Should the Word 'Milk' Be Used To Describe Nondairy Milk-Alternative Products? (arstechnica.com) 520
An anonymous reader quotes a report from Ars Technica: The U.S. Food and Drug Administration seems to have soured on nondairy milk-alternative products that use the term "milk" in their marketing and labeling -- like popular soy and almond milk products. In a talk hosted by Politico, FDA Commissioner Scott Gottlieb announced Tuesday that the FDA will soon issue a new guidance on the use of the term. But he added that products aren't abiding by FDA policies as they stand now. He referenced a so-called "standard of identity" policy that regulates how milk is defined and should be identified. "If you look at our standard of identity -- there is a reference somewhere in the standard of identity to a lactating animal," he said. "And, you know, an almond doesn't lactate, I will confess."
He went on to explain that the issue is that the agency hasn't been enforcing its own policy or putting the squeeze on product makers -- and that it's time to get abreast of the labeling language. But, he admitted, curtailing the wording of non-moo juice labeling isn't an easy task because it means that the agency has to change its "regulatory posture." "I can't just do it unilaterally," Gottlieb said. Hence, the agency is putting together a new guidance for manufacturers to help skim the fat from the market. Gottlieb said the agency will soon tap the public for comments on the terminology and hopes to wring out a new policy within a year.
He went on to explain that the issue is that the agency hasn't been enforcing its own policy or putting the squeeze on product makers -- and that it's time to get abreast of the labeling language. But, he admitted, curtailing the wording of non-moo juice labeling isn't an easy task because it means that the agency has to change its "regulatory posture." "I can't just do it unilaterally," Gottlieb said. Hence, the agency is putting together a new guidance for manufacturers to help skim the fat from the market. Gottlieb said the agency will soon tap the public for comments on the terminology and hopes to wring out a new policy within a year.
Coconuts (Score:5, Informative)
Re:Coconuts (Score:5, Interesting)
WHO picked THAT name?!!! (Score:5, Funny)
Re:Coconuts (Score:5, Informative)
Coconut water is the water inside a coconut.
Coconut milk is the result of putting the white coconut flesh trough a blender and straining it.
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So is coconut cream the stuff left over when they make skimmed coconut milk?
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But you buy Coconut water in stores. This isn't about what you call it, it's about what you market it to be.
Almonds don't have nipples, so we should just call it what it is: Nut-juice. Or Nut-squeezins.
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Going the other way with it, we could start calling mammalian lactation products "tit-milk"
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No, the word originally referred to the hand motion of milking a mammal.
Coconut juice is not milk and never was (Score:5, Informative)
The 'juice' inside a coconut has always been called milk AFAIR. It's a natural thing to do, to extend the use of a word to cover something 'similar'.
It's not similar and just because something has been done a certain way doesn't make it accurate. If it comes from a plant it is by definition not milk. Milk is a substance secreted by mammals to feed their young. If it doesn't come from a mammal it isn't milk. If it comes from a plant it is juice. So the accurate term is coconut juice.
We do it all the time, and in the case of these products which are pitched as cow's mile replacements, there seems even more reason to do so.
Just because something is a substitute doesn't mean you should call it something different than what it actually is. Margarine is (sometimes) a butter substitute but we don't call it butter. If it is a liquid derived from a plant then it is (generally) supposed to be called juice. Nothing wrong with saying coconut juice or soy juice or almond juice. Just coloring something white doesn't make it milk.
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Don't overcomplicate things (Score:3, Interesting)
While I agree that "we've always done it this way, so we should keep doing it this way" is not an argument,
Correct.
your entire argument seems to be "because 'we've always done it this way, so we should keep doing it this way' is not an argument, we should not keep doing it that way".
You got yourself twisted up in your knickers there trying to pretend you are smart. We already have a perfectly adequate word for consumable liquids derived from plants. We call it juice. Marketing people keep trying to pretend that plant juice somehow becomes milk if it happens to be (or is made to be) white. If it didn't come from a mammal then it by definition is not milk and no amount of marketing BS will make it so. Call products what they are and life is a lot simpler.
Re:Don't overcomplicate things (Score:5, Insightful)
Almond milk is no more juice than it is milk. It doesn't come from a fruit, and it's not pressed out of a plant as a liquid. It is a white mixture of protein and fat suspended in a liquid, and in that regard is much more like milk than juice. Just because the marketing department came up with a sensible thing to call a product, doesn't mean they are conniving to deceive anybody.
