The United States Food and Drug Administration (FDA) has published comments from key players in the cell-based seafood space around what to actual label the stuff when it is finally cleared for sale to consumers (h/t Food Navigator). Consensus is building around “cell-cultured” as the most effective descriptor.
The original call for comments was sent out towards the end of 2020, and yesterday was the cutoff date for responses. Among those who weighed in on the discussion were BlueNalu, Finless Foods, and Memphis Meats, all companies currently developing cell-cultured seafood or meat products.
The comments underscore the importance of choosing the right name for a food type that still strikes many average consumers as something out of science fiction. When plant-based meat arrived in grocery stores, the labeling battle was usually less about convincing consumers and more about doing battle with Big Meat over use of certain words. Cultured meat’s big challenge, for now, is trying to concisely but effectively explain the concept of “protein grown from animal cells in bioreactors” to consumers.
Whatever label is settled on will have to convey several things at once to consumers. It will have to make clear that the product is safe, that it is real meat (aka not vegan), but that it is different from traditional animal-based protein in terms of how it is produced (e.g., cell cultured versus wild caught). Based on the comments submitted to the FDA, labels for seafood should also factor in food transparency, adherence to food industry protocols (e.g., allergen alerts), and should not disparage traditional meat products.
Of the companies and individuals that responded to the FDA’s call for comments, the majority back the term “cell-cultured” when it comes to labeling seafood products. Meanwhile, the majority of commenters suggested a move away from terms like “clean meat” and lab-grown meat.”
Finless Foods’ nine-pager of a comment concluded that:
At the highest level, Finless Foods advocates for and strongly supports an accurate, non- misleading, and descriptive label that clearly outlines what the cell-cultured products are, including species and product form, and how they are made, in a way that is uniform within the cell-cultured seafood category and consistent across categories. Therefore, we recommend that FDA adopt and memorialize the use of the term “cell-cultured” through the mechanism of a CPG or a letter to industry to provide appropriate guidance.
Citing a forthcoming Halman and Halman study, the Center for Science in the Public Interest said:
Based on the results of the two Hallman and Hallman studies, CSPI finds that both “cell-cultured” and “cell-based” would inform consumers of material facts and not be misleading, as well as portray the product in a neutral fashion. FDA should closely consider these options, and other peer-reviewed studies, in addition to conducting its own studies before making a final decision on its final label phrase.
Memphis Meats said it supports “disclosure of the term ‘cell-cultured,’ in conjunction with the name of the conventionally-produced seafood product, in the statement of identity or name of cell-cultured seafood products.” The Berkeley, California-based company also noted in its comments that “Terms that specify the type of seafood product (e.g., ‘fillet,’ ‘steak’) should be permitted in the name or statement of identity of a cell-cultured seafood, as long as the term appropriately describes the particular product. “
The Vegetarian Resource Group brought up the issue of consumer education in its comments, stating that, “Use of a term such as ‘engineered using cultured seafood cells’ would help consumers understand that the product is based on seafood and that seafood cells are used in production. An educational program would need to be developed to inform consumers about the meaning of ‘cultured’ in this context.”
You can read the full comments here, many of which delve into some of the more subtle issues that existing in the labeling debate. For example, one anonymous commenter suggested “cell-built” seafood to factor in the use of 3D printing technology.
Interestingly, less than one year ago, Rutgers released a study that found “cell-based” to be the best descriptor for seafood products grown in a lab. “Cell-cultured” was a close runner up in that particular study, which suggests consensus has been building for some time around the evolution of “cell-cultured” seafood.