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

Grounds for EU GM food traceability European traceability rules are intended for food safety 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 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 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 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 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 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 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 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 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 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” 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 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 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 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 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 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 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 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 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 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.