As companies focused on producing cell-based meat continue to secure funding, develop prototypes, and enhance their technologies, they are nearing the point of launching their products. This raises an important question: What should these products be labeled? In September, the USDA, which partnered with the FDA in 2019 to oversee cell-based products, issued a formal request for public input. They posed numerous questions regarding how these products should be labeled on packaging, particularly in comparison to traditional animal-derived products. Which terms would be most appropriate for these new products? Which might be misleading? The public comment period lasted two months and yielded 1,179 responses, with 87 coming from companies, trade associations, policy organizations, and international entities. Comments were submitted by state agricultural departments, cell-based meat companies, traditional meat producers, and various food industry stakeholders. Additionally, 157 individuals provided anonymous feedback, including a U.S. senator.
The feedback revealed a wide range of perspectives on cell-based meat; however, a shared sentiment emerged: these innovative products are distinct and warrant regulatory attention and specific labeling. Deepti Kulkarni, a partner at Sidley Austin LLP and former FDA general counsel, noted that soliciting public comments for regulatory development is a resource-intensive process, yet it underscores the significance of this emerging sector. The influx of over 1,000 comments regarding labeling is indicative of strong public interest. “What we choose to feed ourselves and our families is integral to our cultural identity,” Kulkarni stated. “Meat holds a central place in American culture, driving passionate engagement on these issues. Concurrently, as the global population expands and the impacts of climate change become clearer, many individuals are reevaluating their dietary choices.”
Food Dive reviewed, analyzed, and cataloged all comments submitted by various stakeholders, offering insights into their preferred labeling terminology. Responses ranged from enthusiastic support for cell-based meat innovation to defensive positions about the potential threat to traditional animal agriculture. Proponents of cell-based meat aim to establish an industry that eliminates the need for raising and slaughtering animals, thus addressing the environmental and ethical concerns inherent in livestock farming. Conversely, defenders of traditional agriculture voiced strong opposition. For instance, Agri Beef, a cattle producer, expressed, “Laboratory-manufactured proteins from cultured cells pose a direct threat to the livelihood and economic stability of U.S. producers nationwide.” They argue that manufacturers of cultured cell proteins not only seek to replace traditionally raised meats but also seek to undermine the natural production processes of conventional meats, while obscuring their production methods from consumers.
The North Dakota Farmers Union echoed these concerns, stating that allowing cultured animal cell products to be labeled as “meat” or “poultry” would disadvantage family farmers and ranchers, making it challenging for them to distinguish their products from cell-based alternatives. They emphasized the need for truthful and accurate labeling to support fair competition and informed consumer choices. However, not all comments from the agricultural sector were opposed to cell-based meat. The American Farm Bureau Federation adopted a policy in 2019 supporting the restriction of common meat terms to products derived from slaughtered animals. Yet, they clarified that their comments were not intended to exclude new technologies from the market.
Several state agricultural departments weighed in, with many states proactively enacting their own laws aimed at protecting traditional meat industries. Currently, 13 states have regulations addressing the labeling of cell-based meat products. Kentucky Agriculture Commissioner Ryan Quarles, who advocated for state legislation prohibiting cell-based products from being labeled as meat, emphasized the principle of transparency: “Consumers deserve clarity on what ‘meat’ signifies — it should be meat from an animal.”
U.S. Senator Mike Rounds also cited these state regulations, warning that imprecise labeling could disadvantage consumers in their food choices. Commenters defending traditional agriculture largely agreed with the Farm Bureau’s stance, advocating that terminology associated with meat from slaughtered animals should not apply to cell-based counterparts. The Arizona Department of Agriculture’s Animal Services Division stated that meat should be defined as skeletal tissue from living animals, which cell-based products do not embody. Many comments suggested that terms like “breast,” “loin,” and “flank” should not be used unless the meat originates from an animal.
Proposed terminology to differentiate cell-based meat varied widely. The National Cattlemen’s Beef Association referenced its 2021 research indicating that names highlighting the production method, such as “cell-cultured” and “lab-grown,” enhanced consumer understanding. They found “lab-grown meat” to be particularly clear. Others preferred terms that clearly indicated the products were not genuine meat. The Tennessee Farm Bureau Federation suggested labeling them as “imitation food products derived from meat and poultry,” arguing that cell-based options merely imitate traditional animal products.
