Any ingredient that is made from or containing mammal milk. The Food and Drug Administration (FDA) does not have an official explanation. The UDSA defines milk as "Food products made exclusively or principally from the lacteal secretion obtained from one or more healthy milk-producing animals…… (21 CFR 1240.3(j))." Typically, when we think of dairy, we think of cow’s milk. But dairy can also include milk from a goat, sheep, camel, mare, donkey, buffalo, etc. Often eggs are found in or near the dairy section; however, most milk producing mammals do not lay eggs. Eggs come from chickens, ducks, etc. – birds.
What is Dairy Free?
Any ingredient that is made without ingredients from mammal’s milk. An ingredient that comes from milk cannot be included.
What is non-Dairy?
The FDA did create a regulation to define this many years ago. The regulation stated that a product labeled as non-dairy can contain .5% or less milk by weight, in the form of casein / caseinates (milk protein). This term was added because the Dairy industry did not want consumers confused between dairy substitutes and real dairy products like cream and milk. Non-dairy ingredients can be found in creamers and cheese. Alissa Fleming, who created GoDairyFree.ORG, reached out to the FDA and received a response in 2019 indicating: We do not have a definition for the term [nondairy] in our regulations for food labeling. However, we do not consider the terms “nondairy” and “dairy free” to be equivalent. We have interpreted the term “dairy free” as meaning the complete absence of all dairy ingredients including lactose, etc. The term “nondairy” refers to products, such as nondairy whipped topping and nondairy creamers, that may contain a caseinate milk derivative.
What is in mammal’s milk?
When we think of milk, we usually refer to cow’s milk. Harvard.edu and Milkfacts.info indicate that cow’s milk contains mostly water (87%). It also includes protein, fat, carbohydrates (lactose), vitamins, and minerals. Harvard noted that cows are often pregnant while they are milked and most likely contain hormones like insulin-like growth factor-1 (IGF-1), estrogens, and progestins.
The National Library of Medicine (NIH) indicates that cow’s milk contains more than 25 proteins. Two of those proteins have the potential to cause allergic reactions. They are whey and casein.
Casein is the curd that forms when milk is left to sour.
Whey the watery part that is left after the curd is removed.
A food allergy is an abnormal response or reaction to certain proteins in food. This is not the same as a food intolerance, although the symptoms can be similar. Allergic reactions can range from mild symptoms, like a rash or swelling to a severe life-threatening symptom called anaphylaxis.
The immune system sends out Immunoglobulin E or IgE antibodies. Immunoglobulins are molecules produced by white blood cells that help your body defend against infections and cancer. Their primary function is to bind to foreign cells like bacteria and viruses. This binding helps neutralize the foreign cell and signals to your white blood cells to destroy them. These two groups of immune reactions are categorized as food allergies:
· Immunoglobulin E (IgE) – is a rapid immune response that can be triggered by food. This is an immediate reaction. Some of the symptoms include vomiting, anxiety, hives, rash, difficulty breathing, swelling, itching, anaphylaxis and death. These antibodies are the body’s primary immune response against a foreign substance. The antibody is the body’s red flag that something is attacking the body. It triggers a histamine release from white blood cells to trigger allergic reactions. The immune system is trying to protect the body; however, instead it causes harm.
· Immunoglobulin G (IgG) – this is a more delayed and potentially more mild immune response that can be triggered by food. Symptoms can impact the body within an hour or a day or can take up to three days. The symptoms can be the same as IgE; however, the immune reactions are slower and show with greater focus on the digestive tract and gut health.
Immune reactions to food are very important. The immune response leads to inflammation. These immune reactions can affect your mood, your digestion, your energy, your clarity of thought, your skin, your neurological system, your musculoskeletal system… just about anything you can image.
There are some tests to take to help determine if you are allergic to dairy (or other ingredients). When we are not feeling well, we expect answers quickly. However, some tests take longer than others. Be cautious of the option you select and ask what side effects may occur and the reactions your body may experience. Please seek medical advice before undergoing any type of allergy testing as they could have a negative impact on you. Do NOT try these tests without consulting with an expert.
