What's in a name?

Thursday, December 30, 2021

With petitions in place, there could be a 'beef' about how regulatory officials label lab-grown meat.

By Becky Dumais

Plant-based science has given us burgers "Beyond Meat" and there's much research dedicated to bringing cellular cultivated meat, which uses tissue samples from animals, to market. While there's nothing wrong with a little healthy competition for consumerism, there's still the question of how these new products should be labelled – and even the sustainable merit that's proposed to come with lab-created food options.

Cellular-cultured meat was first showcased in London, England in 2013 by Dr. Mark Post – an edible experiment in hamburger patty form which cost $300,000. Those privy to sampling this first-of-its-kind meal said it only tasted 'close' to beef – even though it was real beef, albeit created in a lab.

Stakeholders have a say

A regulatory whitepaper written by Netta Fulga and Yadira Tejeda Saldana in September 2020 for Cellular Agriculture Canada (CAC) illustrates the hurdles and issues facing this emerging market. "The industry is in its early stages in Canada with only a few companies developing cell-cultured products and paving the way for the industry. Therefore, we believe it is crucial to start a dialogue with regulators and establish thorough documenting procedures to ensure transparency and evidence-based practices that will help to establish fair regulations for the industry."

Proper, accurate labelling for cellular agricultural meat is something the United States Department of Agriculture (USDA) is undertaking. On Sept. 2 the USDA's Food Safety and Inspection Service (FSIS) published an advance notice of proposed rulemaking (ANPR) to solicit comments and information regarding the labeling of meat and poultry products made using cultured cells derived from animals under FSIS jurisdiction. FSIS will be using the comments to inform future regulatory requirements for the labeling of such food products.

"This ANPR is an important step forward in ensuring the appropriate labeling of meat and poultry products made using animal cell culture technology," says USDA deputy under secretary for Food Safety Sandra Eskin. "We want to hear from stakeholders and will consider their comments as we work on a proposed regulation for labeling these products."

The ANPR is requesting comment on specific topics to be considered during rulemaking related to statutory and regulatory requirements for the labeling of meat and poultry products. They also want to hear opinion on consumer expectations about the labeling of these products, including taste, colour, odour, or texture; "names for these products that would be neither false nor misleading; economic data; and any consumer research related to labeling nomenclature for products made using animal cell culture technology," states the release.

"The ANPR also discusses how FSIS will generally evaluate labels for these products if they are submitted before the agency completes rulemaking."

In a Sept. 2 statement the United States Cattleman's Association reiterated its view from a 2018 petition to the USDA: "The terms 'beef' and 'meat' should be retained exclusively for products derived from the flesh of an animal, harvested in the traditional manner."

It's beneficial to producers and consumers that names for cell-cultured meat be different than farm-raised food animals.

"I think it's beneficial to both parties that naming of products is clear, concise and truthful," says Danie Glanc, farm policy analyst for the Ontario Federation of Agriculture. "Accurate, truthful, and easy to understand naming and labelling of products allows for informed choices which do not mislead consumers and increases clarity and transparency."

Public consultation is critical in policy development; that includes input from producers, consumers, stakeholders, etc. "The feedback received from all affected and interested parties helps decision makers understand the values, interests, and concerns about the issue and ultimately leads to a more informed decision-making process," Glanc says.

Health Canada holds responsibility for labelling products regarding health and safety; the Canadian Food Inspection Agency (CFIA) Consumer Protection and Market Fairness Division is responsible for the labelling of products and certain compositional standards.

"The issue of labelling and compositional standards needs to be addressed as soon as possible in order to determine and define cell-cultured food products in Canada," says the CAC's whitepaper.

The meaning of meat

Canadian producers and stakeholders are adamant about clear labelling. "The beef industry as a whole has always been open to competition – it's something we've always had to deal with in the market," says Jennifer Babcock, senior manager, government relations, Canadian Cattlemen's Association (CCA).

