and should co-exist to provide consumers a wider array of healthy choices.”
- Danone North America, October 11, 2018, Re: The Food and Drug Administration’s Comprehensive, Multi-Year
Nutrition Innovation Strategy; Request for Comments; Docket No. FDA-2018-N-2381

Submitting Submission Support Horizontal Verbatim Excerpts from Comments

Company/Organization Date Approach?
American Cheese Society 7/20/2020 Unspecified ACS supports the definitions of milk, milk products, and
(ACS) cheese, which clearly express the unique qualities of
dairy and dairy products… ACS believes that the FDA
“At more than 2,300 should enforce its labeling rules and end the application
members strong, ACS is of the term “milk” or “cheese” to nutritionally and
the leading organization compositionally different non-dairy products…
supporting the
understanding,
appreciation, preservation,
and promotion of artisan,
farmstead, and specialty
cheeses produced in the
Americas.”
Blue Diamond Almonds 11/12/2019 YES FDA should issue a regulation establishing the following
requirements:
“This comment
Leading manufacturer of • If the statement of identity for a separate and distinct
advocates that FDA
PBDA “milk” and “yogurt.” food, e.g., “soymilk,” includes a standardized term
issue a horizontal
from a regulation establishing a standard of identity,
regulation governing
e.g., the term “milk,” that statement of identity must
the statement of
also include a qualifying term that clearly discloses
identity for any
that such food is a separate and distinct product
separate and
rather than the standardized food, e.g., the qualifying
distinct food with a
term “soy” in front of “milk.”
name that includes
• The statement “See Nutrition Facts and Ingredients”
a term from one of
must appear in reasonable proximity to the statement
the existing
of identity in a font that is at least half the height of the
standards of identity
(“SOI”).” statement of identity and in a color that contrasts with
the background.

August 2020 Page 98

Bongards' Creameries (Dr. 11/14/2019 Unspecified • My comments pertain to the changes in consumer
Craig Schroeder, VP of trends and how they impact cheese product
Technology) development… One of the biggest challenges with
the process cheese standards is that sorbic acid and
Minnesota-based propionic acid (and their salts) are no longer
manufacturer of natural consumer friendly. Complete removal does create
cheese, process cheese, problems with shelf life and, potentially, food safety.
imitation cheese, cream Process cheese standards of identity that only allow
cheese and whey specific mold inhibitors are outdated. Standards need
to be updated and more broadly structured to allow
the use of newly developed/available, safe, and
consumer friendly antimicrobials.
Center for Science in the 7/20/2020 YES and NO 1. Issue regulations requiring the amount of key
Public Interest (CSPI) healthful ingredients to be declared.
“To the extent that
2. Allow salt substitutes to be used in standardized
the agency wishes
“Founded in 1971, the foods where necessary to achieve sodium
to consider broader
Center for Science in the reduction targets. We urge the agency to permit
horizontal changes
Public Interest is perhaps the use of potassium salt (potassium chloride)
that cut across food
the oldest independent, and other sodium substitutes… Cheeses with a
categories, we
science-based consumer federal standard of identity, such as Mozzarella,
specifically
advocacy organization with Cheddar, Processed American cheese and
recommend that the
an impressive record of almost all named cheeses, are precluded from
agency prioritize the
accomplishments and a using a salt substitute or other functional
following horizontal
clear and ambitious ingredient not usually allowed by the standard.
regulatory changes
agenda for improving the The National Milk Producers Federation and
to promote
food system to support International Dairy Foods Association have
transparency and
healthy eating.” specifically commented that standards of identity
public health goals.”
serve as a barrier to meeting FDA’s voluntary
sodium reduction targets in standardized
“At a minimum, we
cheeses.
strongly urge the
3. Maintain and expand key standards for enriched
agency not to adopt
cereal flours.
a ‘horizontal
4. Require dairy substitutes to disclose when the
standard’ that allows
product contains less of a key nutrient than the
the addition of self-
reference dairy food. To ensure that consumers
determined GRAS
have a clear understanding of the nutritional
ingredients to
value of these products, we have asked that the
standardized foods,
FDA instead require a front-of-package
as these ingredients
disclosure on the products that fail to provide the
have not been
levels of key nutrients typically found in milk,
reviewed for safety
yogurt, or cheese—naturally or by fortification—
by the FDA.”
under the agency’s general authority to prevent
misleading labeling in 21 U.S.C. § 343(a)(1).52
Such a declaration could be applied horizontally
across all dairy substitutes, rather than as an
amendment to the standard of identity for specific
products.
5. Develop a streamlined process for reviewing
other changes to food standards on a case-by-
case basis.

August 2020 Page 99

Chobani 10/11/2018 Unspecified • Regulatory agencies need to be aligned on the value
and application of SOIs to ensure nutritious products
Leading manufacturer of are equally recognized and encouraged across
products including dairy Federal policies. The example of strained, high-
yogurt and PBDA “yogurt;” protein yogurt being recognized in USDA school
also recently launched meals, but not in FDA’s SOIs, is a good example of
Chobani Oat plant-based this challenge
beverages. • Build on the foundational 2005 FDA-USDA joint SOI
proposed rule…that would promote honesty and fair
dealing in the interest of consumers; allow for food
technology advances
• Incorporate the use of Temporary Marketing Permits
(TMPs) in the SOI development process.
• Create and leverage public-private partnerships to
reduce Federal resources, keep faster pace with
marketplace and consumer demands, as well as
purchase trends.
Danone North America 10/11/2018 Unspecified • We implore FDA to reconsider its current position
against the use of common and usual names for
“…innovation for
Manufacturer of #1 brands plant-based products that include ‘milk’ as part of a
more dairy products
in dairy yogurt, PBMA larger compound word (e.g. soymilk, almondmilk,
will likely come from
“milk” and PBMA “yogurt”; coconutmilk)
updating standards
also owns a leading dairy • Dairy and plant-based products can and should co-
of identity such as
milk brand. exist
the one for yogurt...”
Flavor and Extract 11/14/2019 YES • Additionally, we support horizontal food standard
Manufacturers Association modernization as the potential benefits can help
“FEMA generally
(FEMA) innovation for a myriad of other foods subject to
supports the FDA’s
federal standards, including processed cheese
efforts to
FEMA “is comprised of products at 21 CFR Part 133. Such horizontal
establish broad,
flavor manufacturers, modernization could allow for manufacturers to
horizontal
flavor users, flavor employ additional production techniques to develop
modernization to the
ingredient suppliers, and processed cheese products that continue to reflect
standards of identity
others with an interest in consumers’ expectations. Broad modernization could
in an effort to
the U.S. flavor industry. also encourage innovation by encouraging
provide the
Founded in 1909, it is the manufacturers to utilize safe and suitable ingredients,
food industry
national association of the including spices and flavorings, which reflect modern
flexibility. We agree
U.S. flavor industry.” consumer preferences.
with the agency that
such an approach,
rather than a
standard-specific,
vertical approach
will maximize FDA’s
limited resources
and make the
largest potential
impact…”
Food Marketing Institute 11/12/2019 YES
(FMI)
“We recommend
that a horizontal
FMI “brings together a 1. Ingredients used for technical effect
approach to
wide range of members 2. Alternative flavorants and other substitutes to both
modernizing SOIs
across the value chain — enhance flavor and improve nutrition
allow for variations
from retailers who sell to 3. Use of new technology
from established
consumers, to producers 4. Permit improvements to nutritional profiles that do not
SOIs by providing
who supply the food, as rise to the level of a defined nutrient content claim
flexibility in the
well as the wide variety of 5. Change in shape or form
following areas:”
companies providing
critical services — to
amplify the collective work
of the industry.”