· Elimination Test: The food in question (dairy) is temporarily removed from the diet to see if the symptoms stop. It is recommended to keep a journal of the foods you eat and keep track of any symptoms you feel a few weeks before you start this process and during this process. This option does take time and patience and food labels must be closely reviewed. The recommended period of elimination can vary anywhere from two weeks, one month, or longer depending on the doctor. The doctor may recommend, under their supervision, re-introducing the food to see if the symptoms come back. The doctor may also determine reintroducing the food is not required and/or not recommended based on the reactions and details noted in your journal.
· Skin Prick Test (SPT): The specialist places a drop of liquid on the skin of your arm or back. The liquid contains a protein from a specific food that may trigger an immune reaction. The provider will prick the skin under the drop so the liquid gets below the surface. Then you'll wait for 15 to 30 minutes. If a red, itchy bump forms, you may have an allergy to that food. More than one food protein may be tested. This test is administered by a medical provider and it not recommended if the allergy is life threatening.
· Atopy Patch Test (APT): this is similar to the SPT test. A large patch is put on the skin with the potential allergen on it. The patch is left on 48 hours to help identify the allergic reactions. This may not help with non-IgE mediated milk allergy and is not recommended if the allergy is life threatening.
· RAST (radioallergosorbent test): this is a blood test that measures IgE antibodies. If you have a food allergy, your levels of IgE related to that food may be higher than normal. The amount of IgE in your blood can't confirm a food allergy or tell you how serious an allergy may be as this test can produce false positives. You may need other tests to confirm a food allergy.
· ELISA (enzyme-linked immunosorbent assay): This test uses specialized enzymes that attach to antibodies in your blood. This blood test measures both IgE and IgG antibodies. This test may better identify delayed responses to food allergies.
· Kinesiology: Kinesiologists use muscle testing to access the client’s biofeedback system to help identify stressors, and blockages in the body. Muscle testing is the art of applying pressure to a muscle and looking for either a yes/no, or stress response with the food/allergen. If the muscle does not respond effectively, it shows the body is struggling with the food. For more information, research George J Goodheart Jr, the founder of applied kinesiology. This test indicates that the food should be eliminated; however, it does not indicate which type of allergy you have (immediate or delayed).
What is Lactose Intolerance?
Lactose intolerance is a partial or total inability to digest lactose. It is not the same as a food allergy because it is not an immune response. It is caused by a deficiency of the enzyme lactase. Lactose is “milk sugar” and is the primary carbohydrate in milk products. Lactose is broken down into glucose and galactose for proper absorption in the small intestines. Symptoms of intolerance include nausea, abdominal pain or cramps, diarrhea, gas and bloating. This occurs between 30 minutes to two hours after eating or drinking products with dairy in them. As we age, we naturally produce less lactase. Most people with this intolerance can take the enzyme and may not need to avoid dairy.
Lactose Intolerance Testing
One of the following tests can be completed:
· Hydrogen breath test. After you drink a liquid that contains high levels of lactose, your doctor measures the amount of hydrogen in your breath at regular intervals. If you breathe out too much hydrogen, it indicates that you aren't fully digesting and absorbing lactose.
· Lactose tolerance test. After you drink a liquid that contains high levels of lactose, you take a blood test for the next two to three hours. The lactase enzyme is supposed to break it down and convert it to glucose. If your glucose level doesn't rise, it means your body isn't properly digesting and absorbing the lactose.
· Stool Acidity Test: This test is used for infants and young children. Some or all of the lactose is not digested and absorbed in the small intestine and reaches the colon. This causes the stool to become acidic.
FALCPA Labeling Act
Congress passed the Food Allergen Labeling and Consumer Protection Act of 2004 – FALCPA. This law identifies eight foods as major food allergens for: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat and soybeans. On 4-23-21, the FALCPA added sesame. This law requires that foods, including dietary supplements, or ingredients that contain a major food allergen be specifically labeled with the name of the allergen source. Therefore, if the item contains any form of milk, the item must be labeled. Unfortunately, this requirement does not apply to certain meat, poultry and egg products, alcoholic beverages, drugs, cosmetics, bath products, and foods sold at retail/food service establishments that are not prepackaged.
