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McHughen paper (03-65)

Mandatory Process based labeling: To serve whom and at what cost?

Alan McHughen, D.Phil., FACN

University of California, Riverside


Consumers, according to various surveys, demand labels on foods produced using biotechnology, the process of genetic engineering (GE). The usual justification is to enable an ?informed choice?. But is consumer choice the purpose of food labels? Will such mandatory process-based labels provide meaningful and truthful information? Or simply satisfy curiosity at the cost of credibility in health safety and nutritional labels?

Traditionally, mandatory food labels describe the chemical composition of the food, including such parameters as protein content, calories, minerals and any potential allergenic or toxic substances. Recently, and coincidental with the development of foods using biotechnological methods, also called genetically engineered (GE) or genetically modified (GM), some consumers have campaigned to label foods according to the process by which they were developed. That is, they would like to see labels saying ??produced from genetically engineered tomatoes? or similar wording. This demand includes labels not only on the genetically engineered product itself, but on derivatives, including refined substances lacking DNA and protein, and even on products from animals fed on biotech feed. ?

The impetus for process based labeling is largely a fear of the new technologies. The justification is the consumer?s ?right to know? what they?re buying and how it was made.

For consumer advocates like me as well as for casual observers, this is a compelling argument. After all, if we?re expected to put our money down to acquire a product, don?t we have the right to know exactly what it is and how it was made? Furthermore, how can we consumers exercise our right to choose if we?re not provided with accurate information? A pillar in the foundation of both free market capitalism and also of the consumer movement is informed choice in the marketplace. Without process based labels, the argument goes, consumers cannot exercise informed choice, to the detriment of both market and consumer. Again, a compelling argument to support mandatory process based labels.

On closer analysis, however, fundamental problems arise both conceptually and practically in implementation of process based labels. Because of these problems, implementation of mandatory process based labels will, instead of facilitating informed choice, actually preclude it.

The status

Food label regulations currently mandate compositional information for nutritional and identified health hazards (e.g. presence of allergens). Regulations now require labels for any new foods, including those involving biotechnology, ? IF there is a change in nutritional composition or if a component is toxic or allergenic. A new tomato with increased lycopene content will have to state that on a label, regardless of whether biotech was used in the process or not. Similarly, a new tomato with increased tomatine content would also have to have that on the label, regardless of breeding method, although it is unlikely that such a toxic product would be released. Ordinary plant breeding does occasionally produce foods with increased toxicants; they are usually, but not always, caught and eliminated prior to commercial introduction (Kuiper et al; 2001).

Under standard labeling regulations, the information is based on the quantifiable chemical components of the food product, regardless of the process of introduction. This traditional policy is objective, verifiable and enforceable because the constituent properties of the food can be independently measured, and label claims can be enforced.

Process based labeling shifts from the objective accounting of the composition of foodstuffs to a largely subjective, unverifiable, and often unenforceable system based on serial affidavits from multiple stakeholders. For example, under current regulations, if a food says ?Contains 25mg sodium?, anyone can send a sample of the food to a lab to objectively verify the sodium content. On the other hand, if the label says ?This corn oil is produced from genetically engineered corn?, the consumer has no independent and objective means to verify the label, because the





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