August 2020 Page 100

The Good Food Institute 11/12/2019 YES • The citizen petition submitted by GFI requests that
(GFI) FDA issue a regulation clarifying that new foods may
“This could come in
be named by reference to other ‘traditional’ foods in a
the form of a
GFI “works with scientists, manner that makes clear to consumers their distinct
horizontal standard
investors, and origins or properties.
that would make
entrepreneurs to make • GFI supports an approach, such as that suggested by
these ingredients
groundbreaking good food IDFA [International Dairy Foods Association] and
‘basic dairy
a reality. We focus on FDA, that would allow flexibility to use modern dairy
ingredients’ across
clean meat and plant- ingredients (such as UF [ultra-filtered] milk or milk
all classes of dairy
based alternatives to protein isolate) in standardized dairy foods like yogurt
foods.”
animal products….” and cheeses.
• Continuing to allow innovative producers to use
qualified standardized terms on the labels of new
foods will promote regulatory efficiency and flexibility
and give consumers the opportunity to make more
healthful food choices.
Grocery Manufacturers 11/12/2019 YES 1. Addition or substitution of ingredients intended solely
Association (GMA) for technical, nondistinctive effects, such as emulsifiers,
A horizontal
stabilizers, or antimycotic agents…
approach would
Note: GMA changed its 2. Use of safe and suitable flavors and flavor enhancers
provide flexible food
name to the Consumer in foods generally, and use of safe and suitable
standards... In 2006,
Brands Association in ingredients that can improve the overall nutrition profile
GMA and allied
2020. The organization of a product such as salt substitutes, sweeteners,
associations,
“champions the industry vegetable fats and oils
including the
whose products Americans 3. Use of advanced or more efficient technologies to
International Dairy
depend on every day. produce ingredients of all types
Foods Association,
From household and 4. Use of alternate manufacturing processes, also
submitted a Citizen
personal care to food and known as "alternate make" procedures, for those
Petition that outlined
beverage products, the standards that specify particular processes
a process that could
consumer packaged goods 5. Changes to a product's basic shape in response to
efficiently allow for
industry plays a vital role in consumer demands
such deviations
powering the U.S. 6. Improvements in nutritional properties by adding
through the
economy.” beneficial ingredients, decreasing nutrients of concern
implementation of
or utilizing new or innovative technology that do not rise
categories of
to the level of a defined nutrient content claim
flexibilities.
7. Improvement to products for allergens and
intolerances
8. Eliminate requirements, both maximums and/or
minimums, for salt, sugar, oil and fat in standardized
foods
9. Use of advanced or more efficient technologies or
use of safe and suitable ingredients to improve the
sustainable properties
International Dairy Foods 10/8/2018 YES • Prioritize reviewing and responding to citizen petitions
Association (IDFA) 11/12/2019 requesting changes to the food standards
“Take a horizontal
• Streamline and revise the temporary marketing permit
approach to food
IDFA members “represent (TMP) process so that companies can seek needed
standards
approximately 90% of the flexibility in the standards, including consideration of
modernization,
milk, cheese, ice cream, converting the permit application process into a
looking to the 2006
yogurt and cultured notification process
[GMA] food industry
products, and dairy • Explore legislative changes that could facilitate more
petition as a starting
ingredients produced and timely updates to the dairy standards and modernize
point.”
marketed in the United the standards framework.
States and sold throughout
the world.” Press Release about IDFA’s Public Meeting testimony:
IDFA’s testimony will continue to urge FDA to consider
the principles of the 2006 GMA petition. These six
principals would accommodate many of the changes
that the dairy and food industry are seeking in
standards modernization such as… the addition of mold
inhibitors to all types of cheeses… salt substitutes for
lower sodium cheese… the use of ultra-filtered and
micro-filtered milks in cheese making and other dairy
products…

August 2020 Page 101

 Selected IDFA comments at the 9/2019 FDA Public
Meeting:
…There's lots of different types of yogurt. There's
French-style yogurt, there's Greek yogurt, there's
Aussie yogurt. All of those products have to meet the
yogurt Standard of Identity. They are in compliance…
I'm not going to comment on cheese. We don't have a
position yet on that related to minimum milkfats...
we're very happy to hear that the long-pending petition
for yogurt standards modernization which doesn't even
meet NLEA standards for low fat or non-fat is moving
ahead.
And one of the things we have proposed is that rather
than having minimum milkfats for yogurt that it be based
on a total fat basis…
Because ultra-filtered milk can be a superior drinking
beverage, it could be allowed in yogurt. It is allowed, but
only at certain levels…
SOI priorities listed on IDFA website:
• Finalize updated yogurt standards by removing
milkfat minimums to allow for innovation
• Amend the cheese standards to allow manufacturers
to use fluid microfiltered milk and identify it simply as
"milk" in the ingredients
International Food 11/14/2019 YES • Restrictive SOI limit the ability of food manufacturers
Additives Council (IFAC) to take advantage of advances in science and
“IFAC supports a
technology to meet consumer preferences. For
horizontal approach
IFAC members “range example, the SOI for Colby cheese (21 CFR 133.118)
to modernizing SOI
from small to large global permits the use of optional mold-inhibiting ingredients
to allow food
companies that produce consisting of sorbic acid, potassium sorbate, sodium
manufacturers to
and/or use food sorbate, or any combination of two or more of these,
replace traditional
ingredients, including food in an amount not to exceed 0.3 percent by weight
ingredients in
additives, generally calculated as sorbic acid. Natamycin (21 CFR
certain standardized
recognized as safe 172.155), a permitted mold-inhibiting additive that
foods with food
(GRAS) substances, and may be used on other cheese products, is excluded
additives or related
microbial food cultures and from use on Colby cheese due solely to the specificity
new technologies as
probiotics.” of the standard which is not flexible enough to allow
long as the basic
for this additive which imparts the same technical
nature and essential
function. Furthermore, also related to aligning
characteristics of the
standards with the current food landscape, the
food are not
current standards of identity for yogurt, low fat yogurt,
affected.”
and non-fat yogurt do not explicitly allow for the use
of other bacterial cultures. Providing clear allowance
for the flexible use of food additives and grass
ingredients that impart the same technical functions
such as fermentation, emulsification, and stabilization
is critical to driving future innovation.
Kraft Heinz 11/12/2019 YES Kraft Heinz supports comments submitted by the
07/20/2020 International Dairy Foods Association (IDFA)
“At the outset, it’s
Manufactures leading
important to 1. A horizontal allowance for safe and suitable
brands of natural and
acknowledge that sweeteners and salt substitutes would expand
processed dairy cheese.
the current process possibilities for reducing calories, sugar, and sodium.
for adopting and 2. Flexibility to use ingredients for technical, non-
updating standards characterizing effects, such as mold inhibitors in
is not working well… cheese, would put standardized foods on the same
Four kinds of footing as non-standardized foods.
horizontal flexibility 3. Flexibility to use “alternate make” procedures would
stand out as better allow standardized foods to leverage the most
especially beneficial and efficient manufacturing technologies
promising:” available, just as non-standardized foods are able to do
today.
4. Flexibility to use alternate technologies to
manufacture already permitted ingredients

