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What are mutagenized crops and why they are not labeled and regulated?

"[M]utation breeding led to more than [3000] plant varieties. … Proposing a ban on mutations caused by gene transformation for the sake of biosafety indicates a blind spot about the safety of numerous mutations induced by conventional breeders over more than [80] years, and introgression of unknown chromosomal parts from wild germplasm for centuries."
"In plants …. mutagenesis is a destructive process. One textbook on plant breeding states, “Invariably, the mutagen kills some cells outright while surviving plants display a wide range of deformities.” Experts conclude that most such induced mutations are harmful and lead to unhealthy and/or infertile plants."

At a Glance

Transgenic (GMO) crops have been the primary target of organic supporters and those opposed to crop biotechnology. But many activists have begun taking exception to mutagenized crops—plants produced from seeds exposed to radiation or, less frequently, chemicals. Thousands of random mutations are generated during the breeding process; mutations that generate positive traits are isolated. This breeding technique, which has traditionally not been considered a form of biotechnology, is known as mutagenesis.

Since its introduction in the late 1920s, mutagenesis has been used by scientists to develop food crops that are higher yielding, possess unique traits such as sweetness or hardiness, resist disease or are more nutritious. There are more than 2,000 mutagenized crops. They have been consumed without controversy. Dozens of grains, fruits and vegetables, such as varieties of durum wheat and sweet red grapefruit, are sold as organic crops. Regulations in almost every country do not classify mutagenesis as a GM technology, so plants and animals carrying novel traits produced by nuclear radiation or chemical mutagens traditionally have not been regulated as GMOs.

More recently, mutagenized crops have been targeted by anti-biotechnology advocacy groups opposed to CRISPR gene editing, which they claim is a form of mutagenesis and should be tightly regulated because of potentially ‘unpredictable’ effects. In July 2018, the European Court of Justice (ECJ) bucked historical tradition and recommendations from scientists to rule that mutagenized crops are a form of GMOs, gene editing is a form of mutagenesis, and both fall under the 2001 GMO directive that effectively bans most forms of agricultural biotechnology. It exempted classic mutagenesis techniques using radiation and chemicals, which the court ruled have a long safety record. So far, Europe stands alone as the only region regulating gene-edited crops as GMOs because of its assumed link to mutagenesis

The vast majority of scientists reject the contention that either mutagenesis or gene editing poses unique dangers; they say there is no evidence these plant breeding techniques threaten human health or the environment any more than conventionally bred crops.

Science and Politics

Humans have modified food crops for 10,000 years in order to develop varieties with beneficial traits including disease resistance, improved flavor and higher nutrient content. However, the amount of crop improvement that can be achieved through traditional plant breeding is limited because this process can mostly create only new combinations of existing traits.

To create new traits, scientists can induce mutations that change a plant’s genetic code. Mutated genes provide the variety plant breeders need to develop new crops. University of Missouri geneticist Lewis J. Stadler demonstrated in 1927 that X-ray radiation could be used to mutate the DNA of corn and barley. During the 1930s, scientists experimented with this technique to develop new crop breeds.

In the wake of World War II, the desire to use atomic energy for peaceful pursuits in science and medicine grew, and by 1959, scientists in the US, Europe and Soviet Union were irradiating plant seeds in what became known as mutation breeding in hopes of developing improved varieties of wheat, peanuts and many other crops.

Mutagenesis involves exposing plants to ionizing radiation or, more rarely, chemicals to mutate their genes, then growing them for multiple generations to isolate desirable traits. Plants possessing these traits are bred for still more generations to develop uniformity and field tested to see how they perform in real-world settings. If these mutated crops do well, they are licensed and released to farmers.

The International Atomic Energy Agency continues to support mutation breeding research around the world to develop improved crop varieties. More than 2,500 fruits and vegetables consumed today, including barley used to produce Scotch whiskey, disease-resistant cocoa, high yielding rice and spineless pineapples were artificially created with the help of chemical or radiation mutagenesis.

Unlike genetically modified crops which are often created through one or two mutations and are tightly controlled, and although the plant genome is dramatically altered in a laboratory with the induction of thousands of mutations of unknown effect, mutagenized products such as sweet red grapefruit and varieties of durum wheat have not been considered controversial and are often sold as organic. Scientists view mutation breeding as an extension of natural evolution, which is one reason why it has not been tightly regulated and has been embraced by countries around the world.

Scientists have often used mutagenesis to improve the nutritional profile of important food crops. The breeding technique has been used to increase the protein content of nuts, corn and soybeans, for example, and to develop diabetic-friendly rice that doesn’t dramatically spike blood sugar. According to a 2016 study, dozens of staple crops have been nutritionally enhanced by mutation breeding.

Some biotechnology critics and organic food advocates who oppose GMO crops have begun taking issue with mutagenesis, claiming it is potentially harmful, and likening it to CRISPR and other forms of gene editing, which they oppose. Many claim CRISPR is yet another secret ploy by “Big Ag” to monopolize the world’s food supply. The popular anti-GMO news site Natural Society warned in  2013:

[The seed company] BASF alone licenses its mutagenesis technology to 40 of the largest seed companies in the world, which turn around and sell mutant seeds to everyone from large ag producers to the farmer down the road. And you, the consumer, who eventually ends up searching for the healthiest option for your family, is none the wiser.

