GFI submits recommendations to USDA for cultivated meat and poultry labeling

A fair and sensible regulatory framework is necessary to bring cultivated meat and poultry to market and prevent consumer confusion.
Regulatory framework for cultivated meat

A regulatory pathway

Cultivated meat and poultry will help the world build a sustainable, secure, and just global food supply. Cultivated products diversify our protein sources, reduce the risk of zoonotic diseases and antibiotic resistance, and offer a sustainable solution to the world’s growing demand for meat. To make this promise a reality, however, regulators must provide a clear, practical, and flexible regulatory pathway to market for these products. 

On December 2, 2021, GFI submitted comments to the United States Department of Agriculture’s Food Safety and Inspection Service (USDA-FSIS) regarding the labeling of cultivated meat and poultry products. Under a March 2019 Formal Agreement, USDA-FSIS and the U.S. Food and Drug Administration (FDA) agreed to develop joint principles for labeling products produced using animal  cell-culture technology. FDA has authority over the labeling of cultivated seafood, while USDA-FSIS has authority over the labeling of cultivated meat and poultry.

Any labeling rules or guidance that USDA-FSIS creates for cultivated meat and poultry products will have a substantial impact on consumer choice. The terms used on product labels tell consumers a lot about the food they are buying, from its taste and texture to how it should be prepared and whether it contains known allergens. Accordingly, GFI has urged USDA-FSIS to adopt a sensible approach to labeling that promotes consumer understanding. Labeling rules also have the potential to discriminate against cultivated meat and poultry products in favor of conventional products already on the market. GFI has thus recommended that USDA-FSIS create a regulatory framework that treats cultivated products and conventional products fairly and equally.

In our comments, GFI has asked USDA-FSIS to:

Apply the same principles USDA-FSIS has previously applied to novel processes and methods of production.

New processes and methods for producing meat and poultry products do not always necessitate new labeling requirements. Historically, USDA-FSIS has promulgated new labeling requirements only when a new process or production method alters the properties of the finished product such that the new product has material differences from conventional products or presents increased food safety risks.

Allow cultivated meat and poultry products to use words commonly understood by consumers.

Cultivated meat and poultry companies should be allowed to use terms that consumers already understand to describe their products. Consumers understand the taste and texture of bacon, how to cook it, and that it contains pork. Consumers looking at a package of cultivated bacon are entitled to this same information. Prohibiting the use of a well-known word like “bacon” on this cultivated product package would cause consumer confusion and create potentially severe health risks for consumers with pork allergies. Cultivated meat and poultry producers should also be permitted to use terms like “burger” and “steak” to describe the form of their products if it would help consumers understand the product.

Avoid premature and rigid regulations that may quickly become outdated as consumers develop new language to describe cultivated meat and poultry products.

GFI has recommended that USDA-FSIS refrain from mandating the use of one or more specific terms on cultivated meat and poultry labels at this time. Consumers have not yet had the chance to read cultivated product labels or purchase these items in stores. Consumers may end up referring to cultivated meat and poultry products using entirely different terms from those mandated by regulation, which would only confound shoppers looking for these products on grocery store shelves. GFI has urged USDA-FSIS to allow cultivated meat and poultry developers to refer to their products using a variety of accurate terms that will aid consumers’ understanding. Should USDA-FSIS decide to mandate or restrict the use of specific terminology for cultivated meat and poultry products in the future, it should do so based on evidence of consumer understanding and acceptance.

Ensure fair treatment of cultivated meat and poultry products.

If USDA-FSIS mandates terms for cultivated meat and poultry products, it should ensure that those labels are not disparaging. Terms like “imitation” and “synthetic” are inaccurate and would likely dissuade consumers from purchasing cultivated products. Prohibiting the use of well-known terms would also unfairly discriminate against cultivated products. If cultivated meat and poultry products bear names that mean nothing to consumers while their conventional counterparts are allowed to use well-understood names, consumers are likely to purchase the latter rather than buy products they cannot easily identify. The agency’s rules must put cultivated meat and conventional meat on an even playing field.

The promise of cultivated meat

Cultivated meat and poultry products promise environmental sustainability, public health benefits, and an innovative way to fulfill the world’s growing demand for protein. A clear and workable regulatory framework is key to supporting cultivated meat and poultry innovation and ensuring that consumers understand these products when they see them on the shelves. 

GFI submitted these comments to USDA to ensure a fair regulatory playing field for cultivated meat and poultry, prevent restrictive labeling rules that would increase consumer confusion, and suggest a practical regulatory framework that will allow consumers to make informed decisions.

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Cultivated meat regulation

Cultivated meat will have many benefits for people, animals, and the planet. For cultivated meat to be successful on the market, there must be an efficient regulatory path in every country. Learn how we advocate around the world for clear, efficient regulations.

Author

Madeline cohen

Madeline Cohen REGULATORY ATTORNEY

Madeline Cohen works on regulatory and policy issues affecting cultivated meat and plant-based foods. Areas of expertise: regulatory landscape, domestic policy, and litigation