August 2020 Page 102

Lifeway Foods, Inc. 11/12/2019 YES The cultured milk standard of identity governing Lifeway
Kefir is significant outdated and inflexible… Section
“Take a horizontal
Lifeway Foods claims to 131.112 requires those products to be labeled as
approach to food
be “the largest cultured low-fat milk, which they are not, or even more
standard
manufacturer of Kefir in unwieldy and just as incorrect as Kefir-cultured low-fat
modernization and
the United States.” milk or Lassi-cultured low-fat milk… we also continue to
adopt a “default
endorse the broad concepts of the 2006 Citizen Petition
rule” regulatory
submitted by GMA and IDFA…”
regime like the one
implemented in the Lifeway strongly encourages FDA to:
European Union”
• Release Clarifying Guidance on Kefir and Traditional
Dairy Products
• Reexamine the Food Industry’s 2006 Citizen Petition
and Consider Legislative Changes to Streamline
Updates to Food Standards
National Family Farm 11/14/2019 NO • Some farmers have raised concerns about the
Coalition (NFFC) possibility of allowing the use of standardized terms
“Consumers as well
with plant-based qualifiers to describe certain foods…
as producers could
“Since 1986, National Although most consumers likely know that almonds,
be negatively
Family Farm Coalition has soy, and oats do not produce milk or cream, and that
impacted by FDA's
been mobilizing family rice is not derived from cauliflower, it seems
proposed changes,
farmers and ranchers to disingenuous to farmers whose farms have long
in part due to a
achieve fair prices, vibrant provided real fluid milk and many varieties of rice.
horizontal update of
communities, and healthy • Innovations in the dairy industry, including low-fat
standards of identity
foods free of corporate for specific foods yogurt, ultra-filtered (UF) milk and milk protein
domination.” concentrates (MPCs), should be scrutinized for safety
under the guise of
and nutritional content. However, NFFC is also asking
'nutrition innovation'”
that FDA consider aspects other than nutrition when
“In summary, we making changes to standards of identity, such as the
urge the FDA… to negative effects of allowing wider use of milk proteins
avoid broad, on dairy farmers' pay price. The amount of milk
horizontal changes displaced by milk protein concentrates and UF milk is
to standards of difficult to determine since Federal Milk Marketing
identity for entire Orders do not collect data on their production. [We
categories of food.” understand that MPC and UF milk are now being
used in all four classes of milk products, and that
cheese manufacturers profit when MPC and UF milk
is used for production than when cheese is
manufactured by traditional methods.]
National Milk Producers 03/31/2019 NO • The citizen petition submitted on behalf of the
Federation (NMPF) 11/12/2019 National Milk Producers Federation (NMPF) requests
“Horizontal
06/25/2020 that the Commissioner take actions to address:
Standards are
NMPF “was organized in 1. Enforce existing “imitation” labeling requirements
Unnecessary”
1916 to provide a forum for 2. Amend FDA regulations to codify policies that
dairy producers and the “Innovation has permit the name of standardized dairy foods (as
cooperatives they own to continued to happen listed above), to be used in the statement of
participate in public policy in the food industry identity of a non-dairy substitute “only under
discussions.” without changing the limited and defined conditions.”
standards of • NMPF agrees with FDA that the current lowfat and
identity. For nonfat yogurt standards should be revoked, similar to
example, the yogurt what was done with the milk standard of identity back
category has in the 1990’s.
continued to • NMPF agrees that removing the current requirement
expand, while there to fortify to specific levels of Vitamin A & D is
are only standards appropriate. However, the requirement for nutritional
of identity for yogurt, equivalence for lower fat versions should remain.
low fat yogurt and • NMPF also agrees with many of the proposed
nonfat yogurt. changes that allow for appropriate technological
Greek, Icelandic, advances... These include allowing for: any
French, and others appropriate bacterial culture; safe and suitable
have continued to sweeteners, including non-nutritive sweeteners; safe
enter the yogurt and suitable stabilizers and emulsifiers; and safe and
category while all suitable preservatives…
still meeting the

August 2020 Page 103

 standard of Policy statement on NMPF website:
identity… because NMPF vehemently supports federal standards of
the standard sets identity that have existed since the mid-20th century to
the minimum for a maintain the integrity of food products. The federal
product to be called definition of “milk” dictates that the product must have
‘yogurt’ but does not come from a lactating animal. Today, many imitation
limit innovation.” dairy beverages skirt these regulations and continually
label their products using dairy terms and imagery when
these items are not at all similar to real cow’s milk.
These products can be sold, but they should be
renamed so that consumers better understand the
differences between these imitations and real dairy
products. Dairy terms such as “milk” (or “cheese”,
“yogurt”, “ice cream”) should be used for dairy foods...
Complementing our efforts to fight fake milk is the
DAIRY PRIDE Act. The legislation… further prods the
FDA to take action against plant-based imitators of milk,
cheese, butter and other products that brazenly flout
FDA rules…
National Yogurt 10/11/2018 Unspecified Below are elements of a standard of identity for yogurt
Association (NYA) that were in NYA’s original petition and that we still
support today
Note: IDFA acquired NYA • Yogurt should contain a minimum combined level
in January 2019. (107 CFU/g) of the characterizing live and active
cultures
• FDA should eliminate the 3.25% milkfat minimum
requirement
• The list of basic dairy ingredients should be expanded
to include ultra-filtered (UF) milk and skim milk
powder
• The use of any safe and suitable sweeteners should
be allowed in yogurt.
• Milk-derived ingredients should be permitted to be
added after culturing if the dairy ingredients are
pasteurized
Nestlé U.S. 11/12/2019 YES • Allow the addition of safe and suitable ingredients,
where appropriate, for technical and sensory effects;
“FDA should expand
Nestlé’s Nesquik is the top • Allow the use of advanced technologies or more
the use of horizontal
shelf stable ready-to-drink approaches to efficient technologies to produce ingredients/products;
(RTD) dairy milk brand. modify SOls to:” • Permit improvements to nutritional profiles that do not
rise to the level of a defined nutrient content claim;
• Expand use of milk and milk derived ingredients in
standardized dairy products (i.e., ultra-filtered milk,
milk protein concentrate, etc.).
Plant Based Foods 11/12/2019 YES • PBFA urges the agency to create a regulatory
Association (PBFA) 6/25/2020 landscape that fosters innovation.
“PBFA urges the
agency to adopt a • PBFA urges the agency to avoid an over-reliance on
PBFA “was founded in nutritional equivalence as the marker by which
horizontal approach
2016 to build a strong changes in standards of identity should be measured.
to standards of
foundation for the plant- Many consumers are seeking out plant-based milks
identity that allows
based foods industry… and other animal alternatives to avoid certain
for labels that are
[PBFA] has grown to 170 components such as saturated fat and cholesterol.
clear, transparent,
member companies.” • PBFA suggests that FDA take an approach that
and descriptive.”
answers one essential question: Is the label truthful
Note: PBFA and non-misleading? The Nutrition Facts panel,
released voluntary combined with the required Statement of Identity,
standards for plant- already provide ample information.
based milk in July
2018 and for plant-
based yogurt in May
2020 to “promote
consistency in
labeling.”

