Borobia 2
Solution for the Mandatory Labeling of Genetically Modified Foods
Submitted to Dr. Margaret Hamburg,
Commissioner of the U.S. Food and Drug Administration
Manuel E. Borobia Sánchez
Florida International University
Solution for the Mandatory Labeling of Genetically Modified Foods
The synthesis of genetically modified (GM) organisms, that secrete pesticidal or herbicidal substances, produce greater yield in mass or that contain increased vitamin or nutritional content, has become a standard practice within the Agriculture Industry of the United States. According to the FDA Consumer magazine, seventy to seventy-five percent of the products we are consuming are or contain genetically modified foods (Bren). Even more alarming is the exponential growth that this prevailing practice of producing genetically modified organisms – and using them as primary ingredients in many of our food products – has experienced in the past two decades. According to Deborah B. Whitman, a Biotechnology Magistrate and senior editor of the Cambridge Scientific Abstracts Journal, the cultivation of genetically modified soybean has risen from 7% in 1996 to 54% in 2000; transgenic corn production has increased from 1.5% to 25% during the same time period. Today, the USDA estimates 90% of all crops cultivated in the US are genetically modified (Moskin). Despite the widespread cultivation of GMOs – or their predominance as constituents of the great majority of our shelved goods – many consumers remain unaware of the true composition of the foods they are consuming as the FDA labeling laws do not legislate the mandatory disclosure of a food’s genetic make-up, whether organic or modified. Although the consumption of these foods has yet to be proven detrimental to humans, a staggering 9 out of 10 people support the mandatory labeling and or clear identification of GM foods as such (Hensley). The FDA, however, has inconsiderably rejected the dozens of proposed bills that advocate GM food labeling, upholding that the industry would fall victim to great economic loss, completely disregarding the right of consumers to know the content of the food being consumed. It is your duty, however, as the Commissioner of the FDA, a doctor of medicine and a mother to uphold the right of nutritional choice and consumer knowledge.
The mandatory labeling of GM foods should be enacted to defend the right of the consumer to know the content of the product being bought. This drastic measure, however, will not be implemented very hurriedly, as the economic fallouts many biotechnology companies wish to avoid are theoretically sound and may in fact present a danger to the economy. The first step to instigate this practice, then, is to inform biotechnology companies that such a legislature will be passed. In this way, producers of genetically modified foods will have ample time to promote their product, suggest strategies that will mitigate the initial economic impact they will suffer, and take the necessary measures to ensure labeling may be implemented in their factories. The second step to follow, concurrently with the first, would be to create a labeling convention, among both the FDA and biotechnology companies, that clearly differentiates between genetically modified content, while not deterring the consumer from avoiding what would be thought of as a warning label. Finally, the labeling of the genetically modified products and derived ingredients would be initiated.
According to Pam Scholder and Paula Fitzgerald, both of whom hold Doctorates in marketing and specialize in analysis of consumer behavior and perceptual biases, state that the “Stigma Theory” may be the greatest risk to GM food labeling (69). As explained by the authors, in the scholarly article “Stained by the Label? Stigma and the Case of Genetically Modified Foods,” the “Stigma Theory” describes a consumer bias against a marketed product due to the perceived – and sometimes unfound or unknowledgeable – notion that said product holds undesirable qualities or flaws, thereby deterring consumers from opting to buy this product (Scholder and Fitzgerald 70). Genetically modified foods have been tainted with the uncertainty of whether they present a significant health risk; the main arguments against their consumption include the unknown side effects of prolonged consumption, the possible transfer of antibiotic resistance and the lack of transparency in GM food production (Bittman). Labeling GM foods as such would thus initially deter many consumers from opting to buy these products, even though they may have been consumed regularly while unlabeled. The notion of GM foods as unhealthy and unnatural artifacts of scientific manipulation thus arises not from empirical knowledge of their danger, but from the misrepresentation of these food products as unhealthy substitutes to more costly organic food and from the unavailability of easily accessible, reliable information on the beneficial aspect of GM food consumption. The first step in initiating the labeling of GM foods would then have to be informing the producers of GM food products that a legislation mandating the labeling of all food products will be signed. This way, food companies would be allowed a grace period of approximately six months to market their product. Such marketing should not at first advertise individual products, but aim to educate the public on the many benefits of GM foods. These informative and appealing ads, which emboss and bolster the supplementary benefits that GM foods may have on consumers’ diets, would be coupled with the creation of a website that further informs consumers of these benefits, as well as details the labeling conventions reached and the methods of testing used to approve GM foods. The carefully planned, strategic marketing of the GM foods would then reduce the economic impact of the stigma held by these products by targeting directly its root cause – educating the misinformed public and showing transparency and trustworthiness to consumers.