The pro-organic site told its readers that mutagenized crops are more concerning than GMOs because mutagenesis “…. creates random and unspecific genetic changes ….” Such criticism is now becoming mainstream in anti-biotechnology circles. The Organic Consumers Association, representing thousands of natural and organic food companies, alleges, “…. mutagenesis can cause dramatic shifts in genetically determined traits, producing unknown toxins or allergens.”

Some advocacy-linked scientists and doctors have speculated about so-called ‘unknown’ or ‘unpredictable’ effects of mutagenesis and gene editing. Cardiologist William Davis, author of the bestselling book Wheat Belly, who claims “modern wheat” is a “perfect, chronic poison,” blames the introduction of dwarf wheat, a crop developed via mutagenesis, for fueling a dramatic increase in gluten allergies.

Such claims get their fuel from a tiny cohort of scientists known for their vocal opposition to biotechnology. King’s College, London molecular geneticist Michael Antoniou, for example, warned in a 2014 report for the anti-biotech group Earth Open Source that mutation breeding during the 20th century “…. could have generated crop varieties that are toxic, allergenic, reduced in nutritional value, vulnerable to pests or environmental stressors, or harmful to the environment.” No evidence supports that claim.

Although mutagenesis does introduce unpredictable changes into a plant’s DNA, this fact isn’t as troubling as some activists maintain. Summarizing the evidence in support of the safety of mutagenesis, the authors of one oft-cited study noted that they were “…. not aware of any indications that the underlying mutations have caused damage to the environment, or had adverse effects on human or animal health.”

Another team of researchers has noted that traditional plant breeding, endorsed by even the most fervent anti-GMO activist, introduces thousands of mutations into the DNA of food crops, yet “[w]e all use and eat such cultivars” without a second thought, they noted.

Philosopher of science Giovanni Tagliabue expanded on these arguments in 2016, explaining there is little significant difference between mutagenesis and other conventional breeding techniques.

[T]he phrase ‘some mutagenized crops have exhibited harmful effects,’ while empirically correct, would not cast any doubt on the technology per se….[W]e should not forget that massive phenotypic consequences — frequently undesirable — can derive from even the slightest change in an organism’s genotype….[S]uch risk of failures from even little tweaks to a genome applies to each and any intervention….”

80 years of disaster-free mutation breeding in 30 countries to produce food, animal feed and ornamental plants have convinced food safety officials and scientists around the world that mutagenized crops don’t pose a risk to human health. This is another reason why crops developed through mutagenesis are not regulated in most countries.

Distribution of mutagenized crops by continent:

(Source: Joint Division of the Food and Agriculture Organization of the United Nations and the International Atomic Energy Agency [Joint FAO/IAEA, 2015], [IAEA mutant database,]

Over the years, other forms of mutagenesis have evolved. Scientists have developed oligonucleotide-directed mutagenesis (ODM), which introduces beneficial changes into a plant’s DNA without generating random mutations caused by traditional chemical and radiation mutagenesis. Plants carrying the desired mutation are then bred as described above and released to farmers.

Site-directed nucleases (SDN) including CRISPR-Cas9, Zinc Finger Nucleases (ZFN) and TALENs are seen by some experts as a refinement of that earlier technology in which the technique can be performed in vivo – in the living organism itself – with much more precision. According to a 2019 study published in Nature:

CRISPR-Cas9 is remarkably specific and efficient at generating on-target genome edits …. While CRISPR-Cas9 has the potential to generate off-target cutting in genomic sites that are substantially similar to the target site, off-target edits are likely to be negligible in the background of existing natural variation and continuous unintended changes being generated during the plant breeding process.

These new breeding techniques (NBTs) have added a new layer of complexity to the debate in the European Union (EU) over whether CRISPR is an extension of mutagenesis. While the EU has long recognized the safety of mutagenized crops, it recently determined it will regulate gene-edited and GMO crops as if they were idententical. In a July 2018 ruling, the European Court of Justice determined that Europe’s 2001 GMO directive applied to mutagenesis, a reversal of long-standing but unarticulated tradition. It extended that determination to NBTs, but exempted all prior forms of mutagenesis.

[T]he Court of Justice takes the view, first of all, that organisms obtained by mutagenesis are GMOs…. [However] the GMO Directive …. does not apply to organisms obtained by means of certain mutagenesis techniques, namely those which have conventionally been used in a number of applications and have a long safety record.

The ECJ decision baffled scientists because it created a political distinction between two breeding methods — natural breeding and mutagenesis — whose end results are effectively identical. As biologist Nina Fedoroff explained in the wake of the landmark ruling:

[A]rtificially induced mutations are indistinguishable from naturally occurring mutations at the DNA sequence level. They are also indistinguishable from the genetic changes produced by the newer methods, such as CRISPR/Cas-based gene editing…. The indistinguishability of genetic changes made by nature, 20th century mutagenesis and 21st century gene editing highlights the absurdity of regulating genetic modification based on the process used, as the Court of Justice of the European Union ruled in July of 2018.

