{"id":18277,"date":"2021-11-08T10:00:42","date_gmt":"2021-11-08T15:00:42","guid":{"rendered":"https:\/\/www.vrg.org\/blog\/?p=18277"},"modified":"2021-10-28T09:43:01","modified_gmt":"2021-10-28T13:43:01","slug":"the-vegetarian-resource-groups-testimony-on-the-labeling-of-meat-products-containing-cultured-animal-cells","status":"publish","type":"post","link":"https:\/\/www.vrg.org\/blog\/2021\/11\/08\/the-vegetarian-resource-groups-testimony-on-the-labeling-of-meat-products-containing-cultured-animal-cells\/","title":{"rendered":"THE VEGETARIAN RESOURCE GROUP\u2019S TESTIMONY ON THE LABELING OF MEAT PRODUCTS CONTAINING CULTURED ANIMAL CELLS"},"content":{"rendered":"\n<figure class=\"wp-block-image\"><img loading=\"lazy\" decoding=\"async\" width=\"300\" height=\"171\" src=\"https:\/\/www.vrg.org\/blog\/wp-content\/uploads\/2021\/10\/Labeling-of-Meat-or-Poultry-Products-Comprised-of-or-Containing-Cultured-Animal-Cells-Foo...-300x171.png\" alt=\"\" class=\"wp-image-18278\" srcset=\"https:\/\/www.vrg.org\/blog\/wp-content\/uploads\/2021\/10\/Labeling-of-Meat-or-Poultry-Products-Comprised-of-or-Containing-Cultured-Animal-Cells-Foo...-300x171.png 300w, https:\/\/www.vrg.org\/blog\/wp-content\/uploads\/2021\/10\/Labeling-of-Meat-or-Poultry-Products-Comprised-of-or-Containing-Cultured-Animal-Cells-Foo....png 767w\" sizes=\"auto, (max-width: 300px) 100vw, 300px\" \/><\/figure>\n\n\n\n<p>The Vegetarian Resource Group sent in the\nfollowing testimony to USDA in October, 2021. We\ndid not address every question they asked in the request for comments since\nwhether or not a product is labeled pork loin containing cultured animal cells\nas opposed to pork containing cultured animal cells did not seem like\n&#8220;our&#8221; issue.<\/p>\n\n\n\n<p>We welcome the opportunity\nto comment on Labeling of Meat or Poultry Products Comprised of or Containing\nCultured Animal Cells. As a consumer organization, we prioritize providing\nclear, helpful label information that consumers can use to make an informed\nchoice. <\/p>\n\n\n\n<p>Response to question\n1:<\/p>\n\n\n\n<p>We believe that the\nname or statement of identity of meat or poultry products comprised of or\ncontaining cultured animal cells should inform consumers about how the animal\ncells were produced. Vegetarians do not eat meat or poultry and would want to\nbe aware that a product contains cultured animal cells. We assume that this\nwould also be the case for those with an allergy to meat or poultry products\nand for those who avoid these products due to religious beliefs. In addition,\nconsumers may not want to purchase products comprised of or containing cultured\nanimal cells due to concerns about the negative environmental impact of\nproducing these products.<sup>1<\/sup><\/p>\n\n\n\n<p>In 2020, a survey was\nconducted online within the United States by The Harris Poll on behalf of The\nVegetarian Resource Group from June 22-24, 2020 among 2,074 U.S. adults ages 18\nand older. We found that more than half of the U.S. adult population (54%)\nalways or sometimes eats vegetarian (including vegan) meals when eating out. We\nasked if survey respondents would purchase a meat alternative grown from animal\ncell DNA obtained ten years ago, which does not currently involve the raising\nof animals. Only 12% of respondents said they would purchase such a product;\n19% of vegetarians including vegans would purchase a meat alternative grown\nfrom animal cell DNA; 19% of those that sometimes or always eat vegan meals\nwhen eating out and 18% of those that sometimes or always eat vegetarian,\nincluding vegan, meals when eating out would purchase this type of meat\nalternative.<sup>2<\/sup> Similarly a 2021 national survey was commissioned by\nThe Vegetarian Resource Group and conducted online by YouGov, of 8 -17\nyear-olds. This survey found that more than half (53%) of 8-17 year-olds\nsometimes or always eat vegetarian meals when eating out. As was done in the\nadult poll, we asked if survey respondents would purchase a meat alternative\ngrown from cells (DNA) from an animal, which was collected years ago which does\nnot currently involve the raising of animals. Only 9% of respondents said they\nwould purchase a meat alternative grown from animal cell DNA.