After USDA's Food Safety and Inspection Service asked several questions about how meat made from animal cells should be labeled, it received a flood of responses.
When the comment period closed, Food Dive examined all of the submissions and the suggestions and sentiments they made. This tracker includes all of the comments from companies, industry groups, foreign and state governments, trade groups, consumer groups, public officials and a well-known plant-based industry entrepreneur — but not private individuals or anonymous commenters.
These comments are listed in alphabetical order, and each listing contains an excerpt from that group or individual's comments. Comments can be filtered by the type of person or group, whether they work with the cell-based space, the labeling terms that they prefer for these products, and the terms they believe should be avoided. Grammar, punctuation and typefaces have not been altered.
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Our farmers are leaders in their field, practicing genuinely high-welfare, sustainable stewardship and responsible management—and like all farmers, continuing to produce in the face of significantly challenging economic and environmental conditions. These conditions will not be improved with the introduction of a poorly labeled, techno-industrial protein product that undermines their markets while offering few if any of the benefits they currently provide to families and communities across the country and beyond.
…Farmers and consumers deserve transparent markets that allow fair competition and informed choices. Any product which did not originate from a live animal, born from another live animal and raised on a farm, should not be labeled as meat or poultry (or their equivalent) and should be clearly identified as animal cell culture technology. Importantly from both a transparency and food safety/allergenic perspective, the product should also clearly specify any and all species of animal cells it derives from.
Academy of Nutrition and Dietetics
A number of terms would be potentially false or misleading to consumers, including “cell- based meat,” “cellular meat,” “clean meat,” “cultured meat,” “slaughter-free meat,” “cruelty free meat,” and “sustainable meat.” First and foremost, we reiterate that marketing- friendly terms designed to advance relative or comparative merits are not appropriate unless they provide clarity as to the actual process used. For example, “clean meat” is an inherently relative term that provides nothing from which consumers could readily infer any objective information or differentiate it from other meat products. In addition, we note that many commentators have questioned whether there is sufficient data available to assess the environmental impact of cultured meat and poultry products to even ascertain a comparison to other meat production methods. The term “sustainable meat” asserts facts not (yet) in evidence, but more importantly fails to provide information about the actual process that would putatively make it the more sustainable option. “Cell-based meat” provides some accurate information about the process, but because all meat is cell-based, it is misleading and fails to differentiate it from conventional meat.
Laboratory manufactured proteins from cultured cells is a direct threat to the livelihood and economic well-being of U.S. producers nation-wide. Manufacturers of cultured cell proteins have a goal to not only replace traditionally raised meats but also demean and disparage the natural production process of traditional meats, while obscuring and withholding their process of production process to consumers.
Consumers deserve the right to know how these cell-derived protein alternatives are manufactured and any efforts by these manufacturers to blur and confound consumers by not distinguishing the production difference versus traditionally raised meats via label claims should not be allowed.
Alabama Farmers Federation
We oppose the use of any nomenclature used to refer to this product in the marketplace, and on the labeling of this product, other than "cell-based food product derived from meat and poultry” as well as the use of commonly used nomenclature or specific meat" terms such as beef, chicken, pork, turkey, lamb, veal and fish or specific cuts of meat such as roast, steak, ground, breast, chop, filet, etc. on a lab-grown product label.
...The Alabama Farmers Federation has a natural interest in the long-term success and viability of farmers in the meat and poultry business. However, we want to be clear that our comments do not represent an attempt to prevent new technologies from entering the marketplace.
Aleph Farms is therefore not an alternative meat company – rather, we make meat using an alternative production process.
…Aleph Farms believes that it is important to convey to consumers that the product is a cultivated meat product (or cultivated poultry product) that does not come from a slaughtered or harvested animal. However, we do not believe that any additional specific information about the process of how animal cells are produced should be required in the product name, or on the product label. We believe that cultivated meat companies will want to voluntarily supply additional information in order to educate and build consumer confidence around cultivated meat products.
American Dairy Coalition
Farmers and ranchers have an economic interest here. With the largest meat packers involved in research, development and production of lab-grown cells, the blending of genetically-edited cell blobs with real boneless beef, for example, can be used to dilute natural beef, giving these large processors even more control of market price and margin with a “captive supply.” We already see retail beef prices at high levels while farmers and ranchers are paid low prices. These genetically-edited products, if not properly and distinctively labeled, have the potential to further concentrate the market power through dilution, which harms both consumers and farmers. Clear and distinctive labeling are imperative so that farmers and ranchers can differentiate real beef, real meat, and so consumers can make informed choices.
American Farm Bureau Federation
AFBF policy states the following: “We support prohibiting the use of commonly known and industry-recognized “meat” terms in the labeling and advertising of all lab- grown and plant-based alternatives. We oppose the use of any nomenclature used to refer to this product in the marketplace, and on the labeling of this product, other than “cell-based food product derived from meat and poultry” as well as the use of commonly used nomenclature or specific “meat” terms such as beef, chicken, pork, turkey, lamb, veal and fish or specific cuts of meat such as roast, steak, ground, breast, chop, filet, etc. on a lab-grown product label.”
American Grassfed Association
Any product which did not originate from a live animal, born from another live animal and raised on a farm, should not be labeled as meat or poultry and if allowed to be labeled as such, should be clearly identified as animal cell culture technology. The meat and poultry act clearly does not allow meat and poultry products other than from slaughter. To allow cultured cells as amenable meat and poultry would require amending the meat and poultry act. These products should be required to be segregated from pasture-based products in the retail space. Advertising for these products, if allowed at all, should have warning labels, such as with tobacco, about the possible health effects of ingesting these products and the effects on human health should be monitored and reported consistently on USDA’s consumer facing website, social media and bulletins.
American Sheep Industry Association
We oppose cell-cultured meat and meat products being permitted to use nomenclature associated with protein sourced from traditional livestock production and these proteins claiming to be equivalent to, or a substitute for, proteins derived from livestock production. We support the definition of “lamb” to only include products derived from actual livestock raised by sheep farmers and ranchers and harvested for human consumption. Products comprised of cultured animal cells are not equivalent to, or a substitute for, meat and meat products derived from livestock production.
AMPS Innovation does not support adoption of a specific standard of identity for foods comprised of or containing cultured animal cells. First, based on our current assessment of the new technology, we expect the meat products produced through cell culture technology will be comparable to their conventional counterparts in terms of appearance, texture, nutritional value and composition. It is thus appropriate for these products to be freely substituted for meat and poultry in applicable standards of identity. AMPS Innovation supports use of the term "cultivated" to differentiate meat produced using cell culture technology from conventionally harvested meat in the interests of consumer transparency. However, this distinction is intended to empower transparency and is grounded in the recognition that differences in production method may be important to consumer choice; it is not intended to suggest a material difference between the cultivated and conventional products, as a class, in terms of functional, nutritional or chemical characteristics.