European plant scientists, whose work was effectively halted by the decision,  concurred with Fedoroff’s analysis. The EU’s Group of Chief Scientific Advisors warned that the ruling is likely to block the development of “plants….which have the potential to provide immediate direct benefits to the consumer.”

Researchers in the Netherlands delivered a stark confirmation of scientists’ fears in January 2019, announcing they were close to developing a CRISPR-edited, “safe gluten” wheat variety for celiac patients. But, they added, Europe’s prohibitive precautionary-based biotech crop rules would prevent the commercialization of the new variety. Richard Visser, chair of plant breeding at Wageningen University:

Given the current situation in Europe, these wheat genotypes would not be allowed to be grown in Europe….The whole issue surrounding gene editing needs to be settled in Europe….[T]he products made with gene editing techniques should be allowed on the market….

Experts have also warned that excessive, expensive regulation of NBTs, often endorsed by anti-biotech groups, prices universities, nonprofits and small companies that are poised to lead the gene-editing revolution out of the market. This distortion in the marketplace could encourage the very scenario anti-GMO groups claim to fear: A seed market dominated by a few multinational biotech firms.

The Takeaway

While mutagenesis remains a contentious topic among many food activists and biotechnology opponents, the evidence overwhelmingly shows that the technology is as safe as conventional breeding and has significantly boosted food security and agricultural sustainability. According to a 2016 study:

Because of its relative simplicity and low cost, mutagenic treatment of seeds …. remains a useful tool for isolating the desired variants and developing resistance to biotic and abiotic stresses in various crops. …

[T]he impact of mutation breeding-derived crop varieties around the world demonstrates the potential of mutation breeding as a flexible and practicable approach applicable to any crop….

CRISPR gene editing has earned similar endorsements from the scientific community and food safety regulators in every region of the world except for Europe. The global consensus is that NBTs are perfectly safe, can help farmers meet growing demands for nutritious, healthy and inexpensive food, and should be regulated similar to conventional breeding.

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Why are many cheeses, wines, beers, vitamins and oils—made with GMO ingredients—labeled or banned in some jurisdictions and not others?

"Genetically modified bacteria and yeasts are ... critical to the production of some foods, including many wines and cheeses."
"From cereal and crackers to baking mixes, veggie burgers, and even milk and cheese, GMOs have infiltrated our grocery aisles largely without much study into their long-term health effects on our bodies."

At a Glance

A variety of popular foods contain enzymes, additives, flavorings and vitamins that are made with the help of genetically engineered microorganisms. The list of goods that contain these GMO-derived ingredients includes beer, wine and other alcoholic beverages; cheese and some milk products; baked goods, some juices; and many others.

Ninety percent of cheeses and almost all hard cheeses are produced with an enzyme called chymosin that is generated by genetically modified bacteria, known as fermentation-produced chymosin, or FPC. For many years milk in the United States was produced by cows treated with rBST, a naturally occurring hormone researchers began producing in genetically engineered microbes in 1985. And in the near future, beers may get their “hoppy” flavor from GE yeast instead of actual hop flowers.

The final products made from these substances usually contain no genetically engineered material by the time they reach grocery store shelves. Food safety regulators say that these products are substantially equivalent to foods made without the assistance of genetic engineering. Despite those two important facts, there is disagreement about whether to label foods made from GE-derived ingredients that don’t actually contain any genetically modified material. The US does not; many European countries do; the organic industry guidelines are contradictory.

There is no objective, scientific guidance on whether to regulate GMO-derived ingredients. Instead, these policies are driven by ideological and economic concerns that result in contradictory standards that convey nothing about the safety of the products themselves.

Science and Politics

Regulating and labeling GE food ingredients might seem like a straightforward process, but it’s not. Organic food advocates have taken contradictory stances on food ingredients made from GMOs. Under the USDA’s National Organic Program (NOP), organic breakfast cereals, for example, may contain vitamin A processed from soy, nearly all of which is genetically modified in the United States, and vitamin C grown in GMO corn. The NOP has been criticized for this allowance by anti-GMO activists and organic purists. The popular website Organic and Non-GMO report complains that the policy is “ambiguous”:

According to Gwendolyn Wyard, processing program reviewer at organic certifier Oregon Tilth, the use of …. vitamins creates challenges for organic food companies and for organic certifiers.  The NOP rule states that an organic product “must be produced and handled without the use of excluded methods,” such as genetic engineering. The problem, says Wyard, is that the language in the NOP regarding excluded methods is ambiguous. “This has led to inconsistent interpretations of the GMO prohibition by organic certifiers,” she says.

Contradictions abound. The USDA allows vitamins made from GMO corn and soy in its certified organic products, but the agency’s certified organic cheeses are not permitted to contain enzymes produced with genetic engineering. USDA policy stands in contrast to the more science-based regulations on GE cheeses issued by the Food and Drug Administration and most food regulators around the world: Harvard’s Kevin Bonham:

Most regulatory agencies don’t consider chymosin an ingredient. And in any case, purified chymosin from E. coli is chemically indistinguishable from that taken from calves. And [this] goes beyond cheese, the FDA has approved over 30 recombinant enzymes for use in food production….