This law only protects the consumer if the ingredient is found in the food. You may find an advisory statement such as “may contain milk” or “produced in a facility that uses milk”. These statements are not required by law and are only used if the manufacturer incorporates good processes in their facility and they have taken every precaution to avoid cross contamination that can occur in their facility on shared equipment. FDA guidance and regulations for the food industry states that advisory statements should not be used as a substitute for adhering to current good manufacturing practices and must be truthful and not misleading.
What ingredients are considered "dairy?"
Although Congress does require labeling as noted above, it is CRITICAL to always read labels and know what each ingredient listed is. GoDairyFree.org has a very nice summary of these ingredients as follows as of now. Please keep in mind that this list can change.
Definitely Dairy Ingredients
Caseinate (in general)
Cheese (All animal-based)
Condensed Milk Cottage Cheese
Dry Milk Powder
Dry Milk Solids
Half & Half
Hydrolyzed Milk Protein
Sheep Milk Cheese
Sour Milk Solids
Sweetened Condensed Milk
Whey Protein Concentrate
Whey Protein Hydrolysate
Potentially Dairy Ingredients
· Artificial or Natural Flavors/Flavoring – These are vague ingredients, which may be derived from a dairy source. A few of particular concern are butter, coconut cream, and egg flavors.
· Cultured Dextrose – To make this food preservative, dextrose is fermented. Dextrose is a simple sugar that’s usually derived from corn. The bacteria used to culture, or ferment, the dextrose can be derived from dairy. But some manufacturers of cultured dextrose no longer use a dairy medium. If the bacteria used is derived from dairy, it would need to be clearly declared as “milk” on the label.
· Fat Replacers – Brands such as Dairy-Lo® and Simplesse® are made with milk protein.
· Galactose – This is often a lactose byproduct, but it can also be derived from sugar beets and other gums.
· High Protein or Protein – Ingredients noted with no further details may be derived from milk proteins (casein or whey). This is particularly true in “High Energy” foods.
· Hydrolyzed Vegetable Protein – The processing phase may use casein, but only trace amounts would likely remain.
· Lactic Acid Starter Culture – These cultures may be prepared by using milk as an initial growth medium.
· Lactobacillus – This term is noted often as a probiotic. It is in fact bacteria, not a food byproduct, and is named as such for its ability to convert lactose and other simple sugars to lactic acid. Though often utilized in milk products to create lactic acid, on its own, this ingredient is not always a concern. However, in some cases it may have been cultured or produced on dairy, and thus have the potential to contain trace amounts.
· Margarine – Milk proteins are in most brands, though not all.
· Nisin Preparation – This is a preservative that is often made using milk.
· Prebiotics – A newcomer on the digestive health scene, these are indigestible carbohydrates. They are quite different from probiotics, which are living microorganisms. Prebiotics, such as galacto-oligosaccharides, lactosucrose, lactulose and lactitol may be derived from milk-based foods.
· Tagatose – This alternative sweetener is often derived from the lactose in dairy products. It can, however, be derived from tropical date trees.
Rarely Dairy Ingredients
· Calcium or Sodium Stearoyl Lactylate – Stearoyl lactylates are derived from the combination of lactic acid (See any potential concerns with lactic acid below) and stearic acid. They are generally considered non-dairy and safe for the lactose intolerant and milk allergic (again, see below). However, the stearic acid may be animal derived, which could be a concern for vegans.
· Calcium, Sodium, or Potassium Lactate – Lactates are salts derived from the neutralization of lactic acid, and are rarely a dairy concern. For example, it was noted that the lactate found in one brand of orange juice was made from sugar cane.
