What is really in a “milk-containing product” with milk fat substitute
If a pack in Russia says “milk-containing product with milk fat substitute”, the regulation’s own definition allows up to half of its fat phase to be vegetable. Technical Regulation TR CU 033/2013 requires that to appear in the name and again in a separate box reading “Contains vegetable oils”, in letters at least 3 mm high where the pack allows.
Four groups that are easy to mistake for one
The regulation sorts dairy products by the kind of fat they contain and how much milk is in them. The group names look alike, and the borders between them are legal ones. The definitions are in section II of TR CU 033/2013, which applies in Russia and the other Eurasian Economic Union states.
| Group | What it may contain |
|---|---|
| Dairy product | Milk and its constituents. No non-milk fat and no non-milk protein |
| Composite dairy product | Milk plus non-milk components such as fruit or cocoa, added not to replace milk constituents. More than 50% of the finished product is milk constituents (more than 40% in ice cream). Non-milk fat as a separate ingredient is not allowed, with an exception for dairy products for young children |
| Milk-containing product | A product based on milk in which milk solids are at least 20% of the solids of the finished product. Non-milk fat as a separate ingredient is not allowed |
| Milk-containing product with milk fat substitute | The same, but part of the milk fat is replaced by a milk fat substitute: up to 50% of the fat phase. Non-milk protein is allowed if it is not added in place of milk protein |
The word “milk-containing” alone does not mean vegetable fat. The words “with milk fat substitute” do.
What the pack has to show
For a product with a milk fat substitute, points 80 to 82 of the regulation set these requirements:
- The name starts with “milk-containing product with milk fat substitute” and continues with the technology: “made by sour cream technology”, “by cottage cheese technology”, “by cheese technology”. Letters at least 2.5 mm high.
- Next to it is a separate information box reading “Contains vegetable oils”, in a colour that contrasts with the background, letters at least 3 mm high. On a small pack the lettering is as large as fits.
- The name and the box are on the side of the pack facing the shopper on the shelf, or the side that is easy to read.
- The name may not be shortened.
The exceptions apply only to the start of the name: cream-and-vegetable spread, cream-and-vegetable ghee blend and ice cream with a milk fat substitute are named in their own way. The vegetable oil notice may not be moved to a leaflet insert (point 96).
Words that may not appear in such a name
Point 82 bars milk-containing products from using the terms the regulation reserves for dairy products, in the name, the trademark or a made-up name, and from using words formed from them: the Russian diminutives for sour cream, cottage cheese, cream and butter, and adjectives such as “cheesy” or “cheese-like”. For ice cream with a milk fat substitute the words “milk”, “cream” and “plombir” are not allowed (point 84). The tiers of ice cream are covered in a separate article.
For spreads the word “butter” is barred from the name. It is written both in point 83 of the dairy regulation and in TR CU 024/2011 on fat and oil products.
What separates the product on each shelf
| Shelf | Real dairy product | Version with a milk fat substitute |
|---|---|---|
| Cheese | “Cheese”: made from milk and dairy products, with no substitute for milk constituents | “Milk-containing product with milk fat substitute, made by cheese technology” |
| Sour cream | “Sour cream” (smetana): fermented cream with at least 10% milk fat | “…made by sour cream technology” |
| Cottage cheese | “Cottage cheese” (tvorog): a fermented dairy product | “…made by cottage cheese technology” |
| Butter | “Butter”: at least 50% fat, and the fat is milk fat | A spread. The share of milk fat in the fat phase depends on the type of spread, see below |
The word for “curd” in “curd product” does not signal a fat substitute. By the regulation’s definition a curd product is made without non-milk fats and without non-milk proteins that replace milk ones. More in the article on cottage cheese.
Three spreads with similar names
The two regulations use confusingly similar names, so here are the shares of milk fat in the fat phase side by side.
| Name | Milk fat in the fat phase | Defined in |
|---|---|---|
| Cream-and-vegetable spread | 50 to 95%, total fat 39 to 95% | TR CU 033/2013 |
| Vegetable-and-cream spread | 15 to 50% | TR CU 024/2011 |
| Vegetable-fat spread | under 15% | TR CU 024/2011 |
Butter and spread also differ in other ways, covered in the article on butter and spread.