Next thing you know, people will be all pissed off because peanut butter isn't really butter. When it comes to names we have given things, "we have always done it that way" is a perfectly cromulent argument. If everybody knows what almond milk is, then changing the name to something else will cause more confusion, not less.
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Language is an example of when "we've always done it this way, so we should keep doing it this way" holds weight though. Of the words have always been used a way, I don't see how anyone can make an argument that that's not what they mean. Obviously one needs to allow for linguistic shift, but certainky if a word has been used in a way for decades it doesn't make sense to by dictate change its meaning.
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The term milk, in the context of food, has been applied to many things other than mammary gland products for a very long time.
For that matter, the cow milk you buy in the supermarket really isn't raw milk. It's a processed product made from milk. If you set a glass of freshly milked cow milk, right from the udder, in front of the average person and they'll be anything but pleased.
All of the above, though, is completely pointless because this topic has nothing to do with definitions of what milk is. That's j
Re: Coconut juice is not milk and never was (Score:5, Informative)
[[Citation Needed]]. A quick check of the best references I have available says the typical level for cow's milk is 4%. It varies by breed, but even the richest breeds, like Jersey, have just a bit above 5%. 8% is what you'd expect from something like water buffalo milk, which is the richest of any of the animals humans regularly use as a milk source.
That's not to say that "whole" milk is whole. As I understand it, typical milk processing involves separating the fat from the rest of the milk and then recombining it at specified levels to create a standardized product. So "whole" milk will always be 4% fat, even if it comes from a breed that naturally produces more fat than that; the rest of the fat is removed for products like cream and butter.
Acid Test (Score:5, Informative)
The problem is language is fluid. It's been called coconut milk for centuries. Changing it to coconut juice would be more confusing than leaving it alone.
I think the important thing here is the modifier. As long as you are calling it "Almond Milk" or "Soy Milk" it would be pretty obvious to the average consumer that it isn't dairy milk, especially as the already common term "Coconut Milk" is in use.
Doing this is common in many languages. German is famous for mashing existing words together to make new ones.
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Yes, had this very same argument with some locals. Farmers/Beef-industry/diary ... getting all upset about this topic, meanwhile the megacorp supermarkets drive them to the wall at the gate with the absurdly low payouts for their produce. Not like changing the definition / criterion is going to suddenly improve their profit margins, if anything this will just alienate more people.
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I disagree that "language is fluid" because while it's kinda true in a very specific way, it really, really isn't true in most other considerations. Changes to language happen, but it doesn't mean they should be adopted into permanence. In fact, here are a bunch of words that have been invented or whose definitions are in flux because some people want to control others:
Mansplaining: Defined as the the condescending explanation of a concept from a man/male to a woman/female. This word was intentionally creat
Re:Acid Test (Score:4, Insightful)
Queer was once a word for odd or strange. Then it became a slur toward non-heterosexuals. Now it's something the once slurred community has taken ownership of.
It still means odd or strange. That's why it was used as a description for homosexuals.
Read Shakespeare and apply modern meanings to the words. Lots of things will break, or tragedies will gain comedic value.
Uh, many of them were intentionally written that way. Hell, Shakespeare created many words in order to get a lot of sex jokes in.
The meaning of "knowing" someone has definitely changed since the King James Bible. How many people do you "know"?
No, the meaning of knowing someone hasn't changed. The Bible's "knowing" of someone referred to carnal knowledge. The word didn't mean something different back when that version of the Bible was written, the Bible merely euphemized fucking.
Bad. Yes, the word bad. Which still means bad, but under the correct circumstances can be good. For instance, "bad ass", which actually can also mean two things.
No, bad still means bad. Even in Michael Jackson's song/video, it meant bad. It's use as a positive adjective doesn't come from a negation of the meaning of "bad", but from the perspective of people seeing things that are morally bad as positive. A bad knee is a bad knee, and that's good to no one. A bad dude is a bad dude to all, but to other bad dudes that's a good thing.
This is the reality. It causes the legal system lots of problems, frankly, because it's hard to legislate a natural cognitive process. Also, it's hard to legislate around a natural cognitive process.
It's not a natural cognitive process, however. You have to learn these specific words and how to use them. And we've been dealing with how people use words for a long time. If you say something and you use the wrong words, you're incorrect or lying. We're not asking if a hot dog is a sandwich or not, we're asking if non-milk things can be called milk.