Animal Legal Defense Fund, American Society for Prevention of Cruelty to Animals, Animal Welfare Institute and Humane League
Ensuring cell-cultured meat and poultry products can be identified with the same names as slaughter-based products ensures consumer understanding and may even protect the public health. FSIS should reject out of hand any irrational, counter-productive, and potentially dangerous labeling requirements for these new cultured meat and poultry products — as such measures represent nothing more than an attempt to stifle competition and consumer choice.
...If a final product is meat or poultry on a cellular level, it should not be subject to burdensome, restrictive, or potentially inaccurate labeling requirements simply due to its distinct production process. Again, FSIS has previously stated that the agency “does not consider animal production practices to be material facts that must be disclosed in the product label.” This is the case even despite the fact that in recent survey evidence, more than three out of four consumers reported being concerned about the welfare of farmed animals, and eighty percent of consumers reported that good living conditions for animals are “very important” or “important” to them.
...[P]roducers of slaughter-free meat and poultry products are already incentivized to ensure that consumers are able to distinguish slaughter-free products from conventional meat and poultry varieties. They are thus likely to voluntarily employ claims and qualifiers that identify the products’ nature.
Arizona Department of Agriculture - Animal Services Division
Arizona Department of Agriculture believes that meat is skeletal muscle tissue or parts there of derived from living breathing animals. It is our view that animal cells grown in a laboratory are not MEAT as per the definition and should be prohibited from being labeled as such. We also believe that advisory statements should be predominately displayed on all labels for this product stating exactly how it is made and that it is not from traditional muscle tissue so that the consumer knows exactly what they are buying. We also have concerns on the long term effects that consuming this product rnay have on the American consumer.
Arizona Farm Bureau
As a member of the American Farm Bureau Federation (AFBF), our policy position regarding the labeling of cell-cultured meats aligns. We support and incorporate by reference the comments filed by AFBF, which respond to questions in the ANPR on which the organization has policy.
Artemys Foods supports a labeling requirement that differentiates our products from those produced using conventional herding and slaughter methods. Artemys is committed to supporting and complying with principles that ensure labeling is truthful and not misleading, does not disparage cultivated or conventional products, enables consumers to distinguish between such products, and is consistent with the safety and nutritional qualities of the product.
…Based on several consumer studies, and with consideration given to the processes by which our products are made, Artemys Foods believes the term “cultivated” is sufficiently descriptive to convey to consumers that a meat or poultry product is comprised of or contains cultured animal cells. For example, “cultivated beef” or “cultivated chicken” is appropriate to distinguish from conventionally produced meat and poultry products and indicate the technology used in the production process. Appropriate labeling would be extended to products with additional descriptors, for example “cultivated hamburger, “cultivated chicken nugget”, etc.
As cell-cultured meat products are going to be entering the market, it will be important to inform the customers of these novel food products and creating a clear and easy to understand labeling.
The industry has not yet settled on a specific term for meat consisting of or containing cultured animal cells. However, the terms “cell-cultured” and “cultured” have gained great popularity as they are easy to understand and clearly describe the production method of the meat through cell culture, without having a negative impact on the consumers purchasing decision. Other terms such as “clean”, “lab-grown”, or “cultivated” are less optimal as they are misleading or negatively affect the industry.
This new production method of meat will be one that consumers will seek to purchase instead of traditionally produced meat products in the same way as customers look for “organic” labels on products.
‘Cultivated’, in our opinion, evokes 'farm land, pastures, growing crops', which misleads consumers and mystifies the process, rather than communicating about the production method. From our experience with potential consumers, we’ve found that transparency must be a core part of a cellag messaging. ‘Cultivated’ does not offer clarity to consumers about the product and instead reminds consumers about other types of more traditional agriculture.
While the term ‘cultivated’ can reasonably apply to certain meat production conditions, attempting to use ‘cultivator’ to describe bioreactors or fermentation tanks is truly confusing to us, as neither resemble tractors or large equipment that harrows or tills fields. Middle America has clear connotations and associations with both words, and utilizing that to describe a scientific and lab-synthesized product is misleading.
BlueNalu believes that "cell-cultured" is the most appropriate term for seafood products derived from fish cells, and this term was also supported by the National Fisheries Institute and the Alliance for Meat Poultry and Seafood Innovation in a joint letter signed by both organizations in response to the FDA's RFI.
California Cattlemen's Foundation
[T]here is little to no data that has been collected on ACBP [animal cell-based products]. Due to the lack of information, experts in the field have made it clear that the safety, quality and characteristics of ACBP remain an unknown.
Thus, using any label that equates or associates ACBP with “meat” such as “meat byproduct” or other similar terms are inappropriate and putting the consumer at risk without knowledge of the potential danger. It is imperative that USDA determine an appropriate methodology to establish the safety, nutritional value and food characteristics of ACBP before a regulatory definition is developed and promulgated. This will allow USDA and FDA to efficiently and accurately regulate ACBP as its own product and provide consumer assurances that are legally necessary.
...While labels such as “fake” and “synthetic” are inappropriate labels that may hold negative connotations for the public, highlighting the cultivation process by describing ACBP as “lab-grown” provides clear communication to the consumer what the product is and how it was produced.
California Department of Food and Agriculture; Animal Health & Food Safety Services; Meat, Poultry and Egg Safety Branch
MPES does not support the use of the terms “meat” and “poultry” on labels of products comprised of or containing ACBP [animal cell-based product] since such terms should be reserved for products derived from slaughtered animals. MPES will only approve labels of regulated meat and poultry products that are produced from slaughtered animals. Products solely produced from ACBP would not be under the regulatory oversight of MPES. If regulated products contain ACBP, then these products must follow MPES labeling requirements stating the presence of ACBP (e.g., Italian Style Sausages made with Pork and ACBP).
…Terms such as “Artificially Grown Animal Tissues”, “Artificially Produced”, “Manufactured Animal Tissue”, “Man-Made”, or similar statements that are truthful and factual to the nature or source of the product should be included in the product name.
Canadian Cattlemen’s Association
As a first principal, meat nomenclature should include only products derived from livestock raised by cattle farmers and ranchers and harvested for human consumption. In Canada a meat product is defined under the Safe Food for Canadian Regulations (SCFR) as the carcass of a food animal, the blood of a food animal or a product or by-product of its carcass or any food that contains the blood of a food animal or product or by-product of its carcass. Additionally, standards of identity incorporated by reference into the SFCR, define meat as the edible part of a carcass. CCA asks that FSIS adopt analogous labeling definitions.
Canadian Federation of Agriculture
As such, CFA further believes:
That stem cell cultivated protein does not meet the requirements to be labelled as a meat product, as the cells used to produce stem cell cultured protein constitute far less than 2% of the original meat product;
That any protein cultivated from stem cells that were harvested from a live animal do not meet the definition of meat, defined as the edible part of a carcass; and
That stem cell cultivated protein commodities should not be labelled as meat, given that they do not meet the necessary Federal regulatory and guideline requirements.