· Caramel Color – Anything with caramel in its title may sound like a dairy red flag, but caramel color is typically derived from corn syrup and occasionally from potatoes, wheat, or other carbohydrate sources. While lactose is a permitted carbohydrate in the production of caramel color, it is rarely, if ever used.
· Lactic Acid – Lactic acid is created via the fermentation of sugars, and can be found in many dairy-free and/or vegan foods. Most commercially used lactic acid is fermented from carbohydrates, such as cornstarch, potatoes or molasses, and thus dairy-free. Though lactic acid can be fermented from lactose, its use is generally (I said generally; where concerned, always check with the manufacturer) restricted to dairy products, such as ice cream and cream cheese.
Surprisingly Dairy-Free Ingredients
Cream of Coconut
Cream of Tartar
Fruit Butter (Apple, Pumpkin, etc)
Nut Butters (Peanut, Almond, etc)
Malted Barley or other Grain-Based Malts
What are some milk alternatives?
There are a number of different types of dairy-free milk beverages. It is still important to read the label, especially if you are allergic to the ingredient replacing dairy. My personal preference is to find them labeled non-GMO and/or organic. Here are a few options that you can drink as a beverage or use in recipes. Note that they are not always an even swap and you may need to play with the options in the recipe to fit your taste buds.
· Coconut milk – made from water and the white flesh of brown coconuts. Note that full-fat coconut milk is not a beverage but can be used as a replacement for heavy cream.
· Cashew milk – made with cashews and water.
· Oat milk – is a mixture of oats and water. Oat milk is naturally sweet and mild in flavor.
· Almond milk – made with whole almonds or almond butter and water. It is a slightly sweet and nutty flavor. Most brands contain less than 2% almonds.
· Flax milk – made from a combination of water, flaxseed oil, and pea protein.
· Hemp milk – made by blending hulled hemp seeds with water.
What about Butter?
Butter still does contain some milk protein and low amounts of lactose. Ghee is clarified butter that is brought to higher temperatures. Ghee may be generally safe for those with milk allergies; however, there is no guarantee that all traces of whey or casein are removed. Other options are available and will work differently in recipes.
· Earth Balance natural shortening – made from expeller non-GMO oils. There are different options available. Consult with your doctor if you should use soy.
· Coconut oil is made by by pressing fresh coconut meat or dried coconut meat called copra. Virgin coconut oil uses fresh meat, while refined coconut oil typically uses copra (dried coconut kernals).
· Palm oil is a vegetable oil that comes from the fruit of the oil palm tree.
· Grapeseed oil is a byproduct of the winemaking process of grapes.
· Hemp seed oil is manufactured from varieties of Cannabis sativa that do not contain significant amounts of tetrahydrocannabinol (THC).
· Avocado oil is the flesh, seeds, and skin of fallen avocados are pressed and then filtered to remove impurities. The amount of filtering and processing determines if the product is extra virgin with minimal processing or more refined, similar to olive oil.
What about Cheese?
Dairy free cheese has become more available and tastes good in recipes; however, it does not taste like real cheese. Some stores like Wegmans and Whole Foods allow you to return an item for no reason and still receive a refund. This is a great way to “try” the dairy free cheese to see if it works for you. You can also try a cheese from another mammal (sheep, goad, buffalo) as it may not impact you the same as cow’s milk. However, caution is advised since these are still considered dairy and you can have a severe allergy reaction to these options as well.
What is non-GMO?
Non-GMO” means non-genetically modified organisms. GMOs (genetically modified organisms) are living organisms that are artificially manipulated in a laboratory using engineering techniques. In genetic modification (or engineering) of food plants, scientists remove one or more genes from the DNA of another organism, such as a bacterium, and “recombine” them into the DNA of the plant they want to alter. By adding these new genes, genetic engineers hope the plant will express the traits associated with the genes, such as plant sustainability or improving their growth. These combinations do not occur naturally in nature or through traditional cross-breeding methods. Most GMO’s are engineered to withstand the direct application of herbicide (like Glyphosate) to protect the plant against insects. Scientists and consumer and environmental groups have cited many health and environmental risks with foods containing GMOs.
