After receiving about 1,700 comments, including many from private individuals, the USDA has closed its window for public comments on labeling standards for cell-cultured meat and poultry products.
Some of the most comprehensive responses to the USDA’s list of questions came from the Good Food Institute and New Harvest, nonprofit groups that share a mission of advancing the alternative protein industry. Environmental groups, agricultural associations, and cell-cultured meat startups also entered the fray. Here are some of The Spoon’s takeaways on the debate.
Brave new labeling requirements
The Good Food Institute and New Harvest presented different opinions on a key issue: whether or not the USDA should create unique labeling requirements for cell-cultured meat and poultry products.
Pointing to precedent created by regulatory agencies’ responses to other non-traditional production techniques, the Good Food Institute argued against the need for a new set of labeling requirements. The USDA’s Food Safety and Inspection Service “has generally promulgated new labeling requirements only when a new process or method materially alters the finished product or where it raises different or increased food safety risks,” the Institute said in its letter. Even the practice of harvesting meat from cloned animals, the Institute pointed out, has not warranted new requirements.
While the Institute argued for maximum flexibility, New Harvest seemed focused on guiding the creation of a framework that would be easy to navigate and empirically informed. The group advocated for a required qualifier term, disclaimer, or visual icon on cell-cultured meat labels, but suggested that the USDA wait to decide on a specific qualifier until we have a better understanding of how consumers will react to different options.
Good words, bad words
Per the Federal Meat Inspection Act, the U.S. government currently defines “meat” as “the part of the muscle of any cattle, sheep, swine, or goats which is skeletal or which is found in the tongue, diaphragm, heart, or esophagus…”
In its letter to the USDA, the Arizona Department of Agriculture argued that this refers only to muscle derived from living animals. Other legacy agriculture groups (including the Alabama Farmers Federation and U.S. Cattlemen’s Association) agreed that cell-cultured products should not be considered meat.
But there are other ways to interpret the government’s definition. The Good Food Institute wrote that it does apply to cell-cultured products, because they’re grown from skeletal muscle and fat cells. New Harvest argued that in order to eliminate any room for ambiguity, “strong consideration should be given to amending the statutes and implementations to expressly clarify that ‘meat’ […] may also be produced outside the animal.”
When it came to identifying appropriate qualifier terms for the new products, most of the groups commenting from inside of the industry expressed a preference for “cell-cultured,” or “cultivated.” Alternative seafood startup BlueNalu pointed to research that the company commissioned on the use of different terms, which found that the term “cell-cultured” maximized consumer appeal while minimizing confusion.
Notably, legacy agriculture corporation Tyson Foods (which has invested in UPSIDE Foods and other cell-cultured meat startups) supported the use of the same terms. Tyson also argued that it could be appropriate for cell-based companies to use product descriptors that consumers may associate with conventional meat, like “pork loin” or “steak.”
The Good Food Institute discouraged the USDA from adopting certain terms that have been put forward by legacy agriculture groups, such as “lab-grown,” “imitation,” and “synthetic.” The Institute argued that these terms do not accurately describe cell-cultured meat.
Keeping cell-cultured consumers safe
The concept of consumer confusion has long been used by legacy agriculture groups pursuing stricter labeling requirements for plant-based meat and dairy products.
In its letter to the USDA, the Good Food Institute invoked a different kind of consumer confusion. Cell-cultured meats contain the same allergens as slaughtered meats — but if cell-cultured products are labeled differently, the Institute argued, consumers could be confused into thinking that they are free of animal allergens, creating a potential health risk.
New Harvest weighed in on some potentially misleading claims that could appear on cell-cultured meat labels. Descriptions of these products as animal-free, safer and more sustainable than slaughtered meats, or acceptable by different religious standards should all be subject to scrutiny, the group argued.
All in all, the dramatic differences between different commenters’ visions indicate the need for a clear and empirically supported framework — one that is built on a realistic understanding of consumers’ needs, and that protects companies’ rights to truthful commercial speech.
As New Harvest stated in its letter to the USDA: “Regulatory frameworks need to be redesigned to keep pace with innovation and technology and future-proof our food system. We cannot expect this technology to positively impact our food system when it is built on an outdated regulatory foundation and minimum public scientific data.”
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