Image credit: Max Pixel Vermont, the only US state to pass “right to know” GMO labeling legislation, in 2014 (subsequently superseded by the federal labeling regulations), and a major cheese producer, exempted its dairies from putting a GMO label on cheese produced with fermentation-produced chymosin (FPC) after lobbying from its influential dairy industry. Clarifying Vermont’s policy, the state’s attorney general wrote:

[Animal foods could be considered GMO-free] “regardless of whether the animal has been fed or injected with any food, drug, or other substance produced with genetic engineering,

The UK maintains a similar standard, noting:

Foods produced with the help of GM technology do not have to be labelled. An example of this is cheese produced with the help of GM enzymes which are used to clot the milk in the production process. These are not ingredients in the cheese.

Similarly, Germany doesn’t require foods produced with genetic engineering to be labeled as GMOs, however these products cannot be labeled non-GMO either, even if the final product contains no GE material. CHR Hansen, a Danish company that manufactures dairy enzymes, pointed out:

[C]are needs to be taken with regards to the labelling of the final food products, as in some countries local laws or voluntary standards limit the use of enzymes produced with GMO. One example is the ‘Ohne Gentechnik’ which does not allow the use of GMO produced enzymes according to the German legislation.

The Non-GMO Project, a multi-million dollar food certifying nonprofit that sells its non- GMO butterfly label to food manufacturers classifies all food ingredients derived from genetically modified sources as “high risk” (without citing any evidence). It requires that all products it certifies be made exclusively from “non-GMO” ingredients.

Anti-GMO blogger Vani Hari (the “Food Babe”) takes a similar stance. Warning about “shocking ingredients” like sugar made from GE corn used to brew beer, Hari wrote, “GMOs have not been tested long term on human beings and …. are linked to inflammation, cancer and other diseases.” Contrary to the Food Babe’s concerns and the Non-GMO Projects implied warnings, corn syrup is just sugar, chemically identical to the table sugar sucrose made from non-GMO sugar cane. Many “GMO-free” beers contain sucrose in the form of cane sugar.

Although the Non-GMO Project and the Food Babe don’t make exceptions for products made with GE enzymes and similar ingredients, their more stringent definition of “GMOs” is still arbitrary and unscientific. Harvard University microbiologist Kevin Bonham:

Groups like the [Non-GMO Project] reject the use of [genetically engineered] enzymes, but go even further. Bafflingly, they even oppose the use of recombinant proteins to make small molecule compounds like citric acid, claiming they pose “GMO risk.” This term is meaningless – are they saying a chemical compound can somehow have memory of where it came from?

These clashing policies make clear that ideology and economics drive the decision to treat food ingredients as GMOs. Vermont’s dairies produce $1.3 billion worth of products each year, so the state had a financial incentive to allow its cheese producers to use fermentation-produced chymosin. FPC is less expensive than the same enzyme obtained from the stomach lining of an unweaned calf.

In contrast, the Non-GMO Project, which certifies $11 billion worth of products annually, has an incentive to market its subjective product “purity” standards. So even though Vermont and the project are ostensibly aligned on the issue of labeling GMOs—the Non-GMO Project praised Vermont’s labeling rules as “a huge step towards transparency”— the two entities took opposing positions on several important GMO-derived food ingredients.

The Takeaway

The disagreement over how to classify GMO-derived products like vitamins, food additives, flavorings and enzymes used to make products from cheese to beer will continue. But these contradictory standards miss the broader point: almost all these products are indistinguishable from those made without GE ingredients—and they’re all safe to consume.

As Michigan State University professor of agricultural, food and community ethics Paul Thompson explained, “The FDA has clear authority to regulate additives (like coloring agents or preservatives) and animal drugs (like rBST),” and has done so since 1985.

The fact that these products can now be made in the lab is irrelevant since they are identical to their “natural” counterparts. Officials at the European Food Safety Authority summed up the issue this way:

Enzymes have been used unknowingly in food production, e.g. dough making, for centuries …. Historically enzymes are considered to be non-toxic and not of safety concern for consumers since they are naturally present in ingredients used to make food.

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What is plant-based, genetically engineered “fake meat” and why is it being developed?

"Every year, 66 billion terrestrial animals are slaughtered for food … The impact of grazing animals on the environment is devastating. Some experts have even said meat may not be essential for most people, and a vegetarian diet is healthier than a meat-based one. So, the rationale for developing meat alternatives – “fake meat” – is strong.
"Fake meat has been around a long time. But the new higher-tech vegan meats address one problem - torturing & killing animals – without addressing many others, like resource use and hyperprocessing.

At a Glance

As climate change accelerates and a growing and more prosperous global population demands more food, farmers and scientists have tapped a number of innovative technologies to help sustainably produce enough calories to feed everyone. Meat has been targeted by many environmentalists because it allegedly takes a heavy toll on the environment, because of resource inputs and the climate change implication of methane gas released by cattle. Proponents of plant-based and lab-grown meats maintain that these foods can serve as viable alternative protein sources for consumers while exacting a smaller toll on our natural resources than animal agriculture.