August 2020 Page 104

Wisconsin Cheese Makers 10/9/2018 Unspecified • Modernizing standards of identity offers the
Association (WCMA) opportunity to include of new types of milk to be noted
in the definition of Milk in CFR Title 21, Part 133
WCMA “represents more Cheese and related cheese products [CFR Title 21
than 100 dairy processing Part 133.3 (a) Milk]. Namely, ultrafiltered milk and
companies and microfiltered milk, produced from simple, mechanical
cooperatives operating filtration of milk, should be included in this definition…
across the United States Codifying the addition of both ultrafiltered milk and
and around the world, microfiltered milk to the definition of Milk in CFR Title
backed by more than 575 21, Part 133 Cheese and related cheese products,
companies that supply would recognize advances in technology with the
equipment and services to potential to yield better, more consistent cheeses, and
the industry.” reduce the need for costly dairy plant expansions
costs borne by dairy farmers, dairy manufacturers
and consumers alike…

August 2020 Page 105

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 Appendix A: Front Product Images of Leading PBDA “Milk” Brands
See accompanying file.

August 2020 Page 110

 Appendix B: Detailed Nutritional Profiles of Selected Dairy Milk and PBDA “Milk” Products
• A review of selected nutrient ranges* of fluid white dairy milks and a sample of 60 PBDA “milks” from leading brands** found that many products
meet at least one nutrient standard for milk substitutes in the USDA National School Lunch Program (NSLP) and School Breakfast Program
(SBP); however, only one of the 60 PBDA beverages in this sample – Silk Original Soy Soymilk – meets all nine of these nutrient standards.
Product Calories Protein Calcium Magnesium Phosphorus Potassium Riboflavin Vitamin B12 Vitamin A Vitamin D Total Sugar
(kcal) (g) (mg; % of (mg; % of (mg; % of (mg; % of (mg; % of (mcg; % of (mcg RAE; (mcg; % of (g)
new DV) new DV) new DV) new DV) new DV) new DV) % of new DV) new DV)
Cow’s milk: ranges for 4 USDA 83.6-149 8.14- 306-325; 24- 29.4-30.8; 251-263; 374-411; 0.322- 1.34-1.50; 79.7-203; 2.39-2.77; 12-12.4
Foundation Food fluid white milks*** 8.44 25% 7% 20-21% 8-9% 0.344; 56-63% 9-23% 12-14%
25-26%
Milk, whole, 3.25% fat, with added 149 8.14 306 29.6 251 374 0.344 1.34 79.7 2.39 12
Vitamin D***
Milk, reduced fat (2%), with added 122 8.23 309 29.4 252 390 0.336 1.35 203 2.77 12
Vitamins A and D***
Milk, lowfat (1%), with added Vitamins 106 8.32 310 29.5 253 391 0.344 1.50 143 2.61 12.2
A and D***
Milk, fat free or skim, with added 83.6 8.44 325 30.8 263 411 0.322 1.43 157 2.71 12.4
Vitamins A and D***
Milk substitutes: USDA nutrient NS 8 276; 21% 24; 6% 222; 18% 349; 7% 0.44; 34% 1.1; 46% 150; 17% 2.5; 13% NS
standards in the NSLP / SBP
Almond-based beverages: ranges 35-100 0-4 70-450; 15-20; 20-30; 40-220; NS Claims 50% 0-270; 0-5; 0-19
for 15 sample products 5-35% 4-5% 2%-Claims 1-5% 0-30% 0-25%
20%
Almond Dream Unsweetened Almond 50 1 Claims 30% NS Claims 20% NS NS Claims 50% Claims 30% Claims 25% <1
Drink
Blue Diamond Almond Breeze 100 1 450 20 30 220 NS NS 150 5 19
Chocolate Almondmilk
Blue Diamond Almond Breeze Vanilla 80 1 450 15 20 170 NS NS 150 5 13
Almondmilk
Blue Diamond Almond Breeze Hint of 60 1 450 15 20 170 NS NS 150 5 8
Honey Vanilla Almondmilk
Blue Diamond Almond Breeze 30 1 450 15 20 160 NS NS 150 5 0
Unsweetened Original Almondmilk
Califia Farms Original Almondmilk 60 1 450 NS NS NS NS NS 0 NS 5
Califia Farms Unsweetened 35 1 450 NS NS NS NS NS 0 NS 0
Almondmilk
Pacific Foods Organic Almond Vanilla 70 1 NS NS NS 108 NS NS NS 2 10
Pacific Foods Organic Unsweetened 40 1 NS NS NS NS NS NS NS 2 0
Almond Vanilla
Silk Unsweet Vanilla Almond 30 1 450 NS NS 170 NS NS 150 2.5 0
Almondmilk
Silk Less Sugar Vanilla Almondmilk 45 0 450 NS NS 140 NS NS 150 2.5 6
So Delicious Dairy Free Unsweetened 30 0 450 NS NS 0 NS NS 150 2.5 0
Almondmilk Beverage
Private Label (Target): Good & Gather 60 1 450 NS NS 160 NS NS 150 2.5 7
Original Almond Almondmilk
Private Label (Target): Simply 35 1 350 NS NS 40 NS NS 270 3.4 0
Balanced Unsweetened Vanilla
Almondmilk Non-Dairy Beverage
Private Label: Trader Joe’s Simply 100 4 70 NS NS 120 NS NS NS 0 <1
Almond Beverage
Soy-based beverages: 100-140 6-10 276-450; 40-50; 80-280; 300-380; 0.4-0.5; 1.2-3; 90-150; 3-6; 6-9
ranges for 4 sample products 20-35% 10-15% 6-22% 6-11% 31% 50-125% 10-17% 15-30%
Soy Dream Enriched Original Soymilk 100 7 Claims 30% Claims Claims 15% NS NS Claims 50% Claims 10% Claims 25% 6
15%
Silk Original Soy Soymilk 110 8 450 50 220 380 0.4 3 150 3 6
Silk Vanilla Soy Soymilk 100 6 450 40 80 300 0.4 3 150 3 9
Pacific Foods Ultra Soy Original Plant- 140 10 276 61 280 512 0.5
Based Beverage
Coconut-based beverages: 45-90 0-1 16-460; 35; 80-250; 300-380; 0.4; 0.9-3; 90-150; 3-6; 0-8
ranges for 6 sample products 0-35% 8% 6-20% 6-8% 31% 38-125% 10-17% 15-30%
Califia Farms Unsweetened Organic 90 1 16 NS NS 51 NS NS NS 0 1
Coconut Homestyle Nutmilk
Coconut Dream Vanilla Enriched 90 0 Claims 30% NS NS NS NS Claims 25% Claims 10% Claims 25% 8
Coconut Drink
Coconut Dream Unsweetened Coconut 60 0 Claims 30% NS NS NS NS Claims 25% Claims 10% Claims 25% <1
Drink
Silk Original Coconut Coconutmilk 70 0 460 NS NS 170 NS 0.9 180 2 5
So Delicious Dairy Free Original Sugar 45 0 130 35 NS 40 NS 3 140 2.5 0
Free Coconutmilk Beverage
Private Label (Wal-Mart): Great Value 50 1 340 NS NS 60 NS NS 270 3.4 0
Unsweetened Coconutmilk Non-Dairy
Beverage
Oat-based beverages: 70-170 1-8 110-595; NS 40-270; 40-475; 0.1-0.6; 0.2-2.4; 90-280; 0-5.1; <1-20
ranges for 10 sample products 8-46% 4-22% 0-10% 8-46% 8-100% 10-31% 0-26%
Califia Farms Vanilla Protein Oat + 140 8 595 NS NS 475 NS NS NS 5 3
Omega 3 & Calcium
Dream Oat Beverage Unsweetened 70 1 300 NS 40 40 NS 0.6 90 5.1 <1
Dream Oat Beverage Chocolate 170 3 300 NS 120 220 NS 0.6 90 5.1 20
Oatly! Oatmilk 120 3 350 NS 270 390 0.6 1.2 160 3.6 7
Oatly! Lowfat Oatmilk 90 3 350 NS 270 390 0.6 1.2 160 3.6 7
Planet Oat Extra Creamy Original 120 2 350 NS NS 410 0.1 0.2 180 4 5
Oatmilk
Planet Oat Original Oatmilk 90 2 350 NS NS 400 0.1 0.2 180 4 4
Silk Oat Yeah Chocolate Dairy-Free 120 2 460 NS NS 170 0.33 2.4 230 4 13
Oatmilk
Silk Oat Yeah Vanilla Dairy-Free Oatmilk 80 2 460 NS NS 190 0.33 2.4 230 4 6
Private Label: Trader Joe’s Non-Dairy 90 2 110 NS 100 150 0.49 0.9 280 2.9 9
Oat Beverage
Cashew-based beverages: 45-120 0-2 21-450; 40; NS 30-130; NS 3; 140-150; 2.5; 0-16
ranges for 4 sample products 2-35% 10% 1-3% 125% 16-17% 13%
Califia Farms Unsweetened Organic 120 2 21 NS NS 71 NS NS NS 0 1
Cashew Homestyle Nutmilk
Pacific Foods Cashew Original 80 1 44 NS NS NS NS NS NS NS 6
Silk Chocolate Creamy Cashew 90 1 450 NS NS 130 NS NS 150 2.5 16
Cashewmilk
So Delicious Dairy Free Unsweetened 45 0 130 40 NS 30 NS 3 140 2.5 0
Cashewmilk
Pea-based beverages: 70-140 8-10 450-471; NS NS 330-451; NS 2.5-2.7; 110-112; 4-6; 0-15
ranges for 5 sample products 35-36% 7-10% 105-113% 12% 20-30%
Bolthouse Farms Unsweetened Non- 90 10 450 NS NS 330 NS 2.7 110 4 0
Dairy Plant Protein Milk
Bolthouse Farms Original Non-Dairy 110 10 450 NS NS 330 NS 2.7 110 4 5
Plant Protein Milk
Ripple Original Unsweetened Nutritious 70 8 465 NS NS 451 NS 2.5 110 6 0
Plant-Based Milk
Ripple Vanilla Nutritious Plant-Based 120 8 470 NS NS 450 NS 2.5 112 6 12
Milk
Ripple Chocolate Nutritious Plant-Based 140 8 461 NS NS 449 NS 2.5 110 6 15
Milk