Canadian National Institute of Standards and Technology
As the United States considers potential labelling requirements for these products, Canada would encourage that they be aligned with existing approaches for providing consumers with information that is truthful and not misleading. Furthermore, considerations should be given on how best to provide information on labels, including for special statements and claims, in a manner that is clear, transparent, predictable and substantiated by verifiable evidence.
Canadian Sheep Federation
Commercial protein products derived from cultivated skeletal myocytes from animals are more appropriately labelled as ‘synthetic animal protein’. This terminology accurately reflects the origin of the product that consumers can more readily understand. Think synthetic diamonds and synthetic oil. Neither less valuable than the original product they are intended to substitute, and often a desirable alternative...labelled to ensure consumers make informed buying decisions. The term ‘synthetic’ is not a denigratory name. Rather, it is a term widely accepted by consumers to represent a similar end product made from a different source. Conversely, the term ‘cultured’ offers diverse connotations that can be influenced by perception and mislead consumers to interpret it to mean ‘refined’, ‘superior’, ‘advanced’, ‘distingue’ or some other manner of misinterpretation. Labelling nonmeat protein sources as cultivated meat or poultry goes against the very grain of our country’s fight on food fraud.
Center for Food Safety (petition)
At least 70 companies are attempting to grow cells from meat and poultry in huge vats.
Many of these companies are growing the cells in a bath of fetal calf serum obtained by taking embryonic calves from pregnant cows. USDA should not allow the production of cells cultured in fetal serum from any animals or the labeling of such products.
Other companies are experimenting with using genetic engineering to make the cells grow as though they are embryonic cells, making 'pluripotent' cell lines. Some of the genetically engineered cell lines come from genetic sequences, like P53, known to cause cancer. The USDA should ban the use of those cell lines that use genes known to contribute to cancer and not permit their sale or labeling.
Other kinds of genetic engineering might be considered, but the product must be labeled as “genetically engineered cells cultured from [name of animal, i.e. chicken, beef, lamb].” Thank you.
Center for Food Safety and Food and Water Watch
The names used for these products should clarify how different this new technology is from traditional meat and poultry products. “Synthetic cell-cultured meat and poultry product” could be the generic product name, with the product specifying which animal cells it derives from. For example, “Made with synthetic cell-cultured protein derived from bovine cells.” “Synthetic Cell-cultured” would not risk confusion with other cultured products.
...The common names or standards of identity of such products derived from cultured animal cells should NOT include names for products established by common usage. Names of various cuts of meat automatically include the physical and anatomical structures of the cut. That is the amount of fat, the structure and “mouth feel” of the cut. These attributes will not be found in the synthetic cell cultured forms. Using the common terms like loin, flank steak, T-bone, etc. would constitute a kind of consumer fraud.
Center for Foodborne Illness Research and Prevention, Ohio State University
CFI recommends that any meat and poultry products derived from cell-cultured technology be labeled in such a way that consumers can clearly understand what the product contains. CFI urges regulators to carefully consider the unexpected consequences of labeling these products since consumers’ knowledge and perceptions about these products are not fully developed. Clear labeling of these products is needed and will help consumers to make better informed consumption decisions.
Center for Science in the Public Interest and Consumer Federation of America
While we do not propose a particular phrase for identifying cell-cultured foods for consumers, we believe USDA and FDA jointly should select a phrase that is accurate, neutral, and informative to consumers. It would needlessly confuse consumers if meat and poultry products used one term (e.g., cell-cultured) while seafood products used a different term (e.g., cell-based). Different terms could lead consumers to believe that products were produced using different technologies or methods when they were not. With such a new technology, and one that is not well known to consumers, it would facilitate consumer understanding if products that are similarly produced also are labeled using the same words or phrases, regardless of the agency that regulates them.
Compassion in World Farming
Based on the literature, CIWF recommends the term “cultivated meat” for three main reasons. First, as stated, “cultivated” concisely and accurately captures the essence of the product and how it is produced. Second, “cultivated” is emotionally neutral for potential consumers and conjures the correct associations with food and agriculture. Although not formally tested, we suspect that the term “cultivated” would be associated with nurturing, thoughtful preparation, and improvement. The word “cultivated” also draws parallels to traditional farming, in which plants are cultivated through planting, fertilizing, and harvesting just as the cells used for cultured meat are “planted” into a scaffold and media, fertilized with nutrients, and then harvested once they have multiplied and grown sufficiently. The research suggests that the label “cultivated meat” will activate more accurate, more palatable, and more familiar associations with food and food production rather than confusing, unappealing, or antagonistic associations with a laboratory or artificiality.
Consumer Brands Association
Consumer Brands recommends that FSIS and FDA align on jointly agreed upon principles for product labeling and claims for these products to, among other things, provide for consistency and reduce or avoid consumer confusion.
Rather than obviously inaccurate and biased names (e.g., “lab-grown,” “artificial,” “synthetic,” etc.), a more accurate and neutral term to allow is “cultivated meat.” Meat cultivation is exactly what’s occurring in such a production facility, and the name doesn’t bias the consumer for or against the product.
“Cultured meat” is another name worthy of consideration, both because of its history of use and its accuracy, though it could be confusing when compared to other cultured foods like yogurt that are using a different type of culturing process. Still, this is a good option that’s both accurate and non-prejudicial.
Earthjustice (on behalf of Animal Legal Defense Fund, Center for Biological Diversity, Environmental Working Group, Johns Hopkins Center for a Livable Future)
While we support greater regulatory scrutiny of all product labels, we urge FSIS to avoid imposing unique requirements that will competitively disadvantage the developing cultured products industry, and to instead enable cultured products to compete on a level playing field with slaughtered meat and poultry products.
Embassy of Canada to the United States
As work continues to explore potential regulatory pathways for lab-cultured proteins, international collaboration through bodies such as the World Trade Organization, the World Customs Organization and Codex Alimentarius will play a key role in ensuring international consistency regarding approaches for these products and minimizing potential impacts on trade.
Cell cultured, Cell cultivated, cell based, In vitro, lab-grown
a) Those terms used as modifier could inform the consumer about what technology was used to make the product they are buying and dissociate regular meat from lab-grown meat. To make sure consumers are aware of what they are getting.
b) Having the name differentiation in it could explain a higher price since it is still very expensive to have cell-based meat. The change would not compromise the actual meat market which is in place for years and all products already responding to the existing standards of identity and meat and poultry regulation in place and reviewed by FSIS.
[W]e support differentiating these products from their conventional counterparts through an accurate and descriptive qualifier that modifies the conventional name of the product (e.g., "cell-cultured beef"). This distinction is intended to empower transparency and is based on the recognition that differences in production method may be important to consumer choice. It is not intended to suggest a material difference between cell-cultured and conventional meat, poultry, and seafood products.
Although we fully support and agree in principle with the comment submitted by the Alliance for Meat, Poultry and Seafood Innovation ("AMPS Innovation") calling for consistency in regulation and oversight of meat, poultry, and seafood products, we believe that "cell- cultured," rather than "cultivated," is the best term for distinguishing products produced through the cell culture process from their conventional counterparts. Indeed, the use of "cell-cultured" as a fact-based qualifier that clearly differentiates a product from its conventional counterparts is supported by peer-reviewed research.
