cheese or yoghurt within the European Union because these are reserved for animal products; exceptions to this do not include tofu and soy. Although plant-based dairy alternatives are not allowed to be called "milk", "cheese" and the like, they are allowed to be described as buttery or creamy. In the United Kingdom, strict standards are applied to food labeling for terms such as milk, cheese, cream, yogurt, which are protected to describe dairy products and may not be used to describe non-dairy produce. However, there are exceptions for each of the EU languages, based on established use of livestock terms for non-livestock products. The list's extent varies widely; for example there is only one exception in Polish, and 20 exceptions in English. A proposal for further restrictions failed at second reading in the European Parliament, in May 2021. The proposal, called Amendment 171, would have outlawed labels including 'yogurt-style' and 'cheese alternative'. United States In the United States, the dairy industry petitioned the FDA to ban the use of terms like "milk", "cheese", "cream" and "butter" on plant-based analogues (except for peanut butter). FDA commissioner, Scott Gottlieb, stated on July 17, 2018 that the term "milk" is used imprecisely in the labeling of non-dairy beverages, such as soy milk, oat milk and almond milk: "An almond doesn't lactate", he said. In 2019, the US National Milk Producers Federation petitioned the FDA to restrict labeling of plant-based milks, claiming they should be described as "imitation". In response, the Plant-Based Foods Association stated the word "imitation" was disparaging, and there was no evidence that consumers were misled or confused about plant-based milks. A 2018 survey by the International Food Information Council Foundation found that consumers in the United States do not typically confuse plant-based analogues with animal milk or dairy products. As of 2021, though the USDA is investigating and various state legislatures are considering regulation, various courts have determined that reasonable consumers are not confused, and the FDA has enacted no regulations against plant-based milk labels. In 2021, the FDA issued a final rule that amends yogurt's standard of identity (which remains a product of "milk-derived ingredients"), and is expecting to issue industry guidance on "Labeling of Plant-based Milk Alternatives" in 2022. Proponents of plant-based milk assert that these labeling requirements are infantilizing to consumers and burdensome and unfair on dairy-alternatives. Critics of the FDA's labeling requirements also note that there