- Butter is made from cream.
- Cream is made from milk.
- Therefore, butter contains milk.
The Food and Drug Administration thinks you’re too stupid to figure that out.
The FDA has issued a recall of about 80,000 pounds of butter for containing an “undeclared allergen,” Food & Wine reports. It’s packaged as Kirkland Signature, the Costco store brand. The FDA’s enforcement report says that the reason for the recall is that the “butter lists cream, but may be missing the Contains Milk statement.”
That statement is one of the allergen warnings that the FDA can require be printed on food products, often in capital letters, separate from the ingredients list. It’s how you get incredibly helpful product labeling like the one found on the container of cashews I keep at my desk:
Of course, the front of the container is clearly labeled “WHOLE CASHEWS” with a great big picture of cashews on it, and that’s the part that the government doesn’t mandate at all. So people who are allergic to cashews would already know. But the government requires the company to list the ingredients, which for a container of cashews is basically cashews. And just in case it wasn’t clear already that the cashews are made with cashews, the government also wants the company to write “CONTAINS: CASHEW.” (I like to think Planters was being a little cheeky by printing it directly under the ingredients list.)
The problem with the butter, which says “BUTTER” on the front next to a picture of butter, is that it didn’t also say “CONTAINS: MILK” — or at least, the FDA says it “may” be missing that statement. One would think they’d at least be sure their rule was violated before asking for 80,000 pounds of butter to be taken off the market, but the FDA generally operates under the principle of “block it now, ask questions later,” which it also applies to keeping drugs off the market that could save thousands of lives.
It is also the case that the Food and Drug Act defines “butter” as “the food product usually known as butter, and which is made exclusively from milk or cream, or both, with or without common salt, and with or without additional coloring matter, and containing not less than 80 per centum by weight of milk fat, all tolerances having been allowed for.” So it would be illegal to label the product as “butter” if it didn’t contain milk.
The FDA is not alleging that the butter is unsafe or that the company failed to list the ingredients, one of which is cream. It’s that it didn’t also say that butter contains milk. Where would we be without the FDA to look out for us?