Background Paper
MODERN BIOTECHNOLOGY AND FOOD LABELING
September, 2001
The Issue
How much information about technology should a food label contain?
The application of modern biotechnology to food is the subject of
a debate that is questioning some of the settled principles of labeling
regulation. On one side of the debate are advocates of a policy
that would require all foods modified by modern genetic techniques
to bear labels disclosing that fact. The other side believes no
such requirement is necessary unless the modification creates a
material difference in the food.
Labeling Serves Important Purposes
For consumers buying packaged foods, the label is the single most
important resource because it contributes to their first impression
about the product and it communicates information that helps them
make their purchase decisions. Labels list essential information
such as ingredients and quantities, describe features, give instructions,
explain benefits, and deliver advisories and warnings. Information
considered critical to health and safety is mandated by law to appear
on the label.
Nonetheless, the amount of material that can be incorporated on
a label is limited by its size and by the ability of consumers to
absorb information. The label cannot tell every consumer everything
he or she might want to know about every product, because different
consumers care about different things. With hundreds of millions
of consumers seeking to satisfy different tastes and preferences,
the amount of information that might be useful to everyone could
fill an encyclopedia. Only a small fraction of this information
can fit on the label.
In the stores where hundreds and thousands of products compete
for consumers' attention, labels must serve another critical function.
They must be effective signals. None of the information on the label
can accomplish anything if consumers do not notice the product and
consider its suitability for their purposes. Unnecessary information
on a label can drown out critical messages, or worse, confuse consumers.
A fundamental challenge facing the food manufacturer is to design
labels that communicate effectively the information that matters
most to the consumers of its products. Labels that carry too many
messages may fail to deliver the most important ones, and there
is no question as to the importance of the information about contents,
ingredients, nutrients, and quantities that labels must convey now.
The question is whether information about modern biotechnology is
so essential that it also must appear on every label of a food produced
with it.
Labeling Regulations Should Protect Consumers
The objective of consumer product regulation is to foster a legal
system that protects consumers from harm and requires manufacturers
to describe accurately the products they sell. In order to achieve
that purpose, regulators must apply both the physical sciences,
like biology and chemistry, and the social sciences, like economics
and consumer behavior, when devising the rules that govern product
labels.
Nearly a century of experience at regulatory agencies around the
world has yielded the basic elements of successful consumer protection
regulation. The legal system should prohibit product claims that
deceive consumers. It should expect manufacturers to have the evidence
appropriate to back up the types of claims that they make. And it
should require disclosure of information that is necessary to inform
consumers about such basics as the quantity, ingredients and safety
of the contents of a package.
While the protection of the consumer requires essential information
to be displayed on labels of foods, the effectiveness of the label
requires that other claims remain voluntary, subject only to the
requirement that they be accurate and substantiated. A food labeling
policy that strikes this balance not only protects consumers but
also preserves their ability to choose, because it permits manufacturers
to communicate effectively to them.
Biotechnology And Regulation Have Evolved Together
Neither the nature nor the history of modern food biotechnology
justifies a departure from traditional regulatory policies. The
birth of modern genetic science is typically credited to the pioneering
agricultural work of Gregor Mendel in Austria and Luther Burbank
in the United States at the end of the nineteenth century. Mendel
identified the genetic consequences of cross-breeding plants, while
Burbank created over 800 new strains and varieties of plants by
creating numerous hybrids and grafting seedlings to mature plants.
Although crude by modern standards, these techniques transformed
agriculture and enabled consumers to buy more food of higher quality
for less money than ever before.
Governments did not require the disclosures of cross-breeding and
hybridization on labels of every food that resulted from these techniques.
Regulations of course required the identification of major differences
in foods and ingredients, and protected the consumer from the introduction
of health hazards, whether or not biotechnology played any role
in the development of new foods and ingredients. The principal focus
of food regulators was not on the genetic or breeding technique
that developed a product, but on the characteristics of the product
itself.
With the discovery of DNA, basic genetic research moved from the
gardens and greenhouses to the laboratories. Agents that splice
genes have replaced instruments that insert pollen. Identification
of genetically related markers now supplements physical inspection
of mature plants. The result is more predictable breeding and more
precise development of products with desirable characteristics.
As biotechnology progressed from the crude experiments of 1900
to the precise methodology of today, so did the regulation of food
and labels, which evolved from a set of simple rules to a complex
and comprehensive regime. A system that began with basic demands
for sanitary processing and truthful labeling has evolved into tight
controls of manufacturing practices and detailed specifications
for label disclosures. The result is more certainty than ever in
the safety, consistency and description of modern foods.
Conclusion
A sound labeling policy can and should recognize the rights of
consumers to a safe and nutritious food supply, while facilitating
consumer choice based on meaningful information about the product
itself. By mandating only essential information, allowing voluntary
claims about modern biotechnology, and demanding accuracy in all
labeling, the United States' policy governing the labels of food
has accomplished this goal.
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