THE VEGETARIAN RESOURCE GROUP’S TESTIMONY ON THE LABELING OF MEAT PRODUCTS CONTAINING CULTURED ANIMAL CELLS

The Vegetarian Resource Group sent in the
following testimony to USDA in October, 2021. We
did not address every question they asked in the request for comments since
whether or not a product is labeled pork loin containing cultured animal cells
as opposed to pork containing cultured animal cells did not seem like
“our” issue.

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

Response to question
1:

We believe that the
name or statement of identity of meat or poultry products comprised of or
containing cultured animal cells should inform consumers about how the animal
cells were produced. Vegetarians do not eat meat or poultry and would want to
be aware that a product contains cultured animal cells. We assume that this
would also be the case for those with an allergy to meat or poultry products
and for those who avoid these products due to religious beliefs. In addition,
consumers may not want to purchase products comprised of or containing cultured
animal cells due to concerns about the negative environmental impact of
producing these products.1

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.2 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.3

Since so many
consumers would choose not to purchase a product produced using animal cell
DNA, it is important that consumers be informed about the presence of cultured
animal cells in products in clear, easily understood language. This should be
indicated in the product name and in the ingredient list on the product label
so that consumers can be aware of the product’s composition.

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. This information should also be
presented in clear, easily understood language.

Response to question
2a:

Use of a term such as
“engineered using cultured animal cells” would help consumers understand that
the product is based on animal products and that animal 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.

Response to question
3:

Meat and poultry products
that are comprised of both slaughtered meat and cultured animal cells should be
required to be labeled in a way that clearly informs consumers that the product
contains both slaughtered meat and cultured animal cells. It is important to
specify that the cultured cells are animal cells so that consumers can decide
whether or not they want to purchase a product containing animal cells. As
discussed in our response to question 1 above, consumers are reluctant to
purchase a product derived from animal cell DNA. Information about product
composition should appear on the label.

Response to question
4:

The terms
“vegetarian,” “vegan,” and “plant-based” should never now or in the future be
used in the product name or on the product label of a food comprised of or
containing cultured animal cells. This terminology would be a misrepresentation
of the food product. Although the FDA does not currently define “vegetarian,”
“vegan,” or “plant-based,” 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). “Plant-based” has a variety of
meanings but it is commonly used to indicate that a product is vegetarian or
vegan.4 Having “vegetarian,” “vegan,” or “plant-based” on a label of
a product containing cultured animal cells would be misleading to consumers.

A survey of vegetarian
and vegan groups conducted in 2013 found that the majority did not believe that
a meat alternative grown from animal cell DNA, obtained ten years ago, which
does not currently involve the raising of animals should be labeled as “vegan.”5
This survey, although informal in nature, suggests that advocacy groups would
not support having terms such as “vegan” used on the label of foods comprised
of or containing cultured animal cells.

Additionally, terms
such as “non-animal” or “animal-free” should never now or in the future be used
in the product name or on the product label of a food comprised of or
containing cultured animal cells. Use of these terms would be misleading for
consumers who, for religious, ethical, philosophical, environmental, or other
reasons do not want to purchase products in which animal products were used at
some point in production.

Response to question
8:

FSIS should not
establish a regulatory standard of identity for foods comprised of or
containing cultured animal cells unless this standard of identity clearly
states that the food is comprised of or contains animal cells and that this
information is required to be included on the product label in both the name of
the product and in the ingredient list.

Response to question
12:

FSIS-regulated broths,
bases, and reaction flavors produced from animal cells should be required to
declare the source material in the product name and in the ingredient listing.
This information will allow consumers to choose whether they want to purchase
these products. Additionally, the terms “vegetarian,” “vegan,” and
“plant-based” should never now or in the future be used in the product name or
on the product label of broths, bases, and reaction flavors comprised of or
containing cultured animal cells for the reasons discussed in the response to
question 4.

Response to question
13:

The presence of
cultured animal cells in further processed products regulated by FSIS should be
identified on the product label, both in the product name and in the ingredient
listing. This information will allow consumers to choose whether they want to
purchase these products. Additionally, the terms “vegetarian,” “vegan,” and
“plant-based” should never now or in the future be used in the product name or
on the product label of further processed products comprised of or containing
cultured animal cells for the reasons discussed in the response to question 4.

Thank
you for the opportunity to comment on this issue.

References

1. Meat Atlas. https://eu.boell.org/en/MeatAtlas.
2021; pp. 60-61.

2. What vegetarian and vegan
products will American adults purchase? Questions asked by The Vegetarian
Resource Group in a national poll.  https://www.vrg.org/nutshell/harris2020veganadultwriteup2blog.pdf. 2020.

3. How many youth in the U.S
are vegan? How many teens eat vegetarian when eating out? https://www.vrg.org/nutshell/Yougov2021youthteenwriteup.pdf.
2021.

4. What does plant-based
actually mean? https://www.vrg.org/journal/vj2018issue4/2018_issue4_plant_based.php.
2018.

5. What do vegetarian groups
consider vegetarian and vegan? https://www.vrg.org/journal/vj2014issue2/2014_issue2_what_do_consider.php.
2014.