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Public support for labeling
Current US policy makes the labeling of GE foods mandatory only when
there is some nutritional difference in the food, such as increased allergenicity,
decreased nutrition, etc. However, several recent public opinion surveys
suggest broad public support for a system of mandatory labeling of all
GE foods. Many consumers believe that they have the right to accurate
information about the prevalence of ingredients from genetically engineered
crops in the foods they eat, regardless of nutritional differences. Not
surprisingly, food industry-sponsored surveys find consumers only modestly
support labeling or are even happy with current labeling policy, while
activist groups find "overwhelming" support for mandatory labeling.
What is unclear from the surveys is whether support for labeling represents
a real public demand for mandatory labeling policy, or expression
of a more passive desire for more information when asked. Despite this
ambiguity and discrepancies in the actual percentages, most surveys--
including opinion surveys by mainstream media groups-- consistently show
a steady increase in the number of Americans who are interested in some
form of labeling of genetically engineered foods.
The complexity of US agriculture makes accurate labeling a difficult
challenge. Genetically engineered crops are treated simply as different
varieties of a crop, and are not segregated from non-GE crop varieties-from
the farm all the way to the finished food product. Genetically engineered
corn, for example, is continually mixed with non-GE corn in harvesting
equipment, in trucks, in grain storage buildings, in mills where the corn
is ground into flour, and in processing plants where the flour is incorporated
into a finished food product. Many farmers grow GE and non-GE varieties
of the same crop in the same field and harvest them together. The ability
to implement an accurate system of GE food-labeling would have to be based
on some new system of variety tracking from farm to market, and the infrastructure
to support that kind of system has not yet been developed.
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What do you label?
The first order of business in considering a labeling strategy is to
define exactly what is to be labeled. In the US and some other nations
following the US lead, labeling is "product-based"-- that is,
only if there is a detectable nutritional difference in the product,
such as increased allergenicity, increased/decreased nutrient levels,
increased toxicity, etc. Some other nations are considering systems that
are "process-based"-- labeling merely because something is genetically
engineered, regardless of actual differences in nutrition or heath risk.
The presence of GE ingredients can be determined by detecting the novel
gene (DNA) and/or protein that the GE plant carries. But processing often
destroys or removes these traces entirely. For many highly refined food
ingredients, such as sugars, oils, syrups, etc, there is no method available
to determine if they were extracted from GE plants or not, because there
are no longer any detectable differences. In countries currently considering
labeling strategies, most include labeling of whole foods and moderately-processed
foods (like breads, breakfast cereals, etc), but exempt highly-refined
food ingredients (ironically, very few whole foods are actually genetically
engineered). Many labeling plans under consideration exempt from labeling
"point-of-preparation" foods, that is, foods served at restaurants.
Most labeling systems also exclude animal products from animals fed genetically
engineered feed, because it is impossible to detect the difference-- no
DNA or protein from the GE feed remains in the animal product.
What might a label say?
Most commonly-discussed labeling options fall into one of two categories:
affirmative labels-- including statements like "may contain
GMOs," or "made from genetically engineered ingredients"--
or negative labels-- using phrases like "GMO free" or
"produced without the use of genetic engineering."
Affirmative labels are meant to indicate the presence (or possible
presence) of a food or food ingredient made from a genetically engineered
organism. In reality, the phrase "may contain…"
is probably a more accurate form of affirmative labeling than "does
contain…." Because the mixture of GE and non-GE plant products
arriving at food processors' doors will change from truckload to truckload,
processors would find it difficult to adjust food labels to state exact
percentages of GE ingredients every time the mixture changed. Further,
some shipments would not contain any GE plant products at all, making
"does contain…" labels occasionally inaccurate. Thus,
a "may contain…" type label may be the most practical
type of affirmative labeling.
What products would carry a "may contain…" label? Almost
everything! Most whole foods in the market are not currently generically
engineered. However, the widespread use of corn and soy as inputs for
food ingredients-- two crops of which GE varieties are very commonly
grown in the US-- would mean that an estimated 60-70% of processed
foods would carry a "may contain…" label. In most cases,
several (or even many) different ingredients in a single product are
made from corn and soy-derived ingredients, and might all be labeled
individually.
One of the disadvantages of affirmative labels is that they might be
interpreted to be a warning statement. Because there isn't actually
any evidence that GE foods are harmful to human health, food processors
argue affirmative labels might unnecessarily stigmatize the product.
