Cultivated meat, cell-cultured meat, lab-grown meat? Stakeholders weigh in on nomenclature as products near commercialization in US market
The comments – which you can read HERE - were submitted in response to an advanced notice of proposed rulemaking (ANPR) from the US Department of Agriculture (USDA), which is developing labeling rules for cell-cultured meat and poultry, but says its will review labels submitted by startups in the space before the rulemaking process is completed on the understanding that they may need to be changed down the road to comply with its final regulations.
While not all of the comments that have been submitted by the Dec 2 deadline are yet visible on the regulations.gov website, a brief glance at the submissions that are visible indicates a wide range of views, with some commentators arguing that the technology is so nascent, and the products so poorly characterized, that it is premature to pin down terminology at all at this stage.
ALDF: Slaughter-free meat 'should not be subject to burdensome, restrictive, or potentially inaccurate labeling requirements simply due to its distinct production process'
Animal welfare groups such as the Animal Legal Defense Fund (ALDF), ASPCA, Animal Welfare Institute, and The Humane League, also point out that USDA's Food Safety and Inspection Service (FSIS) has historically taken the position that producers do not need to affirmatively disclose a production method unless it affects the meat or poultry product “in a manner that is not obvious to consumers in the absence of labeling."
Given this, they argue, "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."
To the extent that FSIS believes it may want or need to develop specific labeling guidance for special statements and claims pertaining to cell-cultured meat and poultry, it should not do so preemptively, but wait until it gains a better understanding of the products and the technology, argue the ALDF et al.
FSIS should 'reject out of hand irrational, counter-productive, and potentially dangerous' labels
And if FSIS is to require any type of affirmative disclosure of production methods for slaughter-free products, they add, "It should avoid a one-size-fits-all mandate that would require prescriptive and inflexible disclosures."
Potential product names and claims producers may wish to use include slaughter-free and cell-cultured, they add, noting that "FSIS should reject out of hand any irrational, counter-productive, and potentially dangerous" labels proposed by cattlemen's organizations including 'artificial,' 'imitation,' 'synthetic,' or 'lab-grown.'
NCBA: 'Misleading terms like 'cultured,' 'clean,' or 'cultivated' fail to adequately describe the production practices to the everyday consumer'
The National Cattlemen’s Beef Association, meanwhile, argues that it is by no means clear at this stage whether cell-cultured meat is substantially equivalent to conventionally raised and slaughtered meat, adding: "[Cell-cultured meat] companies claim that the only difference between cell-cultured and traditional meat food products is the process by which the animal 'parts' are grown and harvested.
"However, in the absence of independent, scientific evaluation of cell-cultured products, NCBA and other stakeholders have been forced to base assessments on the unverified claims and somewhat limited academic research on the topic... FSIS and FDA should refrain from finalizing the regulatory framework until independent researchers have the opportunity evaluate the biological, chemical, and ornithological characteristics of lab-grown protein products..."
As for labeling, it agues that '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."
UPSIDE Foods: ‘Cultivated’ is the best term
In its comments, industry pioneer UPSIDE Foods (formerly Memphis Meats), which has historically used the terms 'cell-based' and 'cell-cultured' in its communications, argues that 'cultivated' is now its preferred term.
“A mandatory descriptive designation – using the term ‘cultivated’ along with language noting the product is derived from the ‘cells’ of the corresponding food animal (‘from chicken cells’) – in conjunction with the product name will inform consumers of how the product was produced as well as its nature and source, in a simple and direct manner.
“The nature and other characteristics of the food, including its form and function, would be further described by other terms that will be provided on the label of the package, such as sausage, fillet, or cutlet.”
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,” says the startup, which recently opened what it claims is the “most advanced cultivated meat production facility in the world” in Emeryville, California.
It would be ‘premature’ to adopt a standard of identity for cultivated meat products at this early stage
It would, however, be premature to adopt a standard of identity for cultivated meat products at this early stage given that “it is difficult to draw general conclusions regarding the material characteristics of cultivated meat and poultry products at this time” and that attempting to nail this down too early could “inhibit the innovation and development of a nascent industry," argues the firm.
Michele Simon: ‘It’s not necessary to choose only one term as long as any term that is chosen does not mislead or confuse consumers’
Plant Based Foods Association (PBFA) founder Michele Simon (who is no longer with the PBFA) also noted that given the nascency of the industry, "some of the inquiries in this ANPR cannot be sufficiently or objectively answered” at this stage, especially about things such as the organoleptic or other qualities impacting consumers’ purchasing decisions.
“The industry is in a very early stage of product development and is closely guarding its intellectual property given the massive amounts of investment capital at stake. As a result of having zero product on the market, information on characteristics is not available for public evaluation and scrutiny.”