Food Industry Association (FMI)
FMI supports taking a deliberate, evidence-based approach to labeling cell-cultured meat and poultry products. As this new category matures, all stakeholders will benefit from a clear and fair set of product labeling expectations. FMI encourages FSIS to engage in a transparent, evidence-based process that engages all stakeholders.
Fork & Goode
We believe that the term “cultivated” can evolve to be both broadly descriptive across the cultivated meat industry and highly specific to cultivated meat products made by any particular company. Further, the term “cultivated” does not currently serve to describe any existing food processes. A good parallel for our industry is the term “organic” in crop agriculture, as it is a general term that can serve as a shorthand to cover a longer description of a specific set of processes (e.g., crops grown without the use of synthetic pesticides or fertilizers).
Most importantly, we are describing the cultivation of meat, rather than the conventional slaughter of reared livestock. “Cultivated” brings to mind the ancient transition from hunted or gathered sources of food from nature to the adaptation of what has become known as food from “agriculture”. Similarly, cultivated meat marks the transition from meat derived from slaughtering domesticated animals to the harnessing of animal biology to grow animal cells for food outside the animal.
Further Processors Division of United Egg Association
FSIS’s ANPR concerns only meat and poultry covered by the Federal Meat Inspection Act (FMIA) or the Poultry Products Inspection Act (PPIA). However, UEA strongly urges the agency to include egg products covered under the EPIA in any proposed rule.
Future Meat Technologies
FMT prefers the use of the terms “cultivated meat” or “cultured meat” in that they simply and directly communicate to consumers that the articles are meat or poultry that were produced in a non-traditional manner.
...[T]hese cultivated products should otherwise be described as meat or chicken, as applicable, insofar as they are derived from appropriate parts of livestock and poultry and have similar functional, compositional and nutritional characteristics as the conventionally produced counterparts.
Georgia Farm Bureau
GFB supports proper labeling of food products, and believes any plant-based, cell-based, or other food that is not from the flesh of an animal should not have the word “meat” in the product name. These food products also should not use any labeling or advertising that portrays animal flesh meat products in a negative or inferior manner. Further, GFB opposes the use of any nomenclature when referring to cultured cell-based products in the marketplace, and on the labeling of this product, other than “cell-based food product derived from meat and poultry,” as well as the use of commonly used nomenclature or specific “meat” terms such as beef, chicken, pork, turkey, lamb, veal and fish or specific cuts of meat such as roast, steak, ground, breast, chop, filet, etc.
Good Food Institute
A flexible framework that allows companies to truthfully describe their products using a variety of terms would be optimal at this early stage of product development and sale. Flexibility will allow companies to craft accurate labels and give consumers time to develop an understanding of the terms used to describe cultivated products and what they mean. While there is value in establishing clear guidelines for the labeling of cultivated products, it would be premature to establish strict naming conventions before cultivated products have even hit the shelves. Historically, labeling requirements have not created consumer expectations; rather, they have codified existing ones to ensure consumers continue to receive the products they have come to expect. Consumer expectations regarding cultivated meat and poultry products have not yet solidified and cannot be accurately measured at this time, so there is nothing to codify.
...Cultivated meat and poultry producers will likely want to differentiate their products from slaughtered meat and poultry products and should be permitted to do so. FSIS need not, however, require that all cultivated meat and poultry product names differentiate the products from their conventional counterparts. Differentiation or qualification of cultivated products should not turn solely on whether there are any scientifically measurable differences between the cultivated product and its conventional counterpart, but on whether those differences are material.
...“Cultivated” is GFI’s preferred term because it balances an accurate description of the process for creating meat and poultry by growing animal cells in a cultivator with consumer appeal. The term “cultivated” focuses on how the process of creating the product is different from the process behind slaughtered meat. Furthermore, the term “cultivated” is not commonly used in other food-making processes so it is unlikely to be confused with conventional meat products or other foods. “Cultivated” is also a neutral term that is not disparaging to either conventional products or those grown from cells. A recent survey conducted by GFI indicates that a growing number of companies that create proteins from animal cells also favor the term “cultivated,” with 60 percent preferring the term in the regulatory context.
Harvard Animal Law & Policy Clinic and Harvard Food Law and Policy Clinic
At this time, USDA-FSIS should not impose restrictions for the labeling of cultivated meat and poultry products, and any such labeling guidelines should remain flexible as industry consensus develops around preferred nomenclature for such products. Mandating the use of specific terms or labeling practices for cultivated meat and poultry products would both cut against established USDA-FSIS labeling practices and raise significant First Amendment concerns––potentially deterring the marketing and purchase of such products unnecessarily.
Historically, USDA-FSIS has required disclosures only when food safety concerns or material product differences are present in a regulated product. In the case of cultivated meat and poultry products, neither concern is applicable. Most, if not all, cultivated meat and poultry products will be identical in physical composition and function to their slaughter-based counterparts, and the production process for such products does not increase food safety risks, such as in the case of mechanically tenderized meat products, for example. In fact, cultivated meat and poultry products may be prone to significantly fewer food safety hazards.
...However, if USDA-FSIS nevertheless decides to impose any labeling restrictions on cultivated meat and poultry products, USDA-FSIS should equally require that conventionally raised and slaughtered meat be labeled, accordingly, as “slaughtered meat” (or “slaughtered beef patty,” “slaughtered chicken nugget,” etc.), to allow consumers to distinguish clearly between the two types of meat and poultry products. Using the process by which meat and poultry products are created as the primary labeling criterion for both cultivated and slaughtered products would be a fair labeling solution that would allow consumers to identify which type of meat or poultry product they are purchasing, but would not overly burden just one class of product in a competitive marketplace.
If producers voluntarily label food products to indicate they are comprised of or contain cultured animal cells, USDA-FSIS should require those claims to be substantiated by evidence that the products in question do indeed originate from cultured animal cells rather than from slaughtered meat or poultry products. This is to ensure that consumers are not misled or deceived into purchasing products claiming to be comprised of substances they do not contain.
...If the terms “cultivated” and “slaughtered” meat are used to differentiate types of meat and poultry products, both cultivated and slaughtered meat producers will benefit from a clear distinction between the two types of products. Indeed, the conventional meat industry has long sought points of differentiation between slaughtered meat and plant-based meat, and even successfully lobbied for state legislation to restrict the use of terms like “burger” in plant-based meat alternatives. In deference to this concern, some states have gone so far as to ban the sale of cell-cultured meat and poultry products labeled as “meat.” Therefore, cultivated meat and poultry producers would benefit from federal labeling guidelines that allowed for clear, accurate, and effective consumer-facing communications, as well as from the imprimatur of USDA-FSIS approval of their product.
Healthy Earth LLC-Tasty Safety
Healthy Earth LLC-Tasty Safety proposes to use "Cell Based Lab (CBL)" on the label to distinguished from traditionally slaughtered animals.