Even worse: affirmative labels that include an additional statement
to the effect that "there is no evidence that GE foods are unsafe
for human consumption" might actually backfire and make consumers
more concerned-- "if there isn't any evidence that they
are unsafe, then why do they need a label saying I shouldn't worry?"
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The second category of labeling includes negative statements
that indicate the absence of ingredients derived from GE organisms.
This form of labeling is already being used on some products in the
US, particularly on products marketed as "organic," and includes
statements like "made without GMOs" or "GMO free."
It should also be noted that current US organic farming standards prohibit
the use of genetically engineered organisms, so products labeled as
"organic" are also implicitly "GMO free." Negative
labeling of products may be more costly, because it requires more careful,
active control of the supply of food inputs, from the farm to the finished
product.
One of the weaknesses of negative labeling is the problem of thresholds.
Assuring that something is truly "GMO free" is limited by
the ability to detect small traces of GE products. If, for example,
current sampling and detection methods cannot detect traces of GE ingredients
less than 1 in 10,000 (hypothetical example), then any food with traces
less than 1 in 10,000 could pass as "GMO free." Furthermore,
because it is often difficult to prevent small traces of GE even in
very controlled production systems, some producers request (or could
be forced to accept) a legal threshold. Thresholds allow food
to be labeled as "GMO free" (or not have to be labeled as
"containing GMO's") as long as it contains traces lower than
a certain fraction-- perhaps something like 1% (a standard used in some
European countries).
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Another weakness of negative labeling is that a "does not contain…"
label might imply that an unlabeled product "does contain…"
but that might not necessarily be true. In the US, there are some marketers
that advertise and label their products as "GMO free" when
in fact they contain no ingredients that could be genetically
engineered. Could an apple be labeled "not genetically engineered"
if no apples are genetically engineered (and they are not)? Or
to make things even more confusing, what if varieties of GE tomatoes
have been approved in the US but are not marketed? Could some tomatoes
be labeled as "GMO free" even though all tomatoes on the market
are (this is true)? Furthermore, some producers feel that negative labels
might imply that "GMO free" products are healthier in the
absence of evidence that they are.
How do you assure a label is
accurate?
The accuracy of label claims would have to be supported by some form
of testing and certification system, hiring inspection agents and test
kits for each step of the food system. The least expensive option is a
simple certification process, a "paper trail" from farm
to market-- that growers sign a form stating GE grain was not grown, the
miller signs forms stating only grain from non-GE growers was purchased,
etc. The weakness of a "paper trail" system is that inadvertent
(or deliberate) contamination goes undetected, and necessitates some form
of actual testing.
On the other hand, most testing kits to detect the presence of GE grain
are expensive, time-consuming, and require large samples of grain to ensure
accuracy-- all much more so than the kinds of tests grain handlers routinely
use. Some tests currently require samples to be sent to a laboratory--
not a very practical option if a truckload of produce is waiting for clearance
at the loading dock. As mentioned earlier, for some products there are
no tests that can detect the difference between GE and non-GE products
(canola oil, for example). A mandate to label all genetically engineered
foods and food ingredients would probably require some combination of
both certification and testing-- and the balance of the two could have
an impact on the cost passed on to consumers.
In considering a new mandatory labeling law, the Australia New Zealand
Food Authority (ANZFA) commissioned a study to estimate the cost of its
proposed legislation. The study suggested that the new legislation would
increase the cost of food production 6% in the first year, and 3% in following
years-- a burden consumers would likely have to carry. ANZFA did not accept
the findings of the study, however, concluding that the study assumed
a much more elaborate system of testing and certification than it had
intended. The new legislation will go into effect in December 2001.
In a nutshell
Current FDA policy mandates the labeling of genetically engineered foods
only if the food has some nutritional difference. Several other nations
around the world are moving towards systems of mandatory labeling-- all
GE foods are labeled, regardless of health risks-- and public opinion
surveys in the US suggest there may be growing support for a similar system
here. Several factors must be decided in developing a meaningful labeling
policy, including 1) exactly which foods should be labeled, 2) what the
label should say, and 3) how to ensure that the label is accurate. In
addition, mandatory labeling systems may require some investment in infrastructure
to support the segregation, tracking, and labeling of GE foods from field
to market.
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