<sup>3<\/sup> <\/p>\n\n\n\n<p>Since so many\nconsumers would choose not to purchase a product produced using animal cell\nDNA, it is important that consumers be informed about the presence of cultured\nanimal cells in products in clear, easily understood language. This should be\nindicated in the product name and in the ingredient list on the product label\nso that consumers can be aware of the product\u2019s composition.<\/p>\n\n\n\n<p>In addition to label\ninformation, it is important for companies to have specific information about\nthe source of these cells in their products on their websites since many people\nlook on product websites for information. This information should also be\npresented in clear, easily understood language.<\/p>\n\n\n\n<p>Response to question\n2a:<\/p>\n\n\n\n<p>Use of a term such as\n\u201cengineered using cultured animal cells\u201d would help consumers understand that\nthe product is based on animal products and that animal cells are used in\nproduction. An educational program would need to be developed to inform\nconsumers about the meaning of \u201ccultured\u201d in this context. This terminology\nshould be prominently delayed on the product\u2019s label so that consumers are\naware of the product\u2019s composition. <\/p>\n\n\n\n<p>Response to question\n3:<\/p>\n\n\n\n<p>Meat and poultry products\nthat are comprised of both slaughtered meat and cultured animal cells should be\nrequired to be labeled in a way that clearly informs consumers that the product\ncontains both slaughtered meat and cultured animal cells. It is important to\nspecify that the cultured cells are animal cells so that consumers can decide\nwhether or not they want to purchase a product containing animal cells. As\ndiscussed in our response to question 1 above, consumers are reluctant to\npurchase a product derived from animal cell DNA. Information about product\ncomposition should appear on the label.<\/p>\n\n\n\n<p>Response to question\n4: <\/p>\n\n\n\n<p>The terms\n\u201cvegetarian,\u201d \u201cvegan,\u201d and \u201cplant-based\u201d should never now or in the future be\nused in the product name or on the product label of a food comprised of or\ncontaining cultured animal cells. This terminology would be a misrepresentation\nof the food product. Although the FDA does not currently define \u201cvegetarian,\u201d\n\u201cvegan,\u201d or \u201cplant-based,\u201d these terms are commonly used to imply that products\ndo not contain ingredients from meat\/fish\/poultry (vegetarian) or from all\nanimal products and by-products (vegan). \u201cPlant-based\u201d has a variety of\nmeanings but it is commonly used to indicate that a product is vegetarian or\nvegan.<sup>4<\/sup> Having \u201cvegetarian,\u201d \u201cvegan,\u201d or \u201cplant-based\u201d on a label of\na product containing cultured animal cells would be misleading to consumers.<\/p>\n\n\n\n<p>A survey of vegetarian\nand vegan groups conducted in 2013 found that the majority did not believe that\na meat alternative grown from animal cell DNA, obtained ten years ago, which\ndoes not currently involve the raising of animals should be labeled as \u201cvegan.\u201d<sup>5<\/sup>\nThis survey, although informal in nature, suggests that advocacy groups would\nnot support having terms such as \u201cvegan\u201d used on the label of foods comprised\nof or containing cultured animal cells.<\/p>\n\n\n\n<p>Additionally, terms\nsuch as \u201cnon-animal\u201d or \u201canimal-free\u201d should never now or in the future be used\nin the product name or on the product label of a food comprised of or\ncontaining cultured animal cells. Use of these terms would be misleading for\nconsumers who, for religious, ethical, philosophical, environmental, or other\nreasons do not want to purchase products in which animal products were used at\nsome point in production.