August 2020 Page 112

 Flax-based beverages: 50-60 0-8 280-310; NS 130-210; 0-20; NS 1.3-1.4; 130-140; 2.2-2.3; 0-7
ranges for 2 sample products 22-24% 10-17% 0% 54-58% 14-16% 11-12%
Good Karma Original Flaxmilk 50 0 280 NS 130 0 NS 1.3 130 2.2 7
Good Karma Vanilla Unsweetened 60 8 310 NS 210 20 NS 1.4 140 2.3 0
Flaxmilk + Protein
Plant-based beverage blends: 25-130 1-10 0-470; 10-15; 20; 30-470; 0.35; 3.31; 135-250; 2-5; 0-12
ranges for 8 sample products 0-36% 2-4% 2% 1-10% 27% 138% 15-28% 10-25%
Blue Diamond Almond Breeze 25 1 450 10 20 160 NS NS 150 5 0
Unsweetened Original Almondmilk
Cashewmilk Blend
Blue Diamond Almond Breeze 40 1 450 15 20 170 NS NS 150 5 0
Unsweetened Vanilla Almondmilk
Coconutmilk Blend
Blue Diamond Almond Breeze 80 2 450 10 20 470 NS NS 150 5 12
Almondmilk Blended with Real Bananas
Califia Farms Toasted Coconut 45 1 Claims 45% NS NS NS NS NS 0 NS 0
Almondmilk Blend
Silk Unsweet Almond Coconut 35 1 460 15 NS 30 NS NS 135 2 0
Almondmilk and Coconutmilk
Silk Original DHA Omega-3 Oat and 60 6 470 NS NS 340 0.35 3.31 250 4 4
Almond Pea, Oat and Almondmilk
Silk Original Protein Almond and Cashew 130 10 450 NS NS 80 NS NS NS 2.5 2
Pea, Almond and Cashewmilk
So Delicious Dairy Free Organic Vanilla 50 1 0 NS NS NS NS NS 0 NS 5
Almondmilk with Cashew
Rice-based beverages: 70-130 1 Claims NS 0-claims 15% NS NS NS 0-claims 10% NS-claims <1-12
ranges for 2 sample products 2-25% 25%
Rice Dream Classic Vanilla Rice Drink 130 1 Claims 2% NS NS NS NS NS 0 NS 12
Rice Dream Enriched Original 70 1 Claims 25% NS Claims 10% NS NS Claims 25% Claims 10% Claims 25% <1
Unsweetened Organic Rice Drink
Hazelnut-based beverages: 30-130 1-2 123; NS NS 118-253; NS NS NS 2; 16
ranges for 2 sample products 9% 2-5% 10%
Pacific Foods Hazelnut Chocolate 130 2 123 NS NS 253 NS NS NS 2 0-16
Pacific Foods Hazelnut Unsweetened 30 1 NS NS NS 118 NS NS NS NS 0
Original
Hemp-based beverages: 60-170 3-4 257-263; 57-67; NS 100-150; NS NS NS 2; 0-15
Ranges for 2 sample products 20% 14-16% Claims 2-3% 10%
Pacific Foods Hemp Vanilla 170 4 263 67 NS 150 NS NS NS 2 15
Pacific Foods Unsweetened Hemp 60 3 257 57 NS 100 NS NS NS 2 0
Vanilla
*per 8-ounce serving; Calories, Protein, Calcium (new DV 1300 mg), Magnesium (new DV 420 mg), Phosphorus (new 1250 mg), Potassium (new 4700 mg), Riboflavin (new DV 1.3 mg), Vitamin
B12 (new DV 2.4 mcg), Vitamin A (new DV 900 mcg RAE) and Vitamin D (new DV 20 mcg). Sources include Mintel’s Global New Products Database; USDA FoodData Central (note: not all
nutrient values provided by LabelInsight are available and/or current); brand/company websites accessed 4/2020
**IRI, U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience
Stores. Excludes natural and specialty gourmet channels. Cited by IRI in The Surge of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods, 11/19/2019;
The Good Food Institute, 2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy, 5/2020
***USDA FoodData Central, Foundation Food average nutrient values
Additional Notes:
• New FDA Daily Values are rounded percentages for adults and children ≥ 4 years.
• NS = not stated on nutrition label. The U.S. FDA’s new Nutrition Facts Label (NFL) does not require reporting magnesium, phosphorus, riboflavin or vitamins A or B12 levels
• Between 2009 and 2019, approximately 100 companies collectively launched 457 new liquid PBDA "milk" products/varieties (branded and private label) in the U.S. According to
Mintel’s Global New Products Database, 8% of the 24 products launched in 2009 listed claims of low/reduced sugar or no added sugar, compared to 38% of the 55 products launched
in 2019 that listed the same claims.

