We welcome the opportunity to comment on Labeling of Foods
Comprised of or Containing Cultured Seafood Cells. As a consumer
organization, we prioritize providing clear, helpful label information that
consumers can use to make an informed choice.

     We believe that
the name or statement of identity of foods comprised of or containing cultured
seafood cells should inform consumers about how the animal cells were produced.
Vegetarians do not eat seafood and would want to be aware that a product
contains cultured seafood cells. We assume that this would also be the case for
those with an allergy to seafoods and for those who avoid seafood due to
religious beliefs.

     In 2020, a survey
was conducted online within the United States by The Harris Poll on behalf of
The Vegetarian Resource Group from June 22-24, 2020 among 2,074 U.S. adults
ages 18 and older. We found that more than half of the U.S. adult population
(54%) always or sometimes eats vegetarian (including vegan) meals when eating
out. We asked if survey respondents would purchase a meat alternative grown
from animal cell DNA obtained ten years ago, which does not currently involve
the raising of animals. Only 12% of respondents said they would purchase such a
product; 19% of vegetarians including vegans would purchase a meat alternative
grown from animal cell DNA; 19% of those that sometimes or always eat vegan
meals when eating out and 18% of those that sometimes or always eat vegetarian,
including vegan, meals when eating out would purchase this type of meat alternative.1
Similarly a 2021 national survey was commissioned by The Vegetarian Resource
Group and conducted online by YouGov, of 8 -17 year-olds. This survey found
that more than half (53%) of 8-17 year-olds sometimes or always eat vegetarian
meals when eating out. As was done in the adult poll, we asked if survey
respondents would purchase a meat alternative grown from cells (DNA) from an
animal, which was collected years ago which does not currently involve the
raising of animals. Only 9% of respondents said they would purchase a meat
alternative grown from animal cell DNA.2

     While we do not
have results specifically examining seafood cell DNA, we imagine that results
would be similar.  Since so many consumers would choose not to purchase
such a product, it is important that they be informed about the presence of
cultured seafood cells in products.

     In addition to
label information, it is important for companies to have specific information
about the source of these cells in their products on their websites since many
people look on product websites for information.

     Use of a term
such as “engineered using cultured seafood cells” would help consumers
understand that the product is based on seafood and that seafood cells are used
in production. An educational program would need to be developed to inform
consumers about the meaning of “cultured” in this context. This terminology
should be prominently delayed on the product’s label so that consumers are
aware of the product’s composition.

     Names for conventionally
produced seafood products should be included with the phrase “engineered using
cultured seafood cells” with the specific seafood whose cells were cultured
identified using the common or usual name.  If consumers generally use a
specific name for a certain fish or shellfish, this name should be used as long
as it is clear to consumers that the products are made using cells of fish. For
example, a product might be labeled, “Engineered using cultured catfish cells.”
This would allow consumers who avoid certain types of seafood to be aware of
the type of seafood used in production. This is especially important for
consumers with a shellfish allergy or who keep kosher and do not eat certain
kinds of fish or shellfish.

     Creating a new
name for a food that is comprised of or contains cultured seafood cells and
using it in The Seafood List is likely to confuse consumers. We believe that
the use of a descriptor such as “engineered using cultured catfish cells” is
more informative than assigning a product a new name.

     In addition, we
urge the FDA to forbid labeling products containing cultured seafood cells as
“vegetarian” or “vegan.” Although the FDA does not currently define
“vegetarian” or “vegan,” these terms are commonly used to imply that products
do not contain ingredients from meat/fish/poultry (vegetarian) or from all
animal products and by-products (vegan). Having “vegetarian” or “vegan” on a
label of a product containing cultured seafood cells would be misleading to

     Thank you for the
opportunity to comment on this issue.


1. What vegetarian and vegan products will American adults
purchase? Questions asked by The Vegetarian Resource Group in a national poll.

2. How many youth in the U.S are vegan? How many teens eat
vegetarian when eating out? 2021.