Today, eaters can choose from a wide variety of alternatives to traditional dairy products. Vegans and flexitarians alike can indulge their cheese or yogurt cravings with a version made from nuts, grains or legumes. More recently, a new alternative showed up on grocery store shelves: animal-free dairy products made through genetic engineering. When compared with traditional dairy or existing non-dairy alternatives, animal-free dairy is a different creature altogether.

Animal-free dairy products go by many different names. You might see them described as "whey protein," "milk-identical" or "dairy-identical" proteins made through "precision fermentation." With all the naming confusion, it's crucial to call animal-free dairy what it is: a GMO.

GMO animal-free dairy products are made through a genetic engineering technique known as synthetic biology, or "synbio." The term describes a variety of genetic engineering techniques, including genetically engineering microorganisms to produce novel compounds through fermentation. The proteins are separated from the growth medium and combined with flavorings, other proteins, colorants, texturizers, processing aids or other additives. Synbio animal-free proteins have been used to make non-dairy GMO ice cream, milk, cheese spreads and yogurt.

Real milk? No whey!

Marketing for animal-free dairy products emphasizes the similarities to traditional dairy. Nature-identical, biologically identical, molecularly identical — the industry paints it as milk without the cows. However, these claims can be inaccurate and misleading.

In 2024, the Health Research Institute (HRI) analyzed Bored Cow's animal-free dairy milk, which is made with a synbio protein marketed as a "milk-identical protein." When they compared their results to natural cow's milk, the results were striking:

• What's in synbio milk — While Bored Cow's label reads "made with milk protein," analysis revealed that most of the proteins in the finished product were fungal proteins, not dairy proteins. Natural cow's milk contains mostly whey proteins and casein proteins, not fungal proteins. The lab hypothesized the fungal proteins were likely by-products of the genetic engineering process used to make the product.
• What's not in synbio milk — Most of the nutrients found in cow's milk (think: essential amino acids, lipids, vitamins and nutrients) were absent or present in only trace amounts in Bored Cow's product.

HRI also found approximately 92 compounds that could not be identified through existing scientific literature. The unknown compounds are not only absent from natural cow's milk, they have likely never been part of the human diet.

Unregulated, unlabeled and unnatural

Despite containing fungal proteins that have never before been part of the human diet, GMO animal-free dairy products are entering the market virtually unregulated. The US Food and Drug Administration allows a company to self-determine GRAS status for ingredients. "GRAS" stands for Generally Recognized As Safe and is applied to foods that have a long history of safe consumption. For example, people have been eating oats since long before the FDA came along. With all that history behind us, oats are considered generally safe. It's the same idea here.

But there's a flaw in the logic. The companies that make animal-free dairy proteins have declared their products "generally safe" based on the idea that we've been eating natural milk proteins, whey and casein, for a long time. But the proteins in animal-free dairy aren't necessarily whey and casein. HRI's analysis of Bored Cow found that most of the proteins were fungal proteins, which don't have GRAS status. 

Synbio animal-free dairy products aren't likely to be labeled as GMOs because the GMO microorganisms used to produce animal-free proteins are supposedly removed from the final product. The 2022 Bioengineered Food labeling law only requires disclosures for food with detectable modified genetic material in the finished product (exemptions and loopholes further reduce the BE labeling law's effectiveness). To add to the confusion, animal-free dairy brands are even showing up in natural foods spaces. The synbio industry's participation at Natural Products Expo West, the premier natural products convention, sparked controversy. 

The Non-GMO Project's stance is clear: GMOs are not natural, and products made with them do not belong in natural products.

A greener footprint? Not necessarily.

GMO animal-free dairy is often cast as a cleaner, greener environmental option than traditional dairy. The industry's climate-friendly reputation likely opened the door to synbio brands as natural products in the first place. However, the comparison rests on incomplete environmental assessments and selective data points.

The products rely on energy-intensive techniques and GMO commodity crops. The industry's energy-use assessments tend to ignore necessary inputs that originate beyond the factory's loading dock, effectively externalizing the true cost, and little information is provided about waste disposal. What happens to the billions of GMO microorganisms after they are filtered from the milk-like beverage? An accidental release of GMO microbes could have environmental impacts, community impacts, or affect the health and safety of workers and consumers. 

Critics of the technology have called animal-free dairy "as bad or worse than [conventional] animal agriculture." However, limiting our options to synbio or conventional and concentrated dairy production entirely overlooks the regenerative movement's potential. Animals are essential for recycling nutrients into farmland, building healthy soil and robust crops. Regenerative dairy offers a hat-trick of benefits: high animal welfare standards, improved soil health and carbon sequestration and a more nutritious end product.

Breaking news: Neither cow, nor milk, actually free.

With grocery prices front-of-mind for many eaters, how do the economics of GMO animal-free dairy measure up? At the time of writing, Bored Cow animal-free dairy milk costs around $5/quart, while a gallon of natural, organic milk costs $7-9 — making the synbio product 2-3 times the cost of organic milk. Even top-tier regenerative dairy farms, the operations that build soil health and draw down the atmospheric carbon that is warming the planet, produce natural cow's milk at a lower price than the synbio options.

The synbio industry has been the subject of staggering investment in the last few years. The Non-GMO Project's dedicated research team tracked a sharp increase in activity in the field, driven in large part by an influx of capital from the tech sector. According to author and industry expert Errol Schweizer, "Just about all of this new food technology is heavily funded by tech oligarchs, venture capitalists, or the occasional celebrity." Schweizer, who also serves on the Non-GMO Project's Board of Directors, argues that investors are focused on monopolizing emerging markets. "Think: Uber, Doordash, Instacart, Amazon. The investors throwing billions of dollars at such enterprises are not altruists, even if some are motivated by animal rights or climate change." 

We've written before about patenting and GMOs' impact on the global seed market (click here to learn more). If history is about to repeat itself, it's worth considering the consequences of a single company "owning" the formula for a staple such as milk.  

Clearly, we have as many questions about precision fermentation as we have answers. At the Non-GMO Project, we believe curiosity is a virtue, and empowering people to make the right decision for themselves is work worth doing. We'll keep you posted as more information on animal-free dairy comes to light.