August 2020 Page 113

 Appendix C: Front Product Images of Leading PBDA “Yogurt” Brands
See accompanying file.
 Appendix D: Detailed Nutritional Profiles of Selected Dairy Yogurt and PBDA “Yogurt” Products
• Nutrient values posted on brand websites and Mintel’s Global New Products Database were identified for two samples of product types:
o Plain/unsweetened: 12 dairy yogurt and nine PBDA “yogurts” – categorized by traditional and Greek varieties
 The Greek varieties in the sample contain significantly more protein than their traditional counterparts; the traditional PBDA
“yogurts” contain less sugar than the traditional dairy yogurts; and the traditional PBDA “yogurts” have a wider range of calcium
and potassium levels than dairy yogurts.
o Sweetened: Nine dairy yogurt and 13 PBDA “yogurts” – categorized by traditional and Greek varieties
 These Greek varieties also contain significantly more protein than their traditional counterparts; several of the traditional PBDA
“yogurts” contain less sugar than the traditional dairy yogurts; and these traditional PBDA “yogurts” also have a wider range of
calcium and potassium levels than dairy yogurts.
o Each of the PBDA “yogurts” analyzed – 22 products across eight brands – claim live and active cultures on their product labels, with S.
Thermophilus, L. Bulgaricus, L. Acidophilus, and Bifidobacteria among the most common strains.
PLAIN/UNSWEETENED Yogurt Calories Fat Protein Calcium Potassium Riboflavin Vitamin Vitamin A Vitamin D Total Claim Live & Active
Product (kcal) (g) (g) (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg RAE; (mcg; % Sugar Cultures?
new DV) new DV) new DV) % of new % of new of new (g)
DV) DV) DV)
Dairy yogurt: ranges for 6 sample products 70-120 0-6 6-8 220-320 290-390 NS NS NS 0-1.9 7-10 Yes (100%)
(170 mg serving)
Dannon Plain Whole Milk Yogurt 110 6 6 230 290 NS NS NS 0.4 7 Yes
365 Everyday Value Organic Plain Whole 120 6 6 220 290 NS NS NS 1.9 7 Yes
Milk Yogurt
Dannon Plain Lowfat Yogurt 110 2.5 8 310 380 NS NS NS 0 10 Yes
Stonyfield Organic Plain Lowfat Yogurt 90 1.5 7 260 340 NS NS NS 1.9 9 Yes
Dannon Plain Nonfat Yogurt 80 0 8 320 390 NS NS NS 0 10 Yes
Stonyfield Organic Plain 0% Fat Yogurt 70 0 7 260 360 NS NS NS 1.9 9 Yes
GREEK Dairy yogurt: ranges for 6 sample 90-170 0-9 14-17 90-190 110-240 NS NS NS 0-2 2-5 Yes (100%)
products (170 mg serving)
Chobani Whole Milk Plain Greek Yogurt 170 9 16 169 230 NS NS NS 0 4 Yes
Stonyfield Organic Greek Whole Milk Plain 150 6 16 170 200 NS NS NS 0.9 5 Yes
Yogurt
Chobani Low-Fat Plain Greek Yogurt 130 3.5 17 175 240 NS NS NS 0 4 Yes
Two Good Plain Greek Lowfat Yogurt 90 2 14 90 110 NS NS NS 2 2 Yes
Chobani Nonfat Plain Greek Yogurt 90 0 16 187 250 NS NS NS 0 4 Yes
Stonyfield Organic Greek 0% Fat Plain 90 0 16 190 240 NS NS NS 0.9 5 Yes
Yogurt
PBDA “yogurt”: ranges for 7 sample 80-190 4-15 0-8 64-488 0-440 NS 0.9-1.7 NS 0-8 0-6 Yes (100%)
products (170 mg serving)
Daiya Plain Yogurt Alternative 150 9 6 302 143 NS 1.1 NS 2 3 Yes (L. Plantarum, L.
Casei)
Kite Hill Plain Unsweetened Almond Milk 140 12 5 64 158 NS NS NS 0 1 Yes (S. Thermophilus, L.
Yogurt Bulgaricus, L. Acidophilus,
Bifidobacteria)
Forager Project Plain Unsweetened Coconut 170 11 8 22 157 NS NS NS 0 1 Yes (S. Thermophilus, L.
& Cashew Yogurt Alternative Bulgaricus, L. Acidophilus,
Bifidus, L. Lactis, L.
Plantarum)
Kite Hill Blissful Plain Unsweetened Creamy 110 8 0 488 90 NS 0.9 NS 8 0 Yes (S. Thermophilus, L.
Coconut Milk Yogurt Bulgaricus, Bifidobacteria,
L. Acidophilus)
PLAIN/UNSWEETENED Yogurt Calories Fat Protein Calcium Potassium Riboflavin Vitamin Vitamin A Vitamin D Total Claim Live & Active
Product (kcal) (g) (g) (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg RAE; (mcg; % Sugar Cultures?
new DV) new DV) new DV) % of new % of new of new (g)
DV) DV) DV)
Silk Plain Soymilk Yogurt Alternative 110 4 7 260 440 NS NS NS 2.2 5 Yes (S. Thermophilus, L.
Bulgaricus, L. Acidophilus,
Bifidobacterium spp.)
Silk Plain Almondmilk Yogurt Alternative 190 15 6 Claims 8% Claims 4% NS NS NS Claims 4% 6 Yes (S. Thermophilus, L.
Bulgaricus, L. Acidophilus,
Bifidobacterium spp.)
So Delicious Dairy Free Unsweetened Vanilla 80 5 <1 390 0 NS 1.7 NS 2.6 1 Yes (S. Thermophilus, L.
Coconutmilk Yogurt Alternative Rhamnosus, L.
Acidophilus, L. Bulgaricus,
Bifidobacterium spp., L.
Casei, L. Paracasei, L.
Plantarum)
GREEK PBDA “yogurt”: ranges for 2 160 10 11 121 87 NA NS NS 0 2 Yes (100%)
sample products (150 mg serving)
Kite Hill Plain Unsweetened Almond Milk 160 10 11 121 87 NS NS NS 0 2 Yes (S. Thermophilus, L.
Greek Style Yogurt Bulgaricus, L. Acidophilus,
Bifidobacteria)
Kite Hill Vanilla Unsweetened Almond Milk 160 10 11 121 87 NS NS NS 0 2 Yes (S. Thermophilus, L.
Greek Style Yogurt Bulgaricus, L. Acidophilus,
Bifidobacteria)

