Food Labeling

I. INTRODUCTION

1. The first foods and food ingredients developed through recombinant DNA technologies have reached commercialization and more are nearing commercial distribution. In response to these developments, Member States of the Codex Alimentarius Commission (the Codex) are evaluating questions regarding appropriate labeling for these products. Delegates to a recent meeting of the Codex Committee on Food Labeling (CCFL) agreed that this issue should be addressed, and the US Delegation to the Committee offered to draft a discussion paper on labeling issues.

The discussion paper prepared by the US Delegation to the Codex Committee on Food Labeling presents a highly unbalanced view of the labeling issue that greatly favors the interests of the biotechnology industry at the expense of the broader interests of private citizens and consumers. The rationale presented in the discussion paper relies heavily on arguments that are scientifically untenable. After receiving comments on this discussion paper from a large number of organizations within the US and around the world, the US Delegation released their own comments on the discussion paper. These comments did not incorporate any of the significant and valid comments submitted by other organizations, but merely reiterate and defend the position of the original discussion paper.

In the interest of presenting a broader perspective on the labeling issue, we have prepared the following paper. This paper addresses, point by point, the issues raised in the paper prepared by the US Delegation to the CCFL, but strives to present a more balanced view of the labeling issue, one that respects and reflects the needs and concerns of a broader spectrum of the stake holders in this issue. This paper also strives to base all assessments of potential labeling policies on rigorous scientific principles and research observations. The points contained in this paper are numbered to correspond to the US Delegation's discussion paper in order to facilitate comparison of these documents.

The central conclusion that emerges from this analysis is that mandatory labeling of genetically engineered foods, food constituents, and food additives is, in the long run, good for everyone, consumers and the biotech industry alike. Labeling provides consumers with knowledge upon which to base rational choices regarding the foods they eat, and labeling provides the industry and regulators with a safety net that will allow them to quickly trace problems that arise with genetically engineered foods, thereby minimizing liability. Moreover, in the long run, if genetically engineered foods offer in practice the benefits that industry invisions, the label will become a sign of quality, which will allow industry to demand a premium for these products.

2. The term biotechnology refers to the technical use of biological processes to produce products. It is a broad term that encompasses many methods of genetic modification, including but not limited to cross-hybridization, mutagenesis, cell culture, and recombinant DNA techniques. Much of the discussion about appropriate labeling of foods and food ingredients and additives produced by biotechnology has focused on foods produced using recombinant DNA techniques.

3. Recombinant DNA techniques involve the isolation and subsequent introduction of discrete DNA segments containing the gene(s) of interest into recipient (host) organisms. The DNA segments can come from any organism (plants, animals, or microbes). In theory, essentially any trait whose gene has been identified can be introduced into any food source organism.

Those who wish to minimize to the public the revolutionary nature of recombinant DNA techniques generally claim that they are a part of a continuum of methods that can be used to bring about genetic improvements in food source organisms. On this basis, they argue that it would be inappropriate to subject genetically engineered foods to additional regulatory scrutiny or to require these foods to be labeled as genetically engineered. However, a systematic and scientific comparison of recombinant DNA technologies and other methods makes it clear that they are not part of a continuum.

It is true that the goals of recombinant DNA methodologies are the same as those of traditional breeding methods, namely, the development of new varieties of food source organisms with improved characteristics. However, recombinant DNA techniques stand by themselves as a distinct and revolutionary technology for accomplishing these goals.

Traditional breeding methods are designed to select preexisting genetic traits from the gene pool of a species or closely related species. No new information is actually created in these processes. Instead, genes already existing in the gene pool of a species and its close, reproductively compatible relatives are merely brought together within the same individual. In contrast, genetic engineering alters the information content of the gene pool of a species. This is accomplished either by adding to the gene pool new genes, often derived from a widely divergent species, or by altering the information content of genes already in the gene pool.

Through this powerful technology, genetic information can be transferred between species that would never exchange information under natural conditions or under traditional breeding regimes. For instance, recombinant DNA methods have made it possible to transfer the gene encoding the flounder antifreeze protein into tomatoes, in hopes of increasing resistance to freezing. Natural genetic and reproductive boundaries normally prevent such exchanges, and even prevent crosses between close relatives such as the tomato, the potato, and the eggplant.

Like traditional breeding methods, the other methods listed in the US Discussion Paper-cross-hybridization, embryo rescue, and somaclonal variation-do not involve the introduction of new genetic information into the gene pool of the food-producing organism. The first of these is a variation on traditional breeding methods, the second is a cell culture-based method for generating many genetically identical plants from a single elite specimen, and the third is a variation on this approach.

Because recombinant DNA techniques introduce new genetic information into the gene pool, they do not exist on a continuum with these other methods but are of a distinctly different character and should be treated separately.

4. The biotechnology industry, research scientists, consumers and the public media frequently refer to the applied use of recombinant DNA techniques as genetic engineering. For instance, one of the trade journals for the biotechnology industry is titled Genetic Engineering News.

For this discussion, foods, food ingredients, and additives produced through recombinant