What is known about the substitute itself
TR CU 024/2011 defines a milk fat substitute as a product with at least 99% fat made from unmodified and/or modified vegetable oils. It has no more than 65% saturated acids of the total fatty acids, including no more than 38% palmitic, and a melting point of no more than 36 °C.
The regulation does not list which oil is used. That shows in the ingredient line. Palm oil is only one possibility, and it has its own article.
This is a lawful product category, not a counterfeit. What matters is knowing what you are buying and comparing the price with products of the same group.
What the shop rules say
Under the Rules of retail sale of goods (Government Decree of 30 May 2026 No. 657, in force from 1 September 2026, point 40), dairy, composite dairy and milk-containing products must be displayed so that they are visually separated from other food and carry the sign “Products without milk fat substitute”. By the meaning of that sign, products with a substitute do not belong in that area. The decree is published on the Russian Government website.
Outside the Eurasian Union
The European Union reserves the names of dairy products in Annex VII, Part III of Regulation (EU) No 1308/2013: names such as cream, butter, cheese and yoghurt are reserved for milk products, defined as products derived exclusively from milk, where no added substance is used to replace any milk constituent, in whole or in part. In the United States, 21 CFR 101.3(e) treats a substitute that resembles another food but is nutritionally inferior as an “imitation”, and the label must say so.
How to check in five seconds
- Read the full name, not the large word on the front.
- Look for the box “Contains vegetable oils”.
- In the ingredients look for “milk fat substitute” or names of vegetable oils. The rest of the line is covered in the article on reading a food label.
- Compare prices within one group. How to do it is in the article on price per kilogram.
The norms are given as in TR CU 033/2013 with the amendments of EEC Council Decision No. 143 of 23 September 2022, in force since 22 September 2023, as of 6 October 2026.
Frequently asked questions
- What is a milk-containing product with milk fat substitute?
- A product in which no more than 50% of the fat phase is replaced by a milk fat substitute, and milk solids are at least 20% of the solids of the finished product. The definition is in section II of TR CU 033/2013.
- What must be written on the pack of such a product?
- A name starting with “milk-containing product with milk fat substitute” (letters at least 2.5 mm) and a separate contrasting box “Contains vegetable oils” in letters at least 3 mm. The requirements are in points 81 and 82 of the regulation.
- Does the word “milk-containing” alone mean there is vegetable fat?
- No. A milk-containing product without the words “with milk fat substitute” is made without non-milk fat as a separate ingredient. Vegetable fat is signalled by those words and by the box “Contains vegetable oils”.
- Is a curd product the same as cottage cheese with a milk fat substitute?
- No. By the regulation’s definition a curd product is made without non-milk fats, while a product with a substitute is named “milk-containing product with milk fat substitute, made by cottage cheese technology”.
- What does the sign “Products without milk fat substitute” in a shop mean?
- The retail rules (Government Decree No. 657 of 30 May 2026, point 40) require the display of dairy, composite dairy and milk-containing products to be visually separated and labelled with those words.
Read next
- Tvorog: how to distinguish it from a tvorog product — On the tvorog shelf, there are four different products, and the difference between them is specified in the regulation.
- Cheese: what "45% fat" means on the label — Cheese labeled "45%" does not contain 45 grams of fat per hundred, but rather about 27.
- Butter and spread: how to distinguish them and why they are different products — Butter and spread sit side by side, look the same, and cost different amounts.
- Plombir, creamy and milk ice cream: what sets them apart and how many calories they have — In Russia and the Eurasian Economic Union the type of ice cream is set by its milk fat: milk ice cream has up to 7.
This article is for general information. It is not medical advice, a diagnosis, or a prescription for treatment or a diet, and it does not replace a consultation with your doctor. If you have a health condition, are pregnant, take medication, or follow a diet prescribed to you, decisions about food belong with your doctor.
Figures from regulations, guidelines and studies are given as they stood when this article was prepared and may since have changed; check them against the primary sources. This article is not advertising, an offer, or individual advice, and neither the author nor the site owner is responsible for decisions taken on the basis of it.