However, the cost of implementing the labeling GM foods, as well as the necessary marketing of these products, is the one of the leading oppositions to instigating such legislation. According to a study conducted by the Canadian Department of Agriculture, Fisheries and Food, the estimated cost of labeling GM foods is approximately 24 million US dollars, as opposed to the food industry’s estimation of 800 million US dollars (Lalonde) – Canadian shelves also hold roughly 70% of GM food products (Lalonde). Although 24 million dollars may seem like a very costly expenditure, US consumers spend approximately 1.5 trillion dollars on processed foods (U.S. Food Industry Overview) – 1 to 1.12 trillion dollars on the 70 to 75% of the shelved GM food products. While the approximation of 24 million dollars does not include the marketing campaigns proposed, the inevitable – yet minimal – raise of food cost offset the expense. The promotion of GM products as a healthier alternative to organics, however, would prove to be a great investment; more consumers will become aware of such benefits and sales of GM foods will thus increase, allowing for a return that justifies the initial expenses.
Labeling practices of GM foods, however, may not be left to the will of the individual biotechnology companies that produce such foods. As the FDA Fair Packaging and Labeling Act describes, any labeled commodity must be labeled appropriately so as to accurately identify the contents of said commodity, while appearing conspicuously and concisely in order to clearly expose the information with little provocation of reasonable doubt (HHS). The labeling of GM foods must also be carefully designed so as to reduce the impact of the GM food stigma. Many of the proposed and rejected bills that advocate the labeling of GM foods failed for one reason: they proposed a “warning” label. This label insinuates that the marked food holds a potential health hazard, which clearly alarms consumers and deter their sale. In order to implement a labeling practice that reduces the stigma held by GM foods, while abiding by federal laws and appealing to consumers, I suggest a committee be formed by representatives from each biotechnology company – or those interested in participating. This committee would have the purpose of acting as a union or advocacy syndicate that takes part in planning the GM food labeling mandate with the FDA and other federal agencies involved in the law’s creation and signing. This way, through the efforts of the biotechnology company syndicate and the cooperation of the FDA, the legislation planned will conform to the standards of clearly informative labels, while allowing the minimum disturbance in consumers’ trust of the product.
As Scholder and Fitzgerald explained, the design of the label plays a significant role in both appealing to the consumer while attenuating any existing bias against the product (70). As the stigma on genetically modified food products will not be fully alleviated during the period marketing of these foods, I suggest companies refrain from immediately adding decorative stamps that expose their product as GM. Companies should first use solely the mandated labeling and identification of their GM product – most fitting would be the acronym “gm” next to modified ingredients in the back label – gradually implementing cover designs that designate the product as GM. This gradual, though slow process, allows the companies selling these GM foods to reduce the overall impact of identifying the high percentage of GM foods in the market, while permitting consumers the necessary time to adjust to the change. After the necessary adjustment time has been reached – six to eight months after the signing of the law and its implementation – biotechnology companies should further expand the labeling of their GM products to reach standards of certification. As with organic foods, which bolster their perceived quality using an “Organic Certified” label granted by the FDA, GM food companies should market their products in the same manner, advertising the certification grade of the food. This may thus promote the creation of new standards of food testing that increase the questioned safety of the food’s consumption, while allowing for a form of legitimate advertisement that informs customers of the examined and certified benefits of the food. Although reaching such standard will entail the initