Current Status of Food Traceability and Labeling in

Current Status of Food Traceability and Labeling in USA* Alan Mc. Hughen, D. Phil. , University of California Riverside, Ca USA [email protected] edu *- and some EU info from Willy De. Greef

Grounds for EU GM food traceability European traceability rules are intended for food safety management AND for consumer choice. n This dual purpose has created an unwieldy regulation which has proven difficult to apply and unsatisfactory for some consumers n (W. De. Greef)

Starting point n Farmer buys certified seed, highest purity obtainable for commodity crop n n Purity is guaranteed to 95% Farmer may instead use saved, common or “brown bag” common seed n Purity level is unknown.

Sources of impurity: Farm n From Farm to Port Seed transport and storage on farm n Seeding equipment n Volunteers and weeds in field n Pollen and seed flow from other fields n Harvesting equipment n Storage and Transport. n

Sources of impurity: Delivery n Admixtures of grain at local elevator Throughout the grain handling system n Barges, rail cars, port storage, Panamax vessels n n Delivery port n Unloading and local delivery.

Traceability demands i. p. , segregation and a paper trail with verification at every step. n Historically used only for high value specialty products n Due to high cost n No need for segregation of bulk commodities. n

Commodity vs discrete products n Corn seeds vs papayas or pumelos Corn seeds are bulked, treated as population n Papayas are discrete, can be treated as units n n Cost of i. p. increases with degree of purity demanded Feasibility based on number of units, and n Number of contact/branch/transfer points n

Traceability of commodity grain Is not feasible except at a cost greater than the value of the commodity (affidavits, testing, etc. at each step) n Cannot achieve purity higher than best starting point (5%) without great cost n Adds nothing to public confidence in food safety n Or in regulatory system n n (30% of non-GM food imports to Korea were actually GM: KFDA)

Why does USA not have mandatory GM food labeling? Labeling in US is based on product process , not n Labels are required with changes to product n composition If new allergens or toxicants are present n If changes to nutrient content n Regardless of method of breeding. n

Practical problems Labelling of foods which do not contain any GM genes or expression products n No labelling of animal products n Tracing agricultural commodities through international trade n Testing and identification n The possibility of fraud (De. Greef) n

The possibility of fraud The tracing and labelling requirements for products in which no GM can be detected is an invitation for fraud, if there is a price difference n The absence of large differences between GM and non. GM commodities suggests that much food export to the EU does not comply with the regulations (De Greef) n

What are the motivations for mandatory process based labels? n Public “right to know” n Informed choice n Possible health or environment effects n Distrust in Government regulators.

Conceptual problems with processbased GM labels n GM Corn, soybean or canola oil sold to consumers is identical to non-GM oil. The label is misleading n Cannot be independently verified by analysis n Ripe for abuse n Leads to consumer distrust in labels in general n And distrust in the regulatory system in general! n

Which processes get labeled? n Agrobacterium ? Biolistic ? n Irradiation mutagenesis ? n Somaclonal variation ? n Embryo rescue ? n Wide crossing genes from distant relatives ? n Genes from same species? n

What about ‘derived from’ products? Soybean GM with soybean gene n Soybean with bacterial gene n Tofu from Soybean with bacterial gene n Oil from Soybean with bacterial gene n Lecithin from Soybean with bacterial gene n

Label problems: Special cases n Soybean from wild-type segregant n Fruit from branch grafted onto r. DNA roots n Bread from wheat with rye genes

Common wheat with Rye DNA Friebe et al. , Crop Science 39: 1692 -1696 (1999)

Economic: Who pays? n In capitalist society, those making marketplace demands pay to have those demands fulfilled. n But with GM labels, demand is from those wishing to avoid purchase; the consumer is forced to pay to fulfill demands of others. n How do we charge the ‘demanders’ to pay for GM food labels?

Mandatory process based labels satisfy and cost everyone n Exceptions, tolerances and allowances frustrate those philosophically opposed to biotech n ‘reverse-onus’ of label liability raises costs to all, especially small farmers and poor people n Alternatives exist. Based on concern: n If a health safety issue, fix regulatory credibility (real hazards are in the product, not process) n If concern is philosophical, voluntary labels work well.

Solution to problems n Traceability of commodity grains adds unnecessary burden to farmers and unnecessary cost to consumers. n n Traceability should be used only for high value, specialty and hazardous materials Labels should be based on food composition, not the breeding process.

Conclusion n Traceability and Labeling are feasible only for physical products, not the process by which they were made. n Laws and policies requiring traceability and labeling for process are impracticable n Leading to loss of public trust in politicians and regulators.