Made possible thanks to dramatic technological advances, both meat alternatives have attracted attention because they mimic the qualities that meat eaters find appealing in a hamburger. Plant-based meat options, sold under brand names Impossible Burger and Beyond Meat, began hitting the market in 2013, exploding in popularity in 2019. Lab-grown meat remains in development, although estimates indicate it could be available as soon as 2024, with potentially ‘disruptive’ effects on diet and the environment.

Given their potential to upend the way we produce food, these new products have made powerful enemies and allies, creating odd alliances in the process. Environmental activists and traditional meat producers – often harsh critics of each other – lobby against these alternative meats. Meanwhile, major companies, including Burger King, Carl’s Jr. and Tyson, have invested in these products, cheered on by technology early adopters. Many scientists have lined up on opposing sides of the issue as well, as food safety officials scramble to devise sensible regulations for these novel products.

Science and Politics

Vegan meat alternatives have been on the market for decades. However, these plant-based foods typically have appealed to a small segment of the population that abstains from animal products for health, environmental or ideological reasons. They have failed to attract broad interest from US and European consumers, who eat approximately 200 pounds of meat per person each year. The most challenging hurdle for food manufacturers has been replicating the taste and feel of a beef burger for the meat-loving segment of the market.

The potential market for alternative meat products expanded dramatically in recent years when Beyond Meat and Impossible Foods started developing meat substitutes more palatable to more consumers. Stressing its “non-GMO” ingredients, Beyond Meat makes hamburgers, ground beef, chicken and sausage from yellow peas, mustard seeds, camelina and yeast. The company’s products have been available in US grocery stores since 2013. They so closely mimic traditional meat that many consumers couldn’t tell the difference when Beyond’s products were accidentally mislabeled by a Whole Foods deli in 2014. Beyond Meat has partnered with fast food chains, including Dunkin’ Donuts, Carl’s Jr. and Del Taco, to offer fast food versions of its products.

Established to “make our global food system truly sustainable,” Impossible Foods, Beyond’s major competitor, introduced its Impossible Burger in 2016, a plant-based product that “sizzles” and tastes like a beef hamburger made with a genetically engineered ingredient. Impossible Foods discovered how to derive heme, the molecule that gives beef its “meaty” flavor, from a protein found in soy called leghemoglobin. The company mass produces heme from this soy protein with the assistance of GE yeast. Other commonly used food ingredients contribute to the beef-like texture and flavor as well.

In July 2018, the US Food and Drug Administration (FDA) declared Impossible’s heme-producing protein “generally recognized as safe” (GRAS), allowing it to be sold immediately with no restrictions or labels. Rather than criticizing biotechnology, it took a different tack than Beyond Meat, hyping its “genetically engineered yeast” and its embrace of biotechnology. Impossible burgers are also sold by a variety of fast food restaurants, including Burger King as the Impossible Whopper, and White Castle as the Impossible Slider, and are slated to hit grocery stores in the fall of 2019.

Reducing meat consumption offers potentially substantial environmental benefits. According to a life cycle assessment (LCA), a study evaluating a product’s environmental impact, commissioned by Impossible Foods and conducted by an independent consulting firm, the company’s plant-based burger requires 87% less water, 96% less land, and generates 89% fewer GHG emissions and 92% less aquatic pollutants than a beef hamburger.

Some scientists have challenged this analysis of Impossible’s environmental benefits, noting that such reductions rely on inflated estimates of animal agriculture’s use of water, animal feed and carbon emissions. These researchers have noted, for instance, that widely circulated estimates of water consumed by cattle include all of the rain that falls on the pastureland where a herd is raised, not just the amount of water they consume.

The cattle industry has additionally pointed out that nearly every part of a cow is used to make food and consumer goods, meaning that very little of the animal is wasted. With experts on both sides, this dispute will continue for the foreseeable future, as traditional meat producers and plant-based burger companies battle for market share.

Some environmentalist critics have alleged that growing the GMO soy utilized in the Impossible burger threatens biodiversity and exposes consumers to more pesticides. However, there is no evidence to back up either argument. GMO crops have a minimal impact on biodiversity because they require little or no tilling to control weeds and are typically treated with benign herbicides, protecting a variety of beneficial insects and plants from damage. Moreover, the pesticides used on soybeans, and every other commodity crop for that matter, are tightly regulated by the US Environmental Protection Agency, and regularly re-evaluated to ensure they don’t pose a threat to human health.

Impossible Foods has been similarly lambasted by anti-GMO groups (and critics in the meat industry) over its genetically engineered burger. Activists such as Michael Hansen, a senior scientist with Consumers Union who is also on the board of the anti-biotechnology ETC Group, claims the plant-based meat substitute contains 46 “unknown” proteins that could present some undiscovered threat to human health, a view promoted by almost every food biotechnology critic. But as biologist Mary Mangan explained in response, many foods, including beef, contain proteins whose functions haven’t been determined yet. This doesn’t suggest that those foods are dangerous, as the FDA’s assessment and clearance-to-market of the Impossible burger confirmed.