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I never claimed that words lost their old meanings. To be clear, they've mostly gained new ones which have displaced their old meanings in regular use. Languages evolve, both grammatically and in word meaning. Most words start as either slang or loan words. Further, you're confusing vocabulary (symbols chosen for ideas) with language (the use of symbols to represent thought). Symbols get re-purposed.
We have new words for new things, but we also have old words for new things. Which type of mouse you referenc
By Definition? (Score:5, Informative)
By Definition? The number two definition of milk from Websters is "a liquid resembling milk in appearance: such as a) the latex of a plant b) the contents of an unripe kernel of grain."
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By Definition? The number two definition of milk from Websters is "a liquid resembling milk in appearance: such as a) the latex of a plant b) the contents of an unripe kernel of grain."
What kind of balderdash shit is this?
Noun:
1: A thing that is the thing.
2: A thing that is not the thing, but looks like the thing.
I guess counterfeit money is money!
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Here's a list of things you should fight next:
Peanut butter
Almond butter
Cocoa butter
Cream of Wheat
Grape Nuts
Milk of Magnesia
Good luck with that!
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says the guy who calls all non-government rockets "SpaceX"
Who exactly are you referring to. Sure as hell isn't me because I've never said anything of the sort.
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"There's no such thing as soy milk. It's soy juice. But they couldn't sell soy juice, so they called it soy milk. Because anytime you say soy juice, you actually... start to gag."
Re: Coconut juice is not milk and never was (Score:5, Informative)
Canola is genetically modified rapeseed.
It's not genetically modified, it's just a cultivar of rapeseed that is naturally low in erucic acid.
Canada selected for it, they didn't "modify" it.
Then they gave it a different name (CAN[adian] O[il] L[ow] A[cid]), probably for sales reasons.
There is a GM variant of Canola oil, but that's the evil, rapist, version made by Monsanto.
https://en.wikipedia.org/wiki/Canola_oil [wikipedia.org]
Re: Coconut juice is not milk and never was (Score:4)
Thank you for
A) Distinguishing between selective breeding and genetic modification, because those are two totally different things that are often conflated, and for
B) Teaching me that "Canola" is actually an acronym, Never knew that before today.
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Exactly what I came here to reply with. That product has been around for decades, and suddenly the FDA has an issue? Sounds to me like some dairy lobbyists have succeeded in pushing their agenda.
Re:Coconuts (Score:5, Interesting)
I want to know if they’re also going after peanut butter, which may be something spread on bread but isn’t a substitute for dairy butter in any other application (just in case anyone was thinking of using it to reenact the scene from Last Tango In Paris).
Lol. They're already picky about peanut butter (Score:3)
That's funny.
Actually they have a strict definition of what is peanut butter and what isn't. In the store, next to the peanut butter, you'll see cheaper "peanut spread". This is because the nutritional value of peanut butter is well known (high protein along with sugar, which is fine for growing kids), while the nutritional value of the cheaper peanut spread may be very different.
Re:Coconuts (Score:5, Interesting)
I want to know if they’re also going after peanut butter
When I was a kid in Western Australia, we had "Peanut Paste".
The dairy lobby had successfully lobbied for a ban on the use of "butter" for non-dairy products.
https://en.wikipedia.org/wiki/... [wikipedia.org]
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“Pulse paste” would work better for the catchy alliteration, but unfortunately a “pulse paste sandwich” sounds more like something that happens in the bathrooms at gay bars than something you want in your mouth...
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Re: Soyboys (Score:2)
But enough talk! Have at you!
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Is it clearly a metaphor or simile? (Score:2)
If no, then it should not be allowed to describe a non-dairy product.
Re:Is it clearly a metaphor or simile? (Score:5, Insightful)
I think it would be fair to call non-dairy from vegetable matter milk, milk just as long as it can be used as a replacement for dairy milk.
A protein rich fluid, either from an animal, or from plant matter, if can be used for similar food preparations. Say for baking could safely be considered Milk. just as long as it is noted that it is non-dairy and from what type of plant, as to help people avoid allergic reactions. As a lot of non-dairy milk comes from nuts and seeds which some people have allergic relations too, (As some people have an allergy to Milk (Allergy vs intolerance))
Re:Betteridge's Law (Score:4, Insightful)
"No, [Betteridge's law doesn't apply here]. This is an actual, legitimate question.