In contrast, the California Department of Food and Agriculture proposed more extreme labeling, suggesting terms like “Artificially Grown Animal Tissues” or “Manufactured Animal Tissue” to accurately reflect the nature and source of the products. Most supportive comments from cell-based meat companies lacked the fervor seen in traditional agriculture’s responses. However, some, like The Better Meat Co., framed the resistance to cell-based meat as futile, comparing it to the historical opposition against artificial ice production.
The Good Food Institute, advocating for alternative proteins, argued that cell cultivation is simply a new method of product creation that does not necessitate new identity standards, as was the case for cloned meat. They recommended a cautious approach to labeling, emphasizing flexibility as consumer understanding of cultivated meat evolves. Upside Foods, a California-based cell-based meat company that recently secured $400 million in funding, echoed this sentiment, arguing that strict labeling standards could hinder innovation and make technological advancements more challenging and costly for both companies and consumers.
Upside Foods’ consumer research indicated that a potential label like “Chicken (cultivated from chicken cells)” effectively communicated the product’s nature. They found this label to be more descriptive than alternatives like “cultured meat” or “clean meat.” The company stressed the importance of accurate and objective terminology that does not denigrate either cultivated or conventional products, enabling industry growth without disparaging existing products.
Fork & Goode, a New York-based cultivated meat company focused on pork, likened the term “cultivated” to “organic,” a familiar term that denotes a distinct and recognized process. They argued that cultivated meat signifies a transition from slaughtering animals to utilizing their biology to grow cells outside the animal. Aleph Farms, an Israeli cultivated meat company, asserted that the term “lab” should not be included, as cultivated meat is produced in food processing facilities, not laboratories. They cautioned against using terms like “imitation” or “artificial,” as these could mislead consumers about the product’s true composition.
Companies invested in cell-based meat emphasized the need for flexibility and accuracy in labeling. Tyson Foods, which has invested in cell-based ventures, advocated for transparent labeling that clearly informs consumers about the products. They suggested using appropriate qualifiers such as “cultivated,” “cultured,” or “cell-based” alongside standard identity names to ensure consumer clarity.
Various advocacy and academic groups also sought to promote their agendas through their comments. For example, People for the Ethical Treatment of Animals (PETA) encouraged consumers to adopt a vegan diet while advocating for clearer labeling of animal-derived products. They emphasized the need for labeling that discloses the presence of “slaughtered meat” in food products to enhance consumer awareness.
The Center for Food Safety, which opposes the negative impacts of industrial agriculture, submitted comments addressing concerns about the use of fetal bovine serum in cell cultivation and the implications of genetically engineered cells. They proposed the term “synthetic cell-cultured meat” as a generic product name, clarifying the source of animal cells.
The Academy of Nutrition and Dietetics cautioned against using the term “cultured” for cell-based meat, as it holds a different meaning for consumers compared to how it applies to traditional products. They argued that the culturing process for meat creates a new product, unlike other cultured foods.
Canadian organizations also contributed comments, with many urging the U.S. to align its regulations more closely with Canada’s standards for labeling cell-based products.
As these comments are reviewed, the USDA and FDA will collaborate to determine appropriate labeling terms. A USDA spokesperson indicated that while there is no set timeline for finalizing regulations, product approvals may proceed independently. They assured that all approved labels before the rules are finalized would not be misleading or false. Furthermore, companies entering the market would be informed that labeling requirements might evolve as the process unfolds.
Regulators are currently evaluating the comments, which are being reviewed by technical scientists, policy experts, and legal teams to address any First Amendment concerns. Kulkarni emphasized the importance of ensuring that labeling laws do not restrict commercial speech while adhering to existing federal food labeling regulations. Overall, the guiding principle remains to provide truthful and descriptive designations for food, considering its essential characteristics and source.
As the regulatory process continues, the USDA and FDA will assess how terminology should be applied to cell-based meat products, including whether distinct identity standards are warranted. Kulkarni noted that the diversity of opinions expressed in the comments signifies a shift from an initial black-and-white debate to a more nuanced discussion regarding cell-based meat labeling.