Comments to Lab-Grown Seafood Docket Submitted
April 5, 2021
NMPF submitted comments March 8 to the request for information opened by FDA regarding the use of the word “cultured” to label lab-grown seafood products, using it as an opportunity to push FDA to enforce its current dairy standards of identity. The comments touched on three main points including:
- FDA should enforce existing standards before creating new ones;
- FDA should work to coordinate its policies with USDA; and
- “Cultured” should not be used to describe lab-grown foods.
NMPF pointed out that the use of the word “cultured” to describe lab-grown seafood could cause consumer confusion as cultured is a commonly used term to describe dairy products such as yogurt, kefir, cultured butter, and buttermilk. Instead of cultured, NMPF suggested terms that were more suited to describe lab-grown products such as “synthetic,” “lab-grown,” or “cell-based.”
“To be clear, the issue is not that consumers will confuse dairy and seafood,” NMPF states. “They will not. Rather, the problem is that if the word ‘cultured’ becomes understood to refer to foods derived from synthetic processes not found in nature, consumers will think the same word on dairy labels means they have been manufactured similarly or that synthetic seafood products bearing such labeling contain natural cultures that have been in use for centuries – which is clearly not the case.”
Lastly, NMPF reminded FDA that it is bound to follow the Administrative Procedures Act and cannot rewrite a rule through a stated guidance.