Labeling Issues Complex,
Potentially Costly for Consumers

This information was provided by
the Institute of Food Technologists - Chicago, Illinois

It seems so simple. Just a few words on a food label, how hard is that? It isn’t until you really start to think about it that you realize just how complicated those few words can be. This is especially true about the labeling of rDNA biotechnology-derived foods.

“A food label is only useful to consumers if it is easily understood, truthful, and not misleading. Creating a program that meets the needs of the consumer can be far more difficult and complex than many people realize,” according to Dr. John Vanderveen, scientist emeritus with the Food and Drug Administration in San Antonio, Texas. Vanderveen chaired the expert panel that produced the 'labeling section' of the IFT Expert Report on Biotechnology and Foods.

Labeling a food isn’t just deciding what words to use and where to put them on the label. It means defining the terms used in the statement, setting product purity standards, and establishing procedures to verify and document the truthfulness of the statement. What does “low fat” really mean to the average consumer? How can I be sure this is really a low fat cookie?

In addition to the scientific challenges, any labeling program-whether mandatory or voluntary-must balance complex legal issues, such as manufacturers’ free speech rights and consumers’ right to know material facts about their food.

“To be effective, a labeling program must be based on well defined terminology, criteria, and verification standards that are science-based,” Vanderveen said. “If consumers don’t have confidence in the accuracy and reliability of the label information, it is useless.”

Given the widespread use of biotech crops and the nature of the U.S. food distribution system, labeling initiatives for rDNA biotechnology-derived foods are likely to have substantial effects on the production, distribution, and cost of food to consumers. Because consumers often consider only adding the new statement to the existing label, they perceive the cost of a labeling program to be minimal. But depending on the labeling criteria, the costs of product segregation, monitoring and verification can be substantial.

The criteria selected have a profound impact on the complexity, and hence the cost, of a labeling program. The degree of purity required affects the stringency of product segregation procedures and the choice of verification methods. Verification methods usually consist of final product testing, producer validation and market segregation, or third-party certification. It’s a trade-off. For example, supplier certification, generally considered less expensive than product testing, is also considered less accurate and therefore might not be acceptable for a labeling claim that required a high degree of product purity.

The sensitivity of currently available test methods for detecting rDNA biotechnology-derived organisms greatly exceeds the capabilities of the existing U.S. grain handling and distribution systems. A labeling program with a low de minimis threshold might require a new dedicated system for non-rDNA biotechnology-derived products. It may be unrealistic to expect a grain handling and distribution system that tolerates, for example, 1 percent corn as “foreign material” in soybeans to exclude a comparable, if not lower, level of rDNA biotechnology-derived soybeans.

“It is critical that any labeling initiative for rDNA biotechnology-derived foods achieve broad stakeholder agreement regarding the appropriate substantiation of claims based on definitions and monitoring tools sufficiently precise to meet the labeling objectives,” Vanderveen said. “However, consumers must be prepared to bear the costs associated with these initiatives if they desire labeling for products that are free of rDNA biotechnology-derived ingredients.”