...I would not change any meat current nomenclature for subprimal cuts, ground etc. Everything must stay the same, if not, you risk confusing the typical retail consumer.
Idaho Cattle Association
The Beef Cattle industry has worked long and hard over many decades to promote and protect our product and its image in front of consumers. The importance of differentiation of the current product, available today, which has been raised in open spaces across our state efficiently and productively, and the lab-grown product that is yet to be available to consumers grown inside a facility trough alternative practice needs to remain.
It is critical that these two products are not represented as one in the same, terms such as Lab-grown or Cell-cultured are the preferred terms for proper differentiation.
International Food Information Council
Though the topics covered within our consumer research vary, one consistent thread is that consumers value transparency when making food choices. In alignment with this theme, IFIC supports efforts by FSIS to increase consumer clarity on meat and poultry products made with cultured animal cells.
Kansas Cattlemen's Association
KCA supports the definition of beef to only include products derived from actual livestock traditionally born, raised, and harvested. Cell Cultured products differ materially in conception, growth, harvest, and texture, and therefore KCA opposes these products be labeled as meat.
KCA strongly opposes attempts by cultured cell companies applying any definition, label or reference for any food product traditionally raised and inspected as anything other than “clean” as it is a fallacy of composition and misleading. KCA supports any and all restrictions for alternatives and/or laboratory harvests from defining a product as “clean meat” for the purposes of alluding that traditionally raised protein as something other than clean, wholesome, healthy, and/or safe.
Kentucky Agriculture Commissioner Ryan Quarles
Consumers deserve to know that the word “meat” means something, and that it means meat from an animal. It was for those reasons that I worked with the Kentucky General Assembly in 2019 to pass House Bill 311, which forbid lab-grown protein products from being labeled as meat.
Let me be perfectly clear: the importance of clear and transparent labeling is a consumer protection issue. Kentucky farm families and I believe in the free market and the spirit of competition. As new technology emerges on the scene, it is important that consumer protection agencies on the state and federal level to be proactive in helping educate consumers about new products and giving them the ability to differentiate protein products whipped up in a lab and those raised on a family farm. While I am a supporter of free market principles, it is important that I use my role to fight for transparency and fairness for our agricultural producers and consumers.
Kentucky Farm Bureau
Allowing cell-cultured proteins to market their products as “meat” would certainly cause confusion to the consumer and likely misrepresent what ingredients are contained in the final product. For that reason, we support prohibiting the use of commonly known and industry recognized “meat” terms in the labeling and advertising of all lab-grown and plant-based alternatives.
Kentucky Livestock Coalition
We believe that the production of animal products is best accomplished on a farm or ranch. Consumers should have the right to know if the items in their meat case have been raised according to the animal care standards that we endorse or grown in a lab.
The Kentucky Livestock Coalition urges the USDA to promulgate administrative regulations requiring imitation meat product manufacturers to adopt labeling and marketing technology that is fully distinct from those traditional terms connoting real meat products so that consumers can readily distinguish real meat products from imitation meat products or plant-based alternatives. We believe that the terms “meat” and “poultry” as well as the species-specific terms “pork,” “beef,” “chicken,” “turkey,” etc. should be reserved exclusively for products derived from the flesh of an animal, harvested in the traditional manner, and ask that USDA and other agencies join us in this assertion. We further assert that terms that specify the form of meat or poultry products, such as “filet,” “steak,” “patty,” etc. should be reserved for real meat.
We suggest that products deemed “cultivated meat” by these new standards of identity contain a symbol or marking on the face of their labeling. This mark would be used like a specialized version of the “USDA Organic” marking. This mark should have a consistent design and present the % composition of the product that is cultivated cells.
Mercy for Animals
Overall, the available research contains the most support for the potential of the terms “clean meat,” “cultivated meat,” and “slaughter-free meat” to best encourage consumer acceptance, understanding, and producer innovations. In contrast, these studies indicate that terms containing “cell” or “lab” are likely to be less appealing to consumers.
Missouri Farm Bureau
Missouri Farm Bureau’s member adopted policy states the following: “We support prohibiting the use of commonly known and industry recognized ‘meat’ terms in the labeling and advertising of all lab-grown and plant-based alternatives.”
We use the terminology "plant based" when referring to foods made from plants. Likewise, we say "animal based" when referring to animal foods. Therefore, in the same spirit, we should say "cell-based." Consistent terminology allows consumers to understand the source or origin of the food.
Montana Department of Livestock
1. Montana, like other states, have already passed legislation dealing with the labeling of cell cultured products.
…As you can see from the wording of these statutes the Montana Legislature has made clear how it wants cell cultured products dealt with in commerce within our state. The hope of the MDOL is that any future rulemaking conducted by USDA-FSIS will strongly consider this intent and the desire of the states is taken into consideration to avoid any unnecessary confusion or overreach of state authority.
2. Failure to consider previous state regulations like those passed in Montana can lead to unnecessary confusion over the sell and marketing of cell cultured products in Montana and across the nation.
National Association of State Departments of Agriculture
As coregulators for state meat inspection facilities, NASDA urges USDA to consider the various regulatory frameworks for lab products. Several states have passed legislation to ban lab-grown food from being labeled as “meat” on the market. As innovative products in the food sector continue to emerge, it is essential that standards of identity and labeling requirements are clear and consistently enforced by federal regulatory agencies to maintain the integrity of agricultural products and clarity in the marketplace for consumers. A consistent and modernized approach by federal regulatory institutions is necessary to protect the commonwealth of consumer health and the respective framework of the production standards of the agricultural industry. As part of this entrusted regulatory responsibility, the USDA should advance policies that adequately inform consumers of the nutritional attributes and characteristics of the food consumed by the American public.
National Cattlemen's Beef Association
USDA’s consideration of consumer disclosure related to lab-grown meat can easily be distinguished from other debates related to consumer knowledge of production methods. For example, the ongoing public debate over GMOs differs drastically from the present question. While GMOs alter crop efficiency and resiliency, the production practices remain the same: seed is planted in the soil and grown, then harvested. Lab-grown meat has very little in common with traditionally raised and harvested meat. The production practices have no similarity.
Because these products have yet to reach consumers, no economic hardship would exist related to adjusting labels to satisfy heightened requirements or adjusting labels in a way that may create consumer confusion and loss in market share. The best time to establish these standards is now — the longer USDA waits to effectively establish standard of identity and labeling requirements for these products, the more costly compliance will be for regulated entities and consumers.
...NCBA’s research found that terms that alluded to how the meat is made resulted in greater understanding of the product, such as “cell-cultured” and “lab-grown.” Both terms elicited a partial or full understanding of the product from consumers, prior to defining it. Further, both names performed directionally higher when consumers were asked to score them on their fit with the definition provided and their ease of understanding them. Last, “lab-grown meat” was selected more often for being easy to understand.
Conversely, “cultivated” meat ranked highest in terms of sounding most appealing but scored second lowest in terms of fitting best with the definition provided. NCBA’s consumer survey substantiates misleading terms like “cultured,” “clean,” or “cultivated” fail to adequately describe the production practices to the everyday consumer. In determining how to most effectively name this class of products, the agency must focus on using clean and explicit language, as opposed to terms that have varying definitions.
