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.