"It's not a new thing and what our stance is, is that everything should be represented properly and not mislead consumers at the end of the day: to be able to say quite blatantly what the protein is.

"One of our concerns is: to make sure consumers are not being misled and understand what is in their products for their proteins," she says. "Obviously with beef it's pretty straightforward – it's 100 per cent beef from cattle. Here in Canada, we have CFIA regulations to adhere to and we want everyone to be able to adhere to regulations and to follow the science-based rules."

Canada's Food & Drug Regulations (FDR) definition of "meat" refers to the edible part of the skeletal muscle of an animal that was healthy at the time of slaughter.

"CCA's position would be that cell-cultured protein products should meet the legal definition of meat or meat byproducts as defined by the Food & Drug Administration regulations...in order to be labeled and marketed as meat," Babcock states.

"It's about making sure product labeling (isn't) misleading consumers, so whether that's through Food and Drug Administration, or Canada has the Safe Food for Canadians Regulations, that those are being regulated properly."

"The word 'meat' has a specific definition in our current food regulatory framework," says Glanc. "The Safe Food for Canadians Regulations and the CFIA Labelling Requirements for Meat and Poultry Products state that meat and poultry products include all products that contain two per cent (or more) poultry or meat."

What's interesting is how cell-cultured meat challenges this definition, she says. "The final product would contain less than two per cent of cells derived from the original animal, and therefore does not meet the current definitions of meat and would not be able to be named as such."

Asking for public opinion for input on products and labelling is nothing new and has helped shape the industry and food products that consumers know over time. "Whether USDA or in Canada, we have a lot of government consultations come through and it's common practice for them to seek consultation from a wide variety of stakeholders including consumers, farmers and ranchers," Babcock notes.

"They leave consultations wide open so anyone can respond, which I think is fair and appropriate, but I would say is all the input and feedback that comes through those consultations needs to be held to an appropriate science-based level of review. It just comes down to the government making sure they're weighing all the responses appropriately."

A novel idea

Just how will cell-cultured foods be approved in Canada?

Food products created using cell ag technologies "will likely be regulated as novel foods by Health Canada's Food Directorate," CAC's whitepaper states. "As such, they will need to be pre-approved by Health Canada before they can be commercialized. Regulations regarding novel foods are outlined in Division 28 of the FDR."

The current Health Canada Guidelines for the Safety Assessment of Novel Foods were published in June 2006, therefore they'll be quickly outdated when having to refer to cellular agriculture, since food derived from cell cultures isn't mentioned in the guidelines "nor are novel foods derived from animals, however, the requirements are broad enough and could be adapted to cell ag. Depending on the particular cell-cultured food product ..."

As novel as it sounds to some, Glanc in fact says that cell-cultured meat is a "novel product and would likely be regulated as such by Health Canada, but that has yet to be determined." The reason for classification as such, is that (the meat) "doesn't meet the federal definition of meat, and some of the processes used to create the product are novel."

She also adds that at this time, food derived from cell cultures isn't specifically addressed in the regulations in the federal FDR, "but, could likely fit into one or more of the currently definitions of novel foods. The guidelines provide health and safety requirements in order for novel foods to be approved and commercialized."

The FDR has strict guidelines for labelling already. "The FDR explicitly state that 'consumers must not be misled as to the true nature of these products' and goes on to state that the term 'simulated' must appear on labels and in advertisements for all simulated meat and poultry products," says Glanc.

It really is beneficial to all parties, the producers, and the consumers to not have that confusion at the point of purchase and "it's important that products are clear how they're produced, and I do sincerely believe that's in everybody's best interest, to have it very transparent across the board," Babcock says.

Sustainable validity?

One proponent angle for putting cellular based agricultural products onto consumers' plates seems to revolve around sustainability.