SWEETENED Yogurt Product Calories Fat Protein Calcium Potassium Riboflavin Vitamin Vitamin A Vitamin D Total Claim Live & Active
(kcal) (g) (g) (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg RAE; (mcg; % Sugar Cultures?
new DV) new DV) new DV) % of new % of new of new (g)
DV) DV) DV)
Dairy yogurt: ranges for 4 sample products 100-140 0-7 5-7 180-200 240-280 NS NS 0 1.4-1.6 14-22 Yes (100%)
(150 mg serving)
Dannon Vanilla Low-Fat Yogurt 140 7 7 Claims 25% NS NS NS 0 NS 22 Yes
Stonyfield Organic Vanilla Whole Milk Yogurt 140 5 5 180 240 NS NS NS 1.6 15 Yes
Stonyfield Organic Vanilla Lowfat Yogurt 110 1.5 6 200 270 NS NS NS 1.5 14 Yes
Stonyfield Organic Blueberry on the Bottom 100 0 6 200 280 NS NS NS 1.4 16 Yes
0% Fat Yogurt
GREEK Dairy yogurt: ranges for 5 sample 110-140 0-4.5 11-15 150 200 NS NS NS 0-1.6 12-16 Yes (100%)
products (150 mg serving)
Dannon Oikos Vanilla Nonfat Greek Yogurt 110 0 12 Claims 10% Claims 2% NS NS NS Claims 8% 15 Yes
Dannon Activia Strawberry Nonfat Greek 120 0 12 150 200 NS NS NS 1.6 16 Yes
Yogurt
Chobani Vanilla Nonfat Greek Yogurt 110 0 12 Claims 10% Claims 4% NS NS NS 0 12 Yes
Chobani Banana & Cream Whole Milk Greek 140 4.5 11 Claims 10% Claims 4% NS NS NS 0 12 Yes
Yogurt
Yoplait Vanilla Greek 100 Nonfat Yogurt 100 0 15 Claims 10% Claims 4% NS NS NS Claims 10% 7 Yes
PBDA “yogurt”: ranges for 11 sample 80-190 0-7 <1-6 40-350 0-270 NS 1.27-1.30 NS 0-6 4-18 Yes (100%)
products (150 mg serving)
Stonyfield Organic Vanilla Dairy Free Yogurt 130 2.5 6 110 270 NS NS NS 0 18 Yes (S. Thermophilus, L.
(with soy milk) Bulgaricus, L. Acidophilus
and Bifidus)
So Delicious Dairy Free Triple Berry Oatmilk 80 0 3 130 100 NS 1.27 NS 2 8 Yes (S. Thermophilus, L.
Yogurt Alternative Bulgaricus,
Bifidobacterium, L.
Acidophilus)
So Delicious Dairy Free Vanilla Coconutmilk 130 4 <1 260 0 NS 1.3 NS 2.1 17 Yes (S. Thermophilus, L.
Yogurt Alternative Rhamnosus, L.
Acidophilus, L. Bulgaricus,
Bifidobacterium spp., L.

August 2020 Page 116

SWEETENED Yogurt Product Calories Fat Protein Calcium Potassium Riboflavin Vitamin Vitamin A Vitamin D Total Claim Live & Active
(kcal) (g) (g) (mg; % of (mg; % of (mg; % of B12 (mcg; (mcg RAE; (mcg; % Sugar Cultures?
new DV) new DV) new DV) % of new % of new of new (g)
DV) DV) DV)
Casei, L. Paracasei, L.
Plantarum)
Silk Oatyeah Vanilla Oatmilkgurt 80 0 3 Claims 10% Claims 2% NS Claims 50% NS Claims 10% 9 Yes (S. Thermophilus, L.
Bulgaricus, L. Acidophilus,
Bifidobacterium spp.)
Silk Vanilla Almondmilk Yogurt Alternative 190 11 5 Claims 10$ Claims 4% NS NS NS Claims 6% 17 Yes (S. Thermophilus, L.
Bulgaricus, L. Acidophilus,
Bifidobacterium spp.)
Silk Vanilla Soymilk Yogurt Alternative 140 3.5 6 Claims 15% Claims 8% NS NS NS Claims 10% 16 Yes (S. Thermophilus, L.
Bulgaricus, L. Acidophilus,
Bifidobacterium spp.)
Kite Hill Blissful Salted Caramel Creamy 140 6 1 350 75 NS NS NS 6 13 Yes (S. Thermophilus, L.
Coconut Milk Yogurt Bulgaricus, Bifidobacteria,
L. Acidophilus)
Forager Project Vanilla Bean Cashewmilk 140 6 3 Claims 2% 0 NS NS NS 0 12 Yes (S. Thermophilus, L.
Yogurt Bulgaricus, L. Acidophilus,
Bifidus, L. Lactis, L.
Plantarum)
Good Plants Almondmilk Probiotic Yogurt 100 4 5 40 240 NS NS NS 0 4 Yes (L. Bulgaricus, S.
Alternative Thermophilus, B. Lactis)
Daiya Vanilla Bean Yogurt Alternative 170 7 6 266 124 NS NS NS 2 13 Yes (L. Plantarum, L.
Casei)
Siggi’s Vanilla & Cinnamon Plant Based 190 11 10 0 Claims 2% NS NS NS 0 9 Yes (S. Thermophilus, L.
Coconut Blend Delbrueckii subsp.
Bulgaricus, L. Plantarum,
L. Acidophilus, B. Lactis)
GREEK PBDA “yogurt”: ranges for 2 180-190 9 10 104-105 77-81 NS NS NS 0 12 Yes (100%)
sample products (150 mg serving)
Kite Hill Blueberry Almond Milk Greek Style 190 9 10 105 77 NS NS NS 0 12 Yes (S. Thermophilus, L.
Yogurt Bulgaricus, L. Acidophilus,
Bifidobacteria)
Kite Hill Strawberry Almond Milk Greek Style 180 9 10 104 81 NS NS NS 0 12 Yes (S. Thermophilus, L.
Yogurt Bulgaricus, L. Acidophilus,
Bifidobacteria)