Alternative meat has come under fire from critics who argue the increasingly popular products are “ultra-processed” and thus contain unhealthy amounts of sodium and fat and too many calories. This complaint has been challenged by alternative meat supporters. As retired University of Georgia food scientist Robert Shewfelt has noted, not all processed food is junk and not all junk food is processed. Processing describes a variety of techniques, such as freezing and packaging, designed to preserve the foods we eat; it doesn’t necessarily influence their nutritional qualities.

Second, a simple comparison of the nutrients in plant-based burgers and ground beef confirms they are remarkably similar. Nutritionists say Beyond and Impossible Burgers are unlikely to pose unique health risks.

In part because processing is poorly understood by most consumers, Shewfelt noted, “food gurus” and other activists have used the concept pejoratively to attack any ingredient they dislike. Breakthrough Institute scholar Alex Trembath has pointed out this opposition is usually born out of “antipathy towards mass-produced foods” and distrust of the corporations that make and sell these products.

Unlike an Impossible Burger, lab-grown meat is made from animals, but eliminates the need to slaughter pigs, cows and chickens. According to Leigh Ackland, professor of molecular biosciences at Deakin University in Australia, there are three primary steps required to make a burger in the lab. Scientists identify “starter cells” that can be turned into muscle, supply them with nutrients then grow them in a controlled laboratory environment. The process is in its infancy and food companies are still exploring how to scale it for mass production.

Lab-grown meat is still years away from commercialization, so not much is known about its eventual nutritional content. But since these products have to be constructed from cells, the nutrients in lab-grown burgers, steaks and fish could be manipulated to suit consumer preferences, experts have speculated. For example, burgers could be engineered to contain less saturated fat and fortified with vitamins, as is already possible with some gene-edited crops, such as soy.

While nutrition remains an open question, a fierce debate has broken out over the potential environmental impact of lab-grown meat, as it has with plant-based replacements. Proponents say cellular agriculture could reduce or even eliminate the pollution, animal rights abuses and carbon emissions that result from raising animals for food. They argue that “factory farming” isn’t sustainable as the global population continues to grow.

Critics challenge these views, however. Farmers reject allegations of animal abuse, arguing that humanely raising livestock makes them more productive. University of California, Davis animal geneticist Alison Van Eenennaam has maintained that growing animal cells in the laboratory is an energy-intensive process that could offset the environmental benefits of using less land and fewer agricultural inputs to raise animals. She also noted that animal agriculture accounts for less than four percent of all US greenhouse has emissions, so the environmental benefits of lab-grown meat (and plant-based meat) are far less than advertised.

For now, comparing the environmental impact of traditional and cellular agriculture isn’t possible, since lab-grown meat isn’t yet produced on an industrial scale. Currently available estimates are based on a variety of assumptions that may or may not prove correct.

The Takeaway

Researchers, food producers and activists of various stripes will continue debating the nutritional and environmental merits of lab-grown and plant-based meats as there is much to learn about them. But these products are just the beginning of even more dramatic changes to how we produce food, meat in particular. Scientists are developing animal-free ice cream, bean-free coffee and many more foods and ingredients that popular culture has treated as science fiction. It’s important to remember just how much progress we’ve made in a relatively short period of time. As Trembath has noted:

[W]hen we find fault with a clearly beneficial innovation slotting neatly into modern food systems, perhaps the problem isn’t with the system, but with our own idealized vision for what an equitable, healthy, appealing food system should look like. Surely there are excesses and failures with the status quo …. But …. we might consider whether the systems we have designed over generations to feed billions of humans aren’t doing a relatively good job …. After all, global hunger and undernourishment have been trending downward for decades, an achievement we should surely take into account.

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GLP Articles

Viewpoint: Debunking 6 activist ‘lies’ about the GMO Impossible burger, Stephan Neidenbach, June 3, 2019
Viewpoint: Lab-grown meat should replace farm animals as food, Matti Wilks, May 16, 2019
Viewpoint: Opponents of lab-grown meats are using anti-GMO arguments they will soon regret, Marc Brazeau, April 10, 2019
Viewpoint: Lab-grown meat isn’t as ‘clean’ as you might think, Alison Van Eenennaam, January 7, 2019
With glyphosate-cancer legal battles poised to escalate, what are the ramifications for agriculture if the herbicide is restricted?, Cameron English, August 13, 2018

Additional Resources

Would you eat meat grown from cells in a laboratory? Here’s how it works, Leigh Ackland, The Conversation, June 23, 2019
How Will Cultured Meat and Meat Alternatives Disrupt the Agricultural and Food Industry?, ATKearney, 2019
Impossible Burger GRAS notice, FDA, July 2018
The Case for Sustainable Meat, Keir Watson, Quillette, April 5, 2018
Environmental Life Cycle Analysis: Impossible Burger 2.0, Impossible Foods, March 18, 2018
How GMOs can save civilization (and probably already have), Michael Eisen, Medium, March 16, 2018

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How are GMOs labeled around the world?