Why is it important to know if a product is non-GMO or not? Finding the perfect dairy free product means you need to know what the ingredients are and where they come from. GMO seeds are used to plant over 90% of all corn, cotton and soy crown in the US. Other high-risk crops include: alfalfa, canola, papaya, potato, sugar beet, and zucchini. The list of foods using GMO seeds is growing. There are sites that do indicate eating GMO food is safe; however, I choose to eat food created by mature and avoid . . .
Read more about this at the Non-GMO project
This label will appear to indicate it is non-GMO.
What does Organic mean
The USDA defines organic as: a labeling term that indicates that the food or other agricultural product has been produced through approved methods. These methods integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. Synthetic fertilizers, sewage sludge, irradiation, and genetic engineering may not be used.
The Organic Foods Production Act of 1990 established the National Organic Program (NOP) and its authority to enforce agricultural products sold and labeled or represented as organic. The USDA has organic standards, including prohibited practices, requirements, and the National List of Allowed and Prohibited Substances. If you see the organic label, it indicates the product is certified to have 95% or more organic content. For more information, see: https://www.ams.usda.gov/sites/default/files/media/What%20is%20Organic.pdf
What is Vegan?
A vegan is a person who does not eat any food derived from animals and who typically does not use other animal products. Why is this important? Because Vegans do not eat anything from animals, this includes milk and any kind of dairy product. If the “vegan” label is found on food, it usually means it is also dairy free. To be safe, be sure to read the label for the ingredients.
Is Calcium an issue if I stop dairy?
No. There are many other calcium rich foods such as vegetables like acorn squash, broccoli, bok choy, or grains like oatmeal, or baked beans, great northern beans, molasses, etc.
Why did I choose to go dairy free?
When I was an infant, my mother could not give me milk products and had to find other options. As a young adult, I do not recall any issues. However, over the years I noticed I was very gassy after eating dairy. I enjoyed two 16 oz glasses of milk a day plus other dairy items but couldn’t give dairy up. My weight was going up in my 40’s and I found it difficult to lose weight. But one year, I had overindulged in chocolate and lots of dairy due to stress I felt from a job. I was constipated, found it difficult to concentrate, felt lousy all the time and extremely dizzy. I also had digestive issues. I stumbled across a chiropractor who included kinesiology in her practice. I told her my symptoms. She touched my stomach and told me I had to give up dairy.
Wow was I angry. I didn't believe she really identified the true issue. But I thought, what do I have to lose. I’m going to prove her wrong! I searched the web and there wasn’t much information. But I did find GoDairyFree.org with a list of words identified as dairy…was quite a list. I found recipes on Pinterest…most were good but some were not. Initially it was very hard to come to terms that I could not eat dairy. However, I played with lots of recipes on Pinterest. I did throw out many recipes but I also found some really good tasting healthy recipes. I eventually was able to make many really good tasting recipes that my husband enjoyed as well. I always thought I was intolerant to something in dairy. However, through this research, I discovered I have a slow reacting allergy to the protein in cow’s milk. What I didn’t find was support from others. That took a long time to figure out on my own. My family and friends were not there for me and they thought it was all in my head… how could food cause issues?
In this journey, I also looked into ways to resolve the stress I was feeling, as that made my symptoms worse. This led me to the YMCA where I was already taking Yoga. I started attending Tai Chi classes which led me to some awesome positive people full of love. I opened my heart and looked into many alternative healing modalities to see how they made me feel. I found Reiki which also led me to take Yoga teacher training, which I now teach at the Y. I am also on my way to learn about sound healing with a recent purchase of singing bowls. And the journey continues…..
My hope is to help others struggling to eat dairy free and provide support and training on what it means to be dairy free. My journey is to open a Dairy Free Educational and Healing Center some day very soon. See these links:
THE CHEMISTRY OF MILK Dairy Processing Handbook (tetrapak.com).
Chris Bosch - firstname.lastname@example.org