As I correctly predicted [earlier that same year] [slashdot.org], lots of Slashdotters have seized upon Betteridge as the latest fad kneejerk response, and are misapplying it without understanding what it means. In his own words [wikipedia.org], Betteridge's Law applies to cases where journalists "know the story is probably bollocks, and don’t actually have the sources and facts to back it up, but still want to run it."
For example, without the evidence to back it up, a headline saying "Tomato ketchup caused AIDS that led to exitinction of dinosaurs" would be obvious crap and lead to criticism of the paper and/or journalist. OTOH, "Did Tomato ketchup cause AIDS that led to the extinction of the dinosaurs?" gives them the weasellish get-out of "Well, we didn't actually *claim* that it did".
Even then, if a question headline was a genuine attempt to present a plausibly-supported but not universally-accepted idea (possibly because it was new and/or divisive), then Betteridge's wouldn't apply.
In short, Betteridge's original observation was insightful where he claimed it applied, but it was never a blanket dismissal of question headlines, so please stop the tedious, kneejerk misapplication."
I vote for (Score:5, Funny)
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"Almond Flesh Cocktail"
How about "Modified Sweat Gland Secretion"?
Finally! (Score:4, Funny)
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With any hint of luck, we could get the idiots that think that relabeling a condition changes the condition to jump on this and make room for people who actually could work on changing the condition.
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With any hint of luck, we could get the idiots that think that relabeling a condition changes the condition to jump on this and make room for people who actually could work on changing the condition.
There are some folks in this world who want to spend endless time cleaning up their little corner of the room, endlessly shuffling and re-arranging things in order to make their corner perfect.
While ignoring the mess outside their precious corner.
And there are matters under the jurisdiction of the FDA that are a damn sight more important than making people aware that almond milk is not cow milk. Trying to tidy up that corner while allowing whacked out dietary aids that show obviously photoshopped befo
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Because different groups of people can't work on different things simultaneously?
No, because making pointless rulings is pointless. I wonder how many people are confused by almond milk or coconut milk? After all - where are the tits on almonds? And in old movies Hawaiian ladies work coconut bras - but no, the milk from that coconut wasn't the same thing as the milk from what the coconut was hiding.
And everyone knew it, everyone knows it now, and I would be surprised if anyone will ever confuse it with the liquid expressed from the modified sweat glands of mammals.
Pointless rulings
I'm so glad (Score:5, Funny)
What a time to be alive.
Re:I'm so glad (Score:5, Interesting)
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So... People are stupid and don't want to learn, so let's dumb down products so stupid, ignorant people can remain in that state?
You know, Idiocracy was not supposed to be an utopian movie...
Re:I'm so glad (Score:5, Informative)
It's not only that people are stupid. It's important that you can't sell ground rat and call it ground beef. Some enforcement is welcome, and it shouldn't be up to the consumers to investigate every single item in the store to determine whether they really are what they say they are.
Re:I'm so glad (Score:4, Insightful)
Almond and soy milk are sold as cow milk? That's outrageous!
No, wait... almond milk is actually called almond milk, and soy milk gets sold as soy milk. It's not even "milk". It's without fail sold with the qualifier "almond" or "soy".
And sorry, if people are too stupid to know that you don't squeeze cows and milk almonds, I have very, very little sympathy for them.
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Well, I'm a bit torn. On one hand, yeah, you're 100% correct. On the other hand, stupid, ignorant people die when food labels aren't idiot proof.
There was a news story just this week of a teenager with a deathly peanut allergy. Always ate Chips Ahoy in the red package because it was safe. Went to a friend's house and that same package had "with Reeses Pieces bites" slapped all over the sides, but she just saw the familiar color, and slammed down a couple of cookies. Couple minutes later her throat starts cl
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Well, I'm a bit torn. On one hand, yeah, you're 100% correct. On the other hand, stupid, ignorant people die when food labels aren't idiot proof.
You're not exactly helping your argument...
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No (Score:2, Informative)
Experts have already talked about this... (Score:2)
There is no such thing as soy milk... it's soy juice.. [youtube.com]
A better description (Score:2, Funny)
If it doesn't have pus, steroids, and anti-biotics in it, it's not milk.