"Instead of providing people with useful information, mandatory GMO labels would only intensify the misconception that so-called Frankenfoods endanger people's health…. Ultimately, we are deciding whether we will continue to develop an immensely beneficial technology or shun it based on unfounded fears.
"It’s encouraging to see the number of nations that have embraced labeling. Yet, at the same time it’s frustrating and offensive that Americans are denied the information about their food that those in Kenya and Saudi Arabia receive.

At a Glance

The United States is the 65th nation–joining about one third of the world’s countries–to require mandatory labels on foods containing genetically modified ingredients. The US, which passed a labeling law in July 2016, joins Russia, Brazil, all of Europe and nearly a dozen Asian nations. Federal agencies have until 2018 to establish standards, which will require the disclosure of GM ingredients through text, a symbol, toll-free number or a digital link (such as a QR code that can be read by a smart phone.) Among the nations that have no mandatory labels are Canada, Mexico, Argentina, Chile, Pakistan and most of Africa.

Mandatory labels—dictated by the percentage of GMO ingredients in a product or how the seed was developed—generally take one of two forms. Most regulations require only that the GM items be noted in the ingredients list on a package. Less common are rules mandating a more conspicuous location on the label. The US has carved out a third option.

Science and Politics

Despite the fact that more than 275 science organizations have concluded that GM foods pose no more health concerns than conventional or organic foods, dozens of nations around the world have enacted labeling laws requiring the disclosure of GM ingredients..

Twenty-eight of the world’s nations requiring GMO labeling are found within the European Union, which has long held a somewhat hostile view of genetic modification of foods and despite its importation each year of more than 30 million tons of biotech corn and soybeans used for animal feed.

The continent’s uneasy relationship with GM products stems from numerous food scares since the 1990s, most notably the mad cow crisis. Europe has embraced a precautionary regulatory framework toward food—foods suspected of causing health or environmental problems can be restricted or banned even if the links are not proven.

The EU countries and other countries that have developed a regulatory structure based on how a product is made—the process—and not the final product.  The EU considers a GMO to be any product of “techniques of modern biotechnology called gene technology.” That differs substantially from non-labeling nations, where regulators use what’s called a product-based evaluation, requiring labels only if there is a significant nutritional or compositional difference. So if a GMO soybean is essentially identical to a non-GMO soybean, it receives no special treatment. Such has been the stance of US regulators since a May 1992 ruling by the Food and Drug Administration in which it concluded there was no reason from a health or safety standpoint to require the labeling of genetically modified foods.

The agency is not aware of any information showing that foods derived by these new methods differ from other foods in any meaningful or uniform way, or that, as a class, foods developed by the new techniques present any different or greater safety concern than foods developed by traditional plant breeding. For this reason, the agency does not believe that the method of development of a new plant variety (including the use of new techniques including recombinant DNA techniques) is normally material information within the meaning of 21 U.S.C. 321(n) and would not usually be required to be disclosed in labeling for the food.

The FDA reinforced its position in a 2015 letter to activists rejecting their petition to require labels on a GM salmon.

The agency is not aware of any valid scientific information showing that foods derived from genetically engineered plants, as a class of foods, differ from other foods in any meaningful way. GE (genetically engineered) foods don’t present greater safety concerns than foods developed by traditional plant breeding. … However, if a food derived from a genetically engineered plant is materially different from its traditional counterpart, the labeling of that food must disclose such differences.

That position was bolstered by a May 2016 report by the National Academies of Science, Engineering and Medicine, which said it found “no substantiated evidence of a difference in risks to human health between current commercially available genetically engineered (GE) crops and conventionally bred crops.”

While pointing out that there may be social or economic factors that come into play when deciding whether or not to label genetically engineered food, the report said there is no reason to require labeling for health or safety:

Mandatory labeling is a …  complex issue that involves competing values. There clearly are strong nonsafety arguments and considerable public support for mandatory labeling of products containing GE material. On the basis of its review of the evidence on health effects (Chapter 5), the committee does not believe that mandatory labeling of foods with GE content is justified to protect public health.

The landscape in the United States changed in July 2016, when Congress passed a law , politically bypassing regulators, requiring labeling of foods containing GM ingredients. It requires the disclosure of GM ingredients through text, a symbol (as yet undefined), or a digital link, such as a QR code that can be read by a smart phone. The law invalidated the Vermont mandatory labeling law which had gone into effect on July 1, 2016, and prevented the passing of what the food industry believed would have been a “patchwork of different state labeling laws [that] would be a costly and confusing disaster for the nation’s food supply chain.”

The nation’s organic lobby, the Organic Trade Association, lent its support to the measure as well:

If you consider what the opponents of GMO labeling proposed, and what the voluntary and state by state options would have offered, it’s hard not to see how this mandatory federal legislation is a constructive solution to a complex issue. … This bill reinforces Organic as the original non-GMO market claim and assures consumers that the USDA organic seal is the gold standard for consumers looking to avoid GMO’s, toxic pesticides, and so much more.

While some GMO opponents applauded the bi-partisan federal measure, others were sharply critical. They had wanted an on-label GMO designation. They also objected to the use of QR codes scanned with a smart phone, arguing that many consumers, particularly poorer ones, would not have easy access to the information.