August 2020 Page 117

 Appendix E: Front Product Images of Leading PBDA “Cheese” Brands
See accompanying file.
 Appendix F: Detailed Nutritional Profiles of Dairy Cheese and PBDA “Cheese”
• A review of nutrient values* in selected dairy cheeses and a sample of 20 PBDA “cheese” from leading brands** revealed that dairy and plant-
based varieties contain similar calorie ranges and no Vitamin D.
o Overall, dairy varieties tend to contain higher protein, calcium and Vitamin A levels than non-dairy varieties.
o The sampled dairy and non-dairy varieties contain a similar range of sodium levels, except for cashew “cheese,” which contains less.
Product Calories Protein Calcium Magnesium Phosphorus Potassium Riboflavin Vitamin B12 Vitamin A Vitamin D Sodium
(kcal) (g) (mg; % of (mg; % of (mg; % of (mg; % of (mg; % of (mcg; % of (mcg RAE; (mcg; % (mg; % of
new DV) new DV) new DV) new DV) new DV) new DV) % of new of new new DV)
DV) DV)
Dairy cheese: ranges for 6 45-110 6-9 180-250; NS NS 0; NS NS 60-100; 0; 180-280;
products from leading brands** 14-19% 0% 4-11% 0% 8-12%
Kraft and Sargento
Kraft Fat Free Shredded 45 9 250 NS NS 0 NS NS 60 0 280
Mozzarella Natural Cheese (28g)
Sargento Shredded Whole Milk 90 6 Claims NS NS NS NS NS Claims 4% NS 190
Mozzarella Natural Cheese (28g) 10%
Sargento Shredded Reduced Fat 70 8 Claims NS NS NS NS NS NS NS 210
Mozzarella Natural Cheese (28g) 15%
Kraft Mild Cheddar 2% Milk 90 7 190 NS NS 0 NS NS 80 0 230
Finely Shredded Natural Cheese
(28g)
Kraft Fat Free Natural Cheddar 45 9 250 NS NS 0 NS NS 100 0 280
Cheese (28g)
Sargento Shredded Mild Natural 110 7 Claims NS NS NS NS NS Claims 6% NS 180
Cheddar Cheese (28g) 15%
Cashew-based “cheese”: 70-110 1-4 0-10; NS NS 30-90; NS NS NS 0; 75-120;
ranges for 4 sample products 0% 0-2% 0% 3-5%
Miyoko’s Organic Cultured Fresh 70 1 3 NS NS 30 NS NS NS 0 120
Vegan Mozz (28g)
Miyoko’s Organic Cultured Vegan 110 3 10 NS NS 90 NS NS NS 0 105
Cheese Wheel Garlic Herb (28g)
Treeline Plain Cashew Cream 90 4 0 NS NS 50 NS NS NS 0 75
Cheese (28g)
Treeline Strawberry Cashew 90 3 10 NS NS 40 NS NS NS 0 75
Cream Cheese (28g)
Almond-based “cheese”: 70 2-6 28; NS NS 72; NS NS NS 0; 200-210;
ranges for 2 sample products (1 0-Claims 1.5% 0% 9%
contains casein) 20%
Kite Hill Plain Cream Cheese 70 2 28 NS NS 72 NS NS NS 0 200
Alternative (33g)
Lisanatti Foods The Original 70 6 Claims NS NS NS NS NS NS NS 210
Almond Mozzarella Style Block 20%
(28g) ) – contains casein
 Soy-based “cheese”: 70-90 1-5 9; NS NS 41; NS NS NS 0; 150-290;
ranges for 3 sample products (1 0-Claims 1% 0% 7-13%
contains casein) 20%
Lisanatti Foods SoySation 70 5 Claims NS NS NS NS NS NS NS 210
Mozzarella Style Shreds (28g) – 20%
contains casein
Tofutti Mozzarella Dairy Free 80 2 NS NS NS NS NS NS NS NS 290
Cheese Slices (19g)
Follow Your Heart Cheddar 90 1 9 NS NS 41 NS NS NS 0 150
Cheese Alternative, Made With
Soy (28g)
Rice-based “cheese”: 60-70 5-6 Claims 20- NS NS NS NS NS NS NS 190-210;
ranges for 2 sample products 31% 8-9%
(both contain casein)
Lisanatti Foods RiceCheeze 70 5 Claims NS NS NS NS NS NS NS 210
Mozzarella Style Chunk (28g) – 20%
contains casein
Lisanatti Foods RiceCheeze 60 6 Claims NS NS NS NS NS NS NS 190
Snack Sticks (1 stick) – contains 31%
casein
“Cheese” with multiple plant- 60-90 0-1 0-Claims 0 NS 0-27; NS 0.7; 0; 0; 95-280;
based ingredients: 30% 0% 29% 0% 0% 4-12%
ranges for 9 sample products
Daiya Original Mozzarella Style 90 1 Claims 2% NS NS NS NS NS 0 NS 280
Shreds (28g)
Daiya Cutting Board Collection 80 0 152 NS NS 19 NS NS NS 0 230
Mozzarella Style Shreds (28g)
Daiya Strawberry Cream Cheeze 70 0 10 NS NS 27 NS NS NS 0 95
Style Spread (30g)
Follow Your Heart Mozzarella 80 0 234 NS NS 11 NS NS NS 0 280
Shreds (28g)
Field Roast Creamy Original 60 0 NS NS NS NS NS NS NS NS 180
Vegan Chao Slices (20g)
Go Veggie Classic Plain Vegan 80 1 Claims 4% NS NS NS NS NS 0 NS 115
Cream Cheese (30g)
Go Veggie Vegan Cheddar Style 90 0 Claims NS NS NS NS NS 0 0 280
Shreds (28g) 30%
Violife Just Like Mozzarella 80 0 0 0 NS 0 NS 0.7 NS 0 190
Shreds (28g)
Violife Just Like Cream Cheese 70 0 0 0 NS 0 NS 0.7 NS 0 140
Original (30g)

*per serving; Calories, Protein, Calcium (new DV 1300 mg), Magnesium (new DV 420 mg), Phosphorus (new 1250 mg), Potassium (new 4700 mg), Riboflavin (new DV 1.3 mg), Vitamin B12
(new DV 2.4 mcg), Vitamin A (new DV 900 mcg RAE) Vitamin D (new DV 20 mcg) and Sodium (new DV 2300 mg). Sources include Mintel’s Global New Products Database; brand/company
websites accessed 7/2020
**IRI, U.S. MULOC $ sales for 52 weeks ending 10/6/2019 in Multi Outlet Channels (Food/Grocery; Drug; Mass; Walmart; Club, excluding Costco; Dollar; Military DECA) plus Convenience
Stores. Excludes natural and specialty gourmet channels. Cited by IRI in “The Surge of Plant-Based Foods: Overview of Driving Forces Behind the Growth of Plant-Based Foods,” 11/2019; The
Good Food Institute, “2019 State of the Industry Report: Plant-Based Meat, Eggs and Dairy,” 5/2020
Additional Notes:
• New FDA Daily Values are rounded percentages for adults and children ≥ 4 years.
• NS = not stated on nutrition label. The U.S. FDA’s new Nutrition Facts Label (NFL) does not require reporting magnesium, phosphorus, riboflavin or vitamins A or B12 levels

August 2020 Page 120

Appendix G: Commercial Processing of Dairy Protein Ingredients vs.
Plant-Based Protein Ingredients
• Rohit Kapoor and Hari Meletharayila, researchers with Dairy Management Inc. (DMI), presented at the
American Dairy Products Institute’s (ADPI) Virtual Joint Annual Conference in July 2020.
o The scientists presented a summary of findings from a scientific literature review conducted by
RTI Innovation Advisors which was funded by the National Dairy Council, Dairy Management, Inc.
o See also the U.S. Dairy Export Council Research Brief at
https://www.thinkusadairy.org/Documents/Customer%20Site/C6-News%20and%20Events/C6.2-
Events/2020%20Research%20Brief%20Protein%20Processing%20(FINAL).pdf.
o Selected slides:
August 2020 Page 122
August 2020 Page 123
August 2020 Page 124