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Dairy Facts 2016

IDFA to USDA: Align Disclosure Rule with Consumer Expectations, Support Bioengineering

Aug 31, 2017

 It is important that the National Bioengineered Food Disclosure Standard provides consumers with clear and non-disparaging information about their food products, IDFA told the U.S. Department of Agriculture in comments last week. IDFA encouraged writers of the standard at USDA to ensure that the rule adheres to consumer expectations for transparency; does not disparage the use of bioengineering or stifle food industry innovation; and is consistent with other standards applied to U.S. food manufacturers.

IDFA responded to 30 questions released by USDA’s Agricultural Marketing Service in June, which asked for stakeholder input on crafting the standard’s scope, definitions and requirements for disclosure of a food’s bioengineered content.

Require Disclosure of Refined Ingredients

To meet consumer expectations, IDFA stressed to USDA that the rule’s scope should extend to ingredients refined from bioengineered crops.

“IDFA believes that USDA should establish criteria for what is a ‘bioengineered food’ such that disclosure of refined ingredients that come from a bioengineered source, such as sugar from sugar beets or oil from corn, is mandatory,” it said. “Including refined ingredients as part of the mandatory disclosure aligns this marketing program with consumers’ expectations of the law.”

IDFA also asked USDA to exclude certain food ingredients from the rule’s scope, including vitamins, enzymes, or incidental additives. Exempting these ingredients makes the rule consistent with the National Organic Program and the Vermont law’s disclosure requirement, and it reduces supply chain burdens.

Support Bioengineering

IDFA also asked USDA to prevent the rule’s language from obstructing food industry innovations in biotechnology or discouraging its use. It asked USDA to recognize that bioengineering is a safe and proven technology, which aligns with the lawmakers’ intent for the rule.

“IDFA is supportive of providing consumers with accurate and truthful information about the bioengineered content of their food and ensuring that the standard is not disparaging to bioengineering nor does it stifle innovation of future bioengineering techniques,” it said.

It encouraged USDA to seek up-to-date information about consumer perceptions of bioengineering terms used in the standard to ensure that consumers understand and have confidence in the standard.

“If USDA uses language that is not easily understandable, consumers may begin to fear continued use of bioengineering in food, which is stigmatizing to the technology, may suppress continued innovation and limit adoption in the food system,” IDFA said.

Ensure Consistency

IDFA also asked USDA to take notice of other rules required of U.S. food manufacturers to ensure that the disclosure standard is consistent, with existing requirements. These would include:

  • The National Organic Program’s definitions of conventional and non-conventional breeding;
  • The Food and Drug Administration’s recommendation against the use of the term “GMO” due to its potential to confuse consumers;
  • FDA’s rules on the predominance of ingredients to determine whether a multi-ingredient food is subject to disclosure requirements;
  • FDA’s Food Safety Modernization Act definitions of small and very small businesses; and
  • FDA’s definition of food package sizes when determining a “small” or “very small” package.

IDFA also asked USDA to ensure that the rule follows Congressional intent, which says that foods are not subject to the disclosure requirements solely because they are from animals fed bioengineered substances, like corn silage or soybean meal from bioengineered crops.

In the comments, IDFA also recommended criteria for USDA to consider when determining the threshold for the amount of bioengineered ingredients in labeled foods, recordkeeping requirements, location of disclosure labels on products and the ways of disclosing bioengineered content.

Read IDFA’s complete comments here.

Coalition Calls for Clear Disclosure Standard

IDFA also joined more than 30 other American food and agriculture organizations in the Coalition for Safe and Affordable Food in submitting comments to USDA that supported the creation of a clear, defined standard. The groups together agreed that USDA should make clear that the disclosure standard is a marketing standard and not a health or safety standard; create symbols and other methods of mandatory disclosure that are not disparaging toward bioengineering; and ensure that foods are not subject to the disclosure requirement solely because they are derived from animals fed bioengineered foods.

Read the coalition’s comments here.

For more information, contact Emily Lyons, IDFA director of regulatory affairs and counsel, at

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