As for terminology, meanwhile, in Simon’s view, it is “not necessary to choose only one term as long as any term that is chosen does not mislead or confuse consumers.”
Simon also notes that key stakeholders have changed their position on nomenclature multiple times in recent years, with The Good Food Institute (GFI) – which promotes plant-based, cell-based, and fermentation-based foods - initially using the somewhat loaded term ‘clean meat’ but now preferring ‘cultivated meat.'
According to Simon, who dislikes the term ‘cultivated’ meat, “What should be critically important is clarity, not acceptance. And yet, GFI summarily rejects other terms [such as cell-cultured] that could provide consumers with more clarity out of concern they were too off-putting.”
Simon, however, goes on to suggest terms that many startups in the space believe are not descriptive or neutral, including ‘Lab-grown’ and ‘Biotech meat.’
BlueNalu: 'Cell-cultured' is the best term for seafood, meat, and poultry
BlueNalu, which makes seafood from cells grown in bioreactors (under the purview of the FDA), says it favors 'cell-cultured,' reflecting peer-reviewed research conducted by Dr Bill Hallman at Rutgers University.
"As a result of Dr. Hallman's research, 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 request for information.
"Unfortunately, there is no similar rigorous peer-reviewed research study following Dr. Hallman's validated methodology that has been conducted to date to determine the most appropriate name for meat and poultry products derived from animal cells. In the absence of such studies, BlueNalu feels the term cell-cultured would carry over and be appropriate for these products and provide consistency across categories. Therefore, we encourage FSIS to strongly consider the term 'cell-cultured' for the products it regulates as well."
'Terms such as 'cultivated' had a great deal of appeal to consumers... but they were also the terms that created the greatest amount of potential confusion'
While some of its compatriots in the industry favor 'cultivated' meat, added BlueNalu, "We learned through Dr. Hallman’s research that some commonly proposed names for these product categories may also create the greatest amount of confusion with consumers.
"The names 'cultivated' or 'cultured' had a great deal of appeal to consumers of seafood products derived from fish cells, but they were also the terms that created the greatest amount of potential confusion and were frequently associated with their conventional and aqua cultured seafood counterparts."
AMPS Innovation: Our meat & poultry members are aligned on term 'cultivated'
AMPS Innovation - which represents cell-cultured meat and seafood startups including Artemys Foods, BlueNalu, Finless Foods, Fork & Goode, Future Meat Technologies, GOOD Meat, New Age Meats, Orbillion Bio and UPSIDE Foods - acknowledges that are are differing views within the industry, but says its meat and poultry members have aligned around the term 'cultivated.'
"'Cultivated' is in our view the term that most appropriately reflects the fundamental production of these products. 'Cultivator' is a term many companies use to refer to the bioreactors where cellular agriculture takes place. The adjective 'cultivated' proceeds logically from this and provides a technically accurate definition."
The Good Food Institute: USDA should not mandate or prohibit a specific term on labels at this early stage of development
In its 130-page submission, The Good Food Institute (GFI) urges USDA not to impose new labeling requirements for cell-cultured meat and poultry products unless they are "materially different from their conventional counterparts, consistent with longstanding FSIS policy."
And to the extent products are materially different, USDA "should not mandate or prohibit a specific term or terms on product labels at this early stage of product development," says the GFI.
"Although the industry is expanding rapidly, the technology, methods, and processes behind cultivated meat and poultry products are still being developed... Many products are expected to be biologically, chemically, nutritionally, and organoleptically identical to their conventional counterparts, while others may differ significantly. Companies are also developing hybrid products..."
*We've included a selection of other comments below, and will update this article as more submissions are published.
The Good Food Institute: 'The term 'lab-grown' would be false and misleading if applied to cultivated products as a class. Almost every novel food is first created and refined in a laboratory. But when produced at scale, foods are not manufactured in a laboratory. 'Imitation” has a narrow regulatory definition that does not apply to cultivated meat and poultry... The term 'synthetic' is a highly inaccurate term for a food product that is composed of the same type of cells from the same species as its slaughtered analog.'
The Kentucky Livestock Coalition: '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.'
Canadian Federation of Agriculture: '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.'
Kansas Cattlemen’s Association: 'KCA supports the definition of beef to only include products derived from actual livestock traditionally born, raised, and harvested.'
Kentucky Dept of Agriculture: 'We ask that you keep in mind the two principles of consumer protection and support for our farmers as you develop labeling rules for products made using cell cultures in a lab.'
Paul Shapiro, The Better Meat Co: '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 ('lab-grown,' 'artificial,' 'synthetic'), 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.'