Re:No (Score:5, Informative)
English is seldom as precise as we programmers would like to make it. "Bread" is defined as "flour, water and yeast" ... but various breads are made without yeast ... and bread is used generically for food (dating back to hebrew/biblical usage), not to mention using the term to describe money.
Given that the various soy and nut milks have been in use (and named) since the 13th (other sources, 17th) centuries, it seems to me that the horse left this barn a long time ago.
Melk (Score:2)
Non-dairy milk alternatives have an easy solution. Adopt the midwest's pronunciation and just call it "melk". Easy enough, right?
Soon! (Score:2, Funny)
"And, you know, an almond doesn't lactate, I will confess."
With CRISPR, I'm sure that will change soon enough...
It depends (Score:2)
Milking it (Score:4, Insightful)
Why, yes, yes it is.
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The U.S. Food and Drug Administration seems to have soured
putting the squeeze on product makers
time to get abreast of the labeling language
to help skim the fat from the market
will soon tap the public for comments
and hopes to wring out a new policy within a year
Burma Shave
milk gets used in different contexts as well (Score:2)
Personally, I'd be a little terrified to meet the mammal that secretes milk glass. Fortunately, the FDA probably won't come after that one, as if you're eating milk glass, you have other more serious problems that need immediate attention.
Could pureed clams be called "Milk" (Score:2)
I think calling all white liquids that can be swallowed as milk, problematic
Unintended consequences (Score:3)
Will they have to change the name of milk of magnesia?
Milk of Magnesia is a trademark in some places (Score:3)
In some countries, Bayer still owns trademarks on "Aspirin" and "Milk of Magnesia". In these countries, the generic name for liquid magnesium hydroxide suspension is "cream of magnesia".
malk Now With Vitamin R! (Score:2)
malk Now With Vitamin R!
sick (Score:2)
better-than-milk (Score:4, Insightful)
Milky Way Bar (Score:5, Funny)
The Milky Way is a millenium old trickery to confuse people about the nature of our Galaxy. This should be stopped! Not only Mars Inc., but astronomers have more recently abused common sense with their Milky Way Bar...
Be consistent (Score:2)
Also, the word "blog" should not be used for non-diary products.
Peanut butter (Score:2)
If you English speaking people can call peanut paste "peanut butter" then I don't see why you couldn't call stuff that resembles milk "milk" ;-)
(Note in Dutch we call it peanut cheese :p)
Why not? (Score:2)
What other verb is so descriptive of providing something of not much value apart from fad hype to consumers at a premium price?
Oh wait, you are referring to the suspension of fat particles in water. Never mind...
What can we argue next? (Score:2)
Shall we decree what we call Coke and Pepsi? Is it "pop", "cola", "soda", "soda pop", "soft drink", or just plain "coke"? My guess is government regulations will mandate it be labeled as "Carbonated water with flavoring".
So, can I have a "Carbonated water with cola flavoring from the Coke Classic recipe with rum" for me and a "cow sourced dairy product that has been reduced to 2% dairy fat, homogenized, pasteurized and has had sweetened chocolate flavoring added" for the kid here.
Seriously, this is stup
"Business friendly" regulation... (Score:2)
The point of standard of identity regulations is so that consumers aren't fooled into buying one thing when they think they are buying another. It's consumer-friendly regulation. It prevents companies from selling margarine as "butter".
But "soy milk", "almond milk" and "coconut milk" are the proper English names for those things; everybody knows they don't come out of a cow -- in fact that's the whole point of those products. So why is the administration looking at this question?
It's the kind of regulato
Milk is milk (Score:2)
Noodles, "Alimentary Paste" (Score:3)
The FDA defines "noodles" as a product made from wheat flour and eggs, neither of which Asian cuisines use in their noodles, so for many years they had to be called "alimentary paste" in the grocery store. But when you went to an Asian restaurant you got "noodles" (of course the same product).
Eventually the FDA relented and allowed them to be called "Asian noodles".
Perhaps we can call these products "vegan milk" (though this is really no different from the more specific "soy milk", etc.)?
The difference of course is there are no "noodle producers" associations of industrial farmers whose primary product are noodles.
Rename milk (Score:3)
Call it animal udder secretion and he how the kids will love to drink that.
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Out of curiosity: What name should we instead give to peanutbutter?
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Underground legume paste.
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Obviously peanut paste. Now what do we do with toothpaste?
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in your heart, you know it's true (Score:3)
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What about baby oil?
