Although Miracle whip is largely considered a mayonnaise substitute, it is listened as "dressing" as it does not conform to the legal definition of Mayonnaise:
TITLE 21--FOOD AND DRUGS
CHAPTER I--FOOD AND DRUG ADMINISTRATION
DEPARTMENT OF HEALTH AND HUMAN SERVICES
SUBCHAPTER B - FOOD FOR HUMAN CONSUMPTION
PART 169 -- FOOD DRESSINGS AND FLAVORINGS
Subpart B - Requirements for Specific Standardized Food Dressings and Flavorings
Sec. 169.140 Mayonnaise.
(a) Description. Mayonnaise is the emulsified semisolid food prepared from vegetable oil(s), one or both of the acidifying ingredients specified in paragraph (b) of this section, and one or more of the egg yolk-containing ingredients specified in paragraph (c) of this section. One or more of the ingredients specified in paragraph (d) of this section may also be used. The vegetable oil(s) used may contain an optional crystallization inhibitor as specified in paragraph (d)(7) of this section. All the ingredients from which the food is fabricated shall be safe and suitable. Mayonnaise contains not less than 65 percent by weight of vegetable oil. Mayonnaise may be mixed and packed in an atmosphere in which air is replaced in whole or in part by carbon dioxide or nitrogen.
(b) Acidifying ingredients. (1) Any vinegar or any vinegar diluted with water to an acidity, calculated as acetic acid, of not less than 2 1/2 percent by weight, or any such vinegar or diluted vinegar mixed with an optional acidifying ingredient as specified in paragraph (d)(6) of this section. For the purpose of this paragraph, any blend of two or more vinegars is considered to be a vinegar.
(2) Lemon juice and/or lime juice in any appropriate form, which may be diluted with water to an acidity, calculated as citric acid, of not less than 2 1/2 percent by weight.
(c) Egg yolk-containing ingredients. Liquid egg yolks, frozen egg yolks, dried egg yolks, liquid whole eggs, frozen whole eggs, dried whole eggs, or any one or more of the foregoing ingredients listed in this paragraph with liquid egg white or frozen egg white.
(d) Other optional ingredients. The following optional ingredients may also be used:
(1) Salt.
(2) Nutritive carbohydrate sweeteners.
(3) Any spice (except saffron or turmeric) or natural flavoring, provided it does not impart to the mayonnaise a color simulating the color imparted by egg yolk.
(4) Monosodium glutamate.
(5) Sequestrant(s), including but not limited to calcium disodium EDTA (calcium disodium ethylenediamine- tetraacetate) and/or disodium EDTA (disodium ethylenediaminetetraacetate), may be used to preserve color and/or flavor.
(6) Citric and/or malic acid in an amount not greater than 25 percent of the weight of the acids of the vinegar or diluted vinegar, calculated as acetic acid.
(7) Crystallization inhibitors, including but not limited to oxystearin, lecithin, or polyglycerol esters of fatty acids.
(e) Nomenclature. The name of the food is "Mayonnaise".