Terms like “cultivated” and “synthetic,” that are likely less familiar to consumers in general, potentially create unintended perceptions. For example, significantly more consumers perceived “cultivated meat” as being raised on farms or ranches compared to the other names. As a result, when selecting which attributes that apply to that term, more consumers selected things like “is safe to eat” or “is natural,” while selecting things like “is processed” significantly lower than the other names. The term “cultivated meat,” consequently, is being perceived more positively—driven by the fact that more consumers thought it is raised on farms or ranches. “Synthetic meat,” on the other hand, seems to portray to consumers an enhanced meat product, or product altered to be different than traditional meat. Findings showed significantly more consumers agreed “synthetic meat” was processed and high in protein compared to other terms. These two terms should be avoided when defining this product due to their unintended and potentially inaccurate perceptions.
...Finally, “cultivated” is a term that may be effectively applied to any animal protein product, or any food product for that matter, and fails to distinguish cell-cultured protein from traditionally harvested meat products.
NCBA recommends USDA adopt “lab-grown” as an unambiguous description for these products. Unlike the terms “cultured,” “clean” or “cultivated,” “lab-grown” provides a clear and unambiguous description that effectively distinguishes the product from traditionally harvested meat. NCBA also supports “artificially grown” or “artificially cultured” as alternatives. “Artificial” and “grown” are words used in the Webster’s definition of “cultured” and leaves little room for misinterpretation among consumers.
National Chicken Council
The product name should include the term “cell-cultured” or something similar so that it is clear that these products are not derived from traditional animal protein (skeletal muscle). This approach would be consistent with FSIS’s established requirement that product produced through mechanical separation be labeled as “Mechanically Separated (Species/Kind).” Just as FSIS determined that it was important for consumers to understand that mechanical separation was used to produce that product, FSIS should protect existing consumer expectations by requiring that cell-cultured products be clearly identified as such.
…Both products derived from cell culture as well as products containing cell-cultured material should not be allowed to use commonly defined parts terms such as breast, leg, wing, thigh, etc. These parts terms are specific to broiler chickens (and other poultry) and consumers know the meaning of these terms as referring to specific parts of the bird cut from a whole carcass.
National Fisheries Institute
We want to emphasize the distinction between nomenclature that provides the consumer with an understanding of the nature and production process of the cell-cultured products versus the marketability or likeability of the product’s name. While marketability is important, consumers must have a clear understanding of what is being offered for sale with an appropriate descriptive name. The findings of two peer-reviewed consumer studies on the nomenclature for seafood produced with cell culture technology demonstrated that the qualifiers “cell-based” and “cell-cultured” best informed consumers about the nature of these products and facilitated distinguishing cell-cultured seafood from conventional seafood products.
National Milk Producers Federation
[T]o permit lab-grown products to be labeled in a manner identical to traditional foods would be highly misleading to consumers, who would think they were purchasing the same meat and poultry products they had always consumed, when in fact they were not. It is inconceivable that consumers would not want to know that their steak was grown in a laboratory from a single cell rather than harvested in the normal manner. If FSIS doubts this, the agency should conduct consumer surveys and simply ask whether consumers do or do not want to have this information. There is little doubt what most consumers would say.
National Pork Producers Council
Cell-cultured products designed to mimic real meat must face the same stringent regulatory requirements as livestock agriculture, including truthful labeling standards. Foods composed of or containing cultured meat cells are different and distinct specifically because of the process by which the foods were produced relative to meat derived from animals. Federal law prohibits labeling that is misleading by omission of material fact, and the offering of food for sale under the name of another food. As such, products comprised of or containing cultured cells derived from animals subject to the Federal Meat Inspection Act, should be named or described in a way that informs consumers about how the animal cells were produced.
National Swine Registry and American Berkshire Association
[W]e highly encourage FSIS to not allow any products derived in whole or part from cultured animal cells to include a claim of breed, or any word confusingly similar to a breed, in their name or marketing material.
National Turkey Federation
USDA should ensure terms used on the new product category adequately identify the product components and clearly describe the process by which they were sourced and produced, as they are particularly different from the way traditional products are produced and processed. terms “cell cultured” and “cell cultivated” are factual and clearly communicate the product’s origin is not from a live animal but from using cell culture technology. However, general terms such as “cell based” inadequately describe the nature of these products and could be unclear to consumers. We encourage USDA to consider the confusion that consumers might experience if the simple use of “cultured” or “cultivated” which are vague and do not sufficiently describe these products.
In light of the advancements in animal cell-culture technology and the ability to produce these products outside the animal, strong consideration should be given to amending the statutes and implementing regulations to expressly clarify that ‘meat,’ ‘meat byproduct,’ ‘meat food product,’ ‘poultry product,’ and ‘poultry food product’ may also be produced outside the animal. From a biological, chemical, nutritional, or organoleptic perspective, the tissue biopsy obtained from livestock to start a cell culture may be considered ‘meat’ as defined in 9 CFR 301.2.
New York Farm Bureau
Farm Bureau policy states the following: “We support prohibiting the use of commonly known and industry-recognized “meat” terms in the labeling and advertising of all lab-grown and plant-based alternatives. We oppose the use of any nomenclature used to refer to this product in the marketplace, and on the labeling of this product, other than “cell-based food product derived from meat and poultry” as well as the use of commonly used nomenclature or specific “meat” terms such as beef, chicken, pork, turkey, lamb, veal and fish or specific cuts of meat such as roast, steak, ground, breast, chop, filet, etc. on a lab-grown product label.”
Any presence of cultured animal cells, regardless of the quantity, should trigger clear and conspicuous labeling on-pack stating that the product contains cultured animal cells. As such, the Project recommends the following:
1. All meat or poultry products comprised of cultured animal cells should be clearly labeled as such on-pack and with clear, consistent, standardized terminology.
2. All meat or poultry products containing any amount of cultured animal cells or their derivatives should be clearly labeled as such on-pack with clear, consistent, standardized terminology.
3. All meat or poultry products containing any amount of any coproduct or byproduct of cultured animal cells should be labeled as such on-pack with clear, consistent, standardized terminology.
North American Meat Institute
Though the Meat Institute cannot recommend a specific term, there should be a consistent term or phrase to preclude confusion. The term or phrase should be informed by consumer research to ensure understanding. Importantly, the term or phrase should not be misleading or disparage traditional meat and poultry products.
Standards of identity must be upheld.
SOIs help maintain a fair market and ensure consistency, meeting consumer expectations. Though a new standardized term or phase for differentiation may be warranted, the existing standards may apply if used in combination with the differentiation term or phase. If cultured meat and poultry products use existing standardized terms, these new and novel products must be held to the strict parameters that traditional products have met for years. For standardized terms to be used, cultured products must be comparable to traditional products functionally and nutritionally, while providing the same eating experience familiar to consumers. The same should be upheld for unstandardized terms established by common usage and terms that specify form. Consumers should get the same functionality, nutritional value, and eating experience from products using the same terms.
North Dakota Department of Agriculture
This matter was comprehensively appraised two years ago by the 2019 North Dakota Legislature and, with view toward fully informing the consumer, distinctions between cell-based products and natural meat are now well and reasonably clarified.
...This above labeling regimen has been in effect in North Dakota for over two years and has worked very well. "Cell-cultured" or "cell-based" product manufacturers are not permitted to deceptively misrepresent certain products as meat because these products are not derived from harvested production livestock.
North Dakota is far from alone. As least 13 other states — Alabama, Arkansas, Colorado, Georgia, Kentucky, Louisiana, Mississippi, Missouri, Montana, North Dakota, Oklahoma, South Dakota, South Carolina and Wyoming — have also passed similar consumer protection laws to properly regulate cell-product labeling and prohibit deceptive advertising.
North Dakota Farmers Union
Allowing products comprised of or containing cultured animal cells to be labeled “meat” or “poultry” would place family farmers and ranchers at a disadvantage because it will be difficult for them to differentiate their products from cultured animal cell products. Family farmers and ranchers want fair competition between their slaughtered meat and poultry products and products comprised of or containing cultured animal cells. Fair competition requires truthful and accurate product names and labels for products comprised of or containing cultured animal cells, which will allow consumers to make informed choices about their purchases.
Oklahoma Cattlemen’s Association
For the products in question for this rule, OCA supports the adoption of terms like `lab-grown' or 'artificially grown/produced' in clear and equal font as the term the product is trying to imitate such as 'meat', 'burger', 'steak' or other traditional meat term.
It is IMPERATIVE THAT CONSUMERS/PATIENTS CAN EASILY IDENTIFY AND ACCESS OR AVOID THOSE FOODS THEY TOLERATE/DON'T TOLERATE. Certain brands will undoubtedly work better, or, cause reactions. Cells grown under lab conditions will be nourished with particular formulas; with proper labeling these can be easily identified as either harmful or beneficial to the patient.
...In describing these products, the agency should not use the word cultured. In the context of food, the word "cultured" has been used to describe fermented foods for many years. A much better term would be "laboratory raised."
Although Orbillion Bio accepts that “cultivated” may be industry’s current preference as a differentiation term, we equally strongly support the use of either “cultured” or “cell-cultured” as descriptive and accurate terms for meat or poultry products comprised of or containing cultured animal cells. We believe that the terms “cell-cultured” or the shorter “cultured” are informative to the consumer and can bolster a clearer understanding of the difference between slaughtered and cell-cultured meat.
Pennsylvania Farm Bureau
Pennsylvania Farm Bureau supports the comments submitted by the American Farm Bureau Federation (AFBF) and asks that this support be noted as part of the comment record.
People for the Ethical Treatment of Animals
The specific term of interest for many consumers who wish to avoid consuming the tissue of animals who have been slaughtered, but who wish to purchase products made from cultured animal cells, is “slaughter-free meat.” As final products fitting both “slaughter-free meat” and “slaughtered meat” definitions are functionally equivalent outside of their mode of production, the benefit to consumers is providing product naming conventions that offer a clear consumer choice based on the principal difference in how these products are manufactured.
Pet Food Institute
Traditional meat and poultry proteins are often defined as by-products or co-products. This vernacular should not be considered when classifying cell cultural ingredients as it would not be an accurate representation of the ingredient or how it is process. Careful consideration should be considered when determining term names and guidance. Naming of new ingredients should be inclusive and accepted by the consumer (e.g., “cell cultured” and “cultivated” are found to be more favorable than “lab-grown meat”) rather than villainizing the ingredient due to production method. Traditional production practices should not be hindered in the pursuit of new and innovative ingredients.
Saskatchewan Ministry of Agriculture
One of the difficulties related to determining nomenclature and establishing labelling requirements for these novel cultured food products is the lack of international standards for current terminology and claims used in the food industry. The conventional meat industry has raised concerns that the use of the term meat is misleading to consumers. Given the lack of transparency around cultured meat production methods, and the inability to consistently replicate the organoleptic (appearance, odor, taste, texture) characteristics of traditional meat products, this concern may be valid.
Southwest Meat Association
It is important that products comprised of or containing cultured meat or poultry be clearly identified so that consumers can make informed purchase decisions. SMA does not have a preferred terminology for such information. The agency can conduct whatever needed consumer surveys to help develop appropriate terminology that will inform without confusing consumers. Importantly, the term or phrase should not be misleading or disparage traditional meat and poultry products. Finally, past agency actions would lead toward such differentiation being incorporated via a conspicuously placed qualifying statement rather than in the actual name of the product.
Cultivation of meat is a new technology. The industry is beginning to invest in consumer education. Additionally, explanatory tag-lines and approved claims on packaging as well as point-of-sale information, conventional and new media advertising and public relations are expected to enhance understanding as consumer familiarity grows.
To refer to a product as “Cultivated Pork” is no different than labeling a product “Fancy Pork” or “Handmade Pork” as “Cultivated” not a term describing the production method (similar to the term “Clean”). “Cultivated” is more similar to the FSIS Special Statements and claims such as “Farm raised” or “Certified Tender.” Further, “Cultivated,” in contrast to “cultured,” has no indication of the production process and would be misleading to consumers.
Tennessee Farm Bureau Federation
TFBF farmer members annually participate in an extensive process to develop resolutions to guide the organization on policy issues. This organization’s 2020 Resolutions specifically address the concept of imitation food products. The resolution states:
“Foods manufactured to imitate conventional agricultural products should meet the same safety standards and have separate label requirements that signify the difference of the imitation food.”
…TFBF believes it is imperative to allow consumers the opportunity to understand cell-culture meat is an imitation product and thus the label require the phrase “imitation food product derived from meat and poultry.” TFBF would also be comfortable with the phrase “cell-based food product derived from meat and poultry.”
Texas & Southwestern Cattle Raisers Association
TSCRA recommends USDA adopt “lab-grown” as an unambiguous description for these products. Unlike terms that the cell-cultured community has put forth, such as “cultured,” “clean” or “cultivated,” “lab-grown” will provide a clear and unambiguous description that effectively distinguishes the product from traditionally harvested meat. We would also be comfortable with “artificially grown” or “artificially cultured” as alternatives. These terms will leave little room for misinterpretation among consumers due to Webster’s using “artificial” and “grown” in its definition of “cultured.”
Texas Cattle Feeders Association
“Meat” is explicitly defined in the Code of Federal Regulations as the skeletal muscle of an animal. This definition hinges entirely on the source of the product. Lab-grown protein companies claim that their products give consumers a protein product that does not come directly from an animal but is rather grown from animal cells. Such a product can, at best, be classified as a “meat byproduct” or “meat food product.”