Or... well... hemorrhoid cream?
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Nobody is conflating peanut butter for real butter (Score:3)
Out of curiosity: What name should we instead give to peanutbutter?
I don't see that as a problem since nobody is trying to pretend that peanut butter is somehow a substitute for actual butter. People try all the time to pretend that soy milk and cow's milk are interchangeable when they really aren't.
Re:Nobody is conflating peanut butter for real but (Score:4, Insightful)
Well, you can cook with both of them, put them on your cereal, and drink them. How are they not interchangeable?
Re:Milk comes from a mammal - Juice from a plant (Score:5, Insightful)
Re:Milk comes from a mammal - Juice from a plant (Score:4, Insightful)
Unless it comes from the mammary gland of a mammal then by definition it is not milk.
Actually, the definition of "milk" includes any liquid resembling the opaque white liquid secreted by mammary glands of female mammals. When you claim that something is so "by definition", maybe you should look it up, just to be sure.
Re:Milk comes from a mammal - Juice from a plant (Score:5, Interesting)
Re:Milk comes from a mammal - Juice from a plant (Score:4, Insightful)
This is nothing but marketing bullshit intended to confuse customers into believing they are somehow substitute products when they aren't and do not share the same properties.
Seriously?! You think anyone has ever been fooled into thinking non-dairy milks are actually milk? They'd have to be much stupider even than the average consumer.
Calling them "milks" (always with a modifier to make clear they are not milk, e.g. "soy milk" or "almond milk"--NO ONE calls their non-dairy milk simply "milk") helps people to understand that they are similar, and that they may be useful as a substitute for the thing they are being compared to.
What's far more problematic than non-dairy milk substitutes comparing themselves to dairy milk as an accompaniment to cold cereal or beverages (but never claiming equivalence to milk) is companies such as Nestle which throw massive marketing efforts behind convincing mothers that fake milk (aka a synthetic "formula") is superior to their own, true milk, which as you correctly observe can only come from the mammary gland of a mammal (and ideally one of the same species as the infant that's consuming it).
I too have a habit of wanting to take things very literally, and can relate to your having a pet peeve about language.
But the word "milk" and the adjective "milky" have been used to describe so many things that aren't produced by mammals--think coconut milk, milkweed, milk of magnesia, milk thistle, milk paint (yes, usually actually made with dairy milk), milk glass (milky-colored; not glasses for milk), ... that I hardly think this is a fight worth fighting.
Unless you're the dairy industry, of course. Then, you have big money to lobby the government to change widely-understood and accepted language in hopes of making dairy substitutes less attractive and marketable to your customers. Especially when you have a government in power that is actually even more friendly to massive, well-established "homeland" industries than those of decades past.
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This is a truly stupid argument, but if we truly HAVE to pacify a bunch of sociopathic pedants, how about we define something called an NDMS (Non-Dairy Milk Substitute)? Will THAT make these flakes happy?
Would I put soy-NDMS or almond-NDMS in my coffee? Sure. Occasionally anyway.
If so, we can move on to what to do about Milk of Magnesia.
Re:Waste of time (Score:4, Informative)
Not really. Food classification has a lot of ramifications on how it is treated in terms of regulations, taxation, global trade...
Such as the 1890 Nix v. Hedden case where a Tomato should be considered a vegetable. Its trading status of a vegetable meant it could be shipped for less, because it was considered a more essential food for trade, vs fruit which is considered more for dessert type foods.
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They have flavored Seltzer Water that we don't call pop. They are technical beers and wines called hard drinks,
If it is from a cow it is called dairy.
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The fact that the dictionary itself can’t even define the non-dairy definition of “milk” without referring to actual milk should tell you something about what the word inherently means. Here’s DuckDuckGo’s suggested definition [slashdot.org]:
A liquid, such as coconut milk, milkweed sap, plant latex, or various medical emulsions, that is similar to milk in appearance.
But you see the same thing happening in other dictionaries as well, nearly all of which define “milk” in terms of its resemblance to actual milk:
https://www.merriam-webster.co... [merriam-webster.com]
https://www.thefreedictionary.... [thefreedictionary.com]
https://medical-dictionary.the.. [thefreedictionary.com]
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What do you call a tennis score of 40-40?
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Certainly. As long as Surfactants isn't shortened to Surf. Might cause consumers to think the product is a suntan lotion.