Yet to be resolved are what types of genetically modified ingredients will be covered by the law, particularly highly refined oils and sweeteners that contain no genetic material after processing but are derived from GM crops. Australia’s policy argues that there is no way to tell the difference between sugar derived from a GMO crop or a non-GMO crop. But the European Union, with its traceability and labeling regulations does require labeling of these highly-refined substances, based on an April 2014 amendment.

Uncertainty revolves around how the US and other nations will handle ingredients and products derived from newer technologies (including RNAi and gene editing techniques such as CRISPR)— things the non-browning mushroom, non-browning apple and low-acrylamide non-bruising potato, which so far have been introduced without labeling in the United States.

Anti-GMO leader Gary Hirshberg, founder of the pro-labeling group Just Label It, vowed regulatory and marketplace battles ahead to expand the definition of what is a GMO, and there are expectations some of these issues will be resolved in court.

It appears that no country requires labeling of foods produced with the aid of GM enzymes, including the vast majority of hard cheeses produced in the US and Europe. Such cheeses were traditionally produced with rennet – found in the lining of calf stomachs—which provides the chymosin that helps turn milk into cheese. Today, most of the chymosin used by cheese makers is the result of genetic modification, through a substance called fermentation-produced chymosin or FPC.  While products made with FPCs are exempt from international labeling laws, they are rejected by the Non GMO Project, which considers them to be GMO.

Mandatory labeling laws generally come into play based on the GMO percentage of any particular ingredient in a food product, although some base the percentage on the entire food item. The most restrictive rules—in places like the European Union, Saudi Arabia, Turkey and Australia—have a 0.9 percent threshold.  Others allow a greater degree of GMO inclusion, with South Korea at 3 percent and Japan at 5 percent. US agencies have not yet determined a cut-off threshold under the mandatory labeling bill signed into law in July.

Labels can be divided into two categories: The first requires the consumer notification to be included in the list of ingredients. The second requires the notice to be placed elsewhere on the package, in a conspicuous area. The latter option has been a target of criticism from some experts. “It’s like putting a skull and crossbones on a food product. GMO labels would be telling people this is toxic while there’s no definite proof it is,” said Tim Richards, agribusiness professor at Arizona State University.

Some examples:

United Kingdom
The Netherlands

The European Union’s traceability and labeling regulations come into play whenever any ingredient in a particular food item is more than .9 percent GMO. Pre-packaged foods must carry the information in the ingredients list, while those without packaging must have a notice near them on the supermarket or bakery shelf:

“The list of ingredients must indicate “genetically modified” or “produced from genetically modified [name of the organism]”.


Australia and New Zealand require that GMO ingredients be noted in the ingredient panel, unless the entire item is genetically modified. In that case, the information has to be included next to the name, according to the Food Standards Australia New Zealand agency.

South Korea has a higher threshold for GMO labeling, with anything under 3 percent considered to be unintentional. There are three different labeling options: 1) “Genetically modified [name of agricultural product],” 2) “Partially contains genetically modified organism,” 3) “Possibly contains genetically modified organisms.” Regarding placement:

The label for the GM agricultural product should be on the package, the container, or the storage facility of the product.  The label must be eye-catching, with a different color from the background color… The label for processed food should be created with a non-erasable ink in an eye-catching form on the package or container of GM food.


Brazil, the world’s second largest producer of GMO crops, requires a label “when more than 1% of a product marketed as food for human or animal consumption contains or is produced from GMOs.” The notice is in the form of a black T superimposed on a yellow triangle.

Saudi Arabia requires notices on labels to be written in both Arabic and English, in an ink color that differs from the primary text. The regulations require that the GMO label be prominently displayed on the package:

A triangle should be drawn and on it the text should read “Contains Genetically Modified Product (s).”

ecuador label

Ecuador, which bans the growing and import of GMO crops and seeds, requires a front-of-package label for processed food containing genetically modified ingredients that is akin in size and presentation to a tobacco warning.



The Takeaway

The international community is in considerable disagreement over whether or not GMO labels should be mandatory. This was on display in 2011 when the Codex Alimentarius Commission, an international food-standards group managed by the United Nations and the World Health Organization, attempted to issue standards for mandatory labeling. The group was unable to come an agreement, and instead decided to leave the issue in the hands of individual nations with voluntary labeling:

Codex has adopted principles and guidelines to assess food safety of foods derived from recombinant-DNA plants, animals and microorganisms. If a government chooses to build a regulatory mechanism to address the food safety of so-called GM foods, then they can use Codex text as a basis for it. This being said, each government is free to adopt its own policy as to the use of GM organisms in the agriculture and other sectors.

At the moment, there are no internationally-agreed recommendations on the food labelling of GM foods. Governments are therefore applying their own regulations.

The most significant element of the Codex decision was the shielding it offers to nations in potential World Trade Organization disputes involving GMO products. The Codex is recognized by the WTO as a legitimate standards-setting organization, according to Henry Chang, an international trade lawyer in Canada:

As a result, member countries who choose to adopt mandatory GM labelling requirements should avoid any WTO challenge based on the claim that such requirements restrict international trade.

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