There is research to indicate it's not entirely true. Babcock often hears conversations about the sustainable validity of cellular cultured and plant-based meat. "When we look at it, it depends on even what part of the environment you're talking about, so in terms of greenhouse gas yes, cellular cultured meat will produce less methane, but it will produce more carbon dioxide, whether partly from building the industrial plants and then incubating the tissue cultures more so than cattle," Babcock says.

"In the short-term that means cellular cultured meat would have a lower greenhouse gas footprint but if you look at how methane breaks down much faster than carbon dioxide: we've seen some modelling research that suggests cellular-cultured meat would have a significantly worse impact on greenhouse gases in the long run."

Natural climate protection

Many other environmental factors come into question where naturally raised animals in fact do play a vital role.

"Here in Canada, we have the cattle outside grazing and cellular meat does not rely on grassland so it's not contributing to carbon sequestration, soil conservation and healthy wetlands and watersheds the way we see grassland-based beef production does," explains Babcock.

Canada's natural grasslands of the Great Plains need to be conserved, and farm animals play a role in preserving, "an area that cattle production plays a key role in (is) the protection of those grasslands," Babcock says.

Nature United, a Canadian conservation organization based in Toronto, released a report titled Natural Climate Solutions for Canada, published in Science Advances journal on June 24. It highlights the importance of Canada's unique landscapes that animals play a role in preserving. "Avoided conversion of grassland, avoided peatland disturbance, cover crops, and improved forest management offer the largest mitigation opportunities," states the report.

Babcock too highlights the significance of the protection and restoration of Canada's wetlands and grasslands as it holds significant potential to sequester carbon and mitigate Canada's greenhouse gas emissions.

"Cattle production plays a key role in that protection. We want to protect the lands that we have left. It's a lot harder to convert things back to their natural grassland state once they've been converted into other uses."

Scientific assessments

Since the cultured meat industry is still in the early stages of research and development, and the production of cell-cultured meat is still an emerging technology, it's likely too early to determine exact impacts to the environment. "Some of these products/processes claim to be environmentally beneficial: that being said, the federal government requires all environmental claims to be verified with accurate supporting data. Producers of these products should conduct life cycle assessments, similar to the ones conducted on agricultural products, to support their claims to better determine the environmental impact of cell-cultured meat," says Glanc.

There are many factors to consider. "We definitely hear conversations on both cellular and plant-based meat. I think it depends on the audience you're talking to what the conversation is about. Even both products are seen differently by the government. It's something we're learning about. Obviously, the cell-cultured piece is newer in terms of research and what that will mean for the future," Babcock says.

A December 2020 article published in Nature estimated that by 2040, 35 per cent of all meat consumed will be cultured, inferring the reduction of greenhouse gas emissions and antibiotic use.

More than a mere label on a package, if the future of cellular agriculture continues to evolve, what will happen to the natural order of things?

"There is one thing to consider is that it wouldn't be healthy for animals when we look at the loss of genetic diversity if we no longer needed them and what would this do to the genetic resources available to grow cellular meat, so there's other things long-term that could be detrimental," says Babcock. "For the environment too. There are a lot of potential impacts that should be considered."

In the end, terminology, definitions, naming and labelling are all factors that need to be considered and modernized to accommodate cellular agriculture products – and plant-based alternatives.

"Any labelled product should have labels which are truthful, verifiable, consistent with domestic regulations, and consistent with international standards," says Glanc.

"Consistency between terminology, product definitions, and labelling requirements is critical so that trade continues undisrupted, and confusion by consumers is reduced when exporting products between countries," says Glanc.

Ultimately, whichever food item consumers choose to buy and consume is their own individual choice – and variety at the retail level is acceptable, and important.

However, so is accurate, truthful, and easy-to-understand labelling of products which do not mislead consumers and allows for informed choices," Glanc says.

"A truthful and transparent labelling regulatory framework is critical, including for cell-cultured foods. Clear, concise guidelines are necessary to support industry in their understanding and application and transparency of regulatory requirements and support informed purchasing decisions for consumers." BF