<\/p>\n\n\n\n<p>Response to question\n8:<\/p>\n\n\n\n<p>FSIS should not\nestablish a regulatory standard of identity for foods comprised of or\ncontaining cultured animal cells unless this standard of identity clearly\nstates that the food is comprised of or contains animal cells and that this\ninformation is required to be included on the product label in both the name of\nthe product and in the ingredient list.<\/p>\n\n\n\n<p>Response to question\n12:<\/p>\n\n\n\n<p>FSIS-regulated broths,\nbases, and reaction flavors produced from animal cells should be required to\ndeclare the source material in the product name and in the ingredient listing.\nThis information will allow consumers to choose whether they want to purchase\nthese products. Additionally, the terms \u201cvegetarian,\u201d \u201cvegan,\u201d and\n\u201cplant-based\u201d should never now or in the future be used in the product name or\non the product label of broths, bases, and reaction flavors comprised of or\ncontaining cultured animal cells for the reasons discussed in the response to\nquestion 4.<\/p>\n\n\n\n<p>Response to question\n13:<\/p>\n\n\n\n<p>The presence of\ncultured animal cells in further processed products regulated by FSIS should be\nidentified on the product label, both in the product name and in the ingredient\nlisting. This information will allow consumers to choose whether they want to\npurchase these products. Additionally, the terms \u201cvegetarian,\u201d \u201cvegan,\u201d and\n\u201cplant-based\u201d should never now or in the future be used in the product name or\non the product label of further processed products comprised of or containing\ncultured animal cells for the reasons discussed in the response to question 4.<\/p>\n\n\n\n<p>Thank\nyou for the opportunity to comment on this issue.<\/p>\n\n\n\n<p>References <\/p>\n\n\n\n<p>1. Meat Atlas. <a href=\"https:\/\/eu.boell.org\/en\/MeatAtlas\">https:\/\/eu.boell.org\/en\/MeatAtlas<\/a>.\n2021; pp. 60-61.<\/p>\n\n\n\n<p>2. What vegetarian and vegan\nproducts will American adults purchase? Questions asked by The Vegetarian\nResource Group in a national poll. &nbsp;<a href=\"https:\/\/www.vrg.org\/nutshell\/harris2020veganadultwriteup2blog.pdf\">https:\/\/www.vrg.org\/nutshell\/harris2020veganadultwriteup2blog.pdf<\/a>. 2020.<\/p>\n\n\n\n<p>3. How many youth in the U.S\nare vegan? How many teens eat vegetarian when eating out? <a href=\"https:\/\/www.vrg.org\/nutshell\/Yougov2021youthteenwriteup.pdf\">https:\/\/www.vrg.org\/nutshell\/Yougov2021youthteenwriteup.pdf<\/a>.\n2021.<\/p>\n\n\n\n<p>4. What does plant-based\nactually mean? <a href=\"https:\/\/www.vrg.org\/journal\/vj2018issue4\/2018_issue4_plant_based.php\">https:\/\/www.vrg.org\/journal\/vj2018issue4\/2018_issue4_plant_based.php<\/a>.\n2018. <\/p>\n\n\n\n<p>5. What do vegetarian groups\nconsider vegetarian and vegan? <a href=\"https:\/\/www.vrg.org\/journal\/vj2014issue2\/2014_issue2_what_do_consider.php\">https:\/\/www.vrg.org\/journal\/vj2014issue2\/2014_issue2_what_do_consider.php<\/a>.\n2014. <\/p>\n","protected":false},"excerpt":{"rendered":"<p>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 &#8220;our&#8221; issue. [&hellip;]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-18277","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts\/18277","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/comments?post=18277"}],"version-history":[{"count":1,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts\/18277\/revisions"}],"predecessor-version":[{"id":18279,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts\/18277\/revisions\/18279"}],"wp:attachment":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/media?parent=18277"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/categories?post=18277"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/tags?post=18277"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}