…TCFA recommends USDA adopt “lab-grown” as an unambiguous description for these products. Unlike the terms “cultured”, “clean” and “cultivated”, “lab-grown” provides a clear and unambiguous description that effectively distinguishes the product from traditionally harvested meat. TCFA also supports “artificially grown” and “artificially cultured” as alternatives. “Artificial” and “grown” are words used in the Webster’s definition of “cultured” and leaves little room for misinterpretation among consumers.
Texas Farm Bureau
The production of cellular based products involves the use of numerous processes and ingredients not common to food production. It is reasonable to consider listing the ingredients and processes used in cell-cultured meat development on the consumer product label. It should be regulated in a fashion similar to requirements for farmers and ranchers to label credence attributes such as “grass-fed” or “grain finished” on their meat and poultry products, including but not limited to listing third party verification.
...Texas Farm Bureau policy states that all packaged meat substitutes be labeled “not a meat product.” Utilizing this statement on label packages will provide enhanced clarity to consumers as they make their purchasing decisions.
The Better Meat Co.
[M]eat made from animal cells is no less real meat than ice made by freezers is real ice. For millennia, the only way we had to get ice was from nature, just as for millennia the only way we had to get meat was out of animals’ bodies. However, new technology has empowered us to more efficiently obtain the same thing, whether refrigeration with ice, or now cell culture with meat.
While the “natural ice” industry barons of the 19th century railed against what they derided as “artificial ice” (ice made via new human technology rather than in nature), we all know that the end product is still the same. Similarly, some detractors of this new meat industry will argue for prejudicial names designed to turn off consumers. But in the end we must treat this new industry fairly and without protectionism for the incumbents in the sector.
Rather than obviously inaccurate and prejudicial names (e.g., “lab-grown,” “artificial,” “synthetic,” etc.), a more accurate and neutral term to allow is “cultivated meat.” Meat cultivation is exactly what’s occurring in such a production facility, and the name doesn’t bias the consumer for or against the product.
The Vegetarian Resource Group
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.
...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.
True Health Initiative
Referring to a cultivator as a lab is an inaccurate reflection of how this meat is produced. If the USDA were to label products based on their perceived origin, then perhaps we would be labeling processed pig meat as 'slaughterhouse harvested' or ground beef from a 'Concentrated Animal Feeding Operation (CAFO).' If we are relying heavily on standards of provenance as part or all of labeling of plant and cultivated products, then we should also hold non cell-cultivated meats to the same standards.
Tyson Foods supports the development of all forms of protein products, be it the more traditional ground beef burger and chicken nugget, or the newer market entrants like cultured cell-based meat or poultry products.
...Tyson Foods is supportive of labels that use the appropriate qualifier, e.g., “cultivated, cultured, or cell-based” along with the appropriate standard of identity or common or usual name. In order to provide a path forward for consistent labeling, Food Safety and Inspection Service (FSIS) should ensure product names are recognizable and understandable to consumers, inform consumers that some or all of the product comprises cultured animal cells, and are not ultimately misleading and confusing when compared with the names of traditional products on the market.
U.S. Beef Breeds Council
Live animal specifications have been established with AMS that accurately identify breed influence (e.g., Angus, Hereford, Wagyu). These specifications have given FSIS confidence to approve labels that are accurate and not misleading to consumers. It is unclear to us how a similar system could be implemented on cultured animal cell products that aligns with a breed association standard and provides that same level of confidence to FSIS. As a result, we highly encourage FSIS to not allow any products derived in whole or part from cultured animal cells to include a claim of breed, or any word confusingly similar to a breed, in their name or marketing material.
U.S. Sen. Mike Rounds
Simply put, lab grown food products are not equivalent to meat and poultry products born, raised and harvested in the traditional manner. Pursuant to applicable federal laws, the FSIS should promulgate clear, accurate and fair regulations goveming the labeling of these cell cultured foods so they cannot be confused with traditional meat and poultry products. Because this new technology has yet to reach commercial scale or a broad level of public awareness, consumers are substantially unacquainted with these products and their nutritional properties. In fact, the impact on human health when consuming these products is unknown due to a lack of longitudinal data. This is especially true relative to carefully studied meat and poultry products enjoyed by consumers for hundreds of years. My constituents are concerned that imprecise labeling regulations could result in consumers being placed at a disadvantage when attempting to make informed decisions.
Lab grown products should be recognized in the marketplace based upon their standalone reputation, not the hard-fought reputation achieved by our nation's agricultural producers. This consideration, in part, has led a majority of states to either pass or introduce legislation to prohibit cell cultured food from receiving labels that conflate these products with meat.
United Egg Producers
FSIS’s ANPR concerns only meat and poultry covered by the Federal Meat Inspection Act (FMIA) or the Poultry Products Inspection Act (PPIA). However, UEP strongly urges the agency to include egg products covered under the EPIA in any proposed rule.
United States Cattlemen’s Association
[W]e write to you today in favor of retaining the definition of beef and meat to pertain exclusively to products derived from the flesh of a bovine animal born, raised, and harvested in the traditional manner.
...The “beef” and “meat” labels should inform consumers that the products are from animals harvested in the traditional manner, as opposed to derived from alternative proteins or artificially grown in laboratories. As such, the definitions of “beef” and “meat” should be limited to animals born, raised, and processed in the traditional manner, regardless of the country of origin. Synthetic products and products grown in labs from animal cells should thus not qualify to be labeled as “beef” or as “meat.”
[C]urrent consumer research supports use of the term “cultivated” in product labeling, especially when provided alongside language noting that the product is derived from the “cells” of a specific food animal, as a means of effectively differentiating cultivated products from slaughtered meat and poultry products. For example, research conducted on behalf of UPSIDE found that “Chicken (cultivated from chicken cells)” evokes accurate associations to the cultivated product, and that packaging using “Chicken (cultivated from chicken cells)” differentiated the product from slaughtered chicken products and made clear that the product is derived from the chicken cells. Another study demonstrated that consumers found the term “cultivated” to be a descriptive term. In that study, researchers tested 31 different terms by asking survey respondents to rate the terms on a scale from 1 to 5, with 1 being “not at all descriptive” and 5 being “extremely descriptive.” “Cultivated meat” received a descriptiveness score of 3.41, which was greater than the score for “cultured meat” and “clean meat,” among other terms.
...[T]his labeling approach provides meaningful benefits to consumers as well as industry. Most importantly, the cultivated product descriptive designation provides direct and accurate information to consumers, which will enable them to have a clear understanding of the nature, source, and production method for these products. Further, by differentiating cultivated meat and poultry products from slaughtered products as well as plant-based products, the descriptive designation enables consumers to affirmatively identify and distinguish between products and make informed purchase decisions. It also helps ensure that consumers who have sensitivities or allergies to slaughtered meat and poultry products (or seafood products) are able to clearly identify cultivated products as meat and poultry (and likewise for seafood), as these consumers would have the same reaction to cultivated products. And, by using terminology that is accurate and objective and does not denigrate cultivated or conventional product categories, the approach allows the industry to grow and innovate without disparaging other products. Notably, various media outlets representing different audiences and stakeholders have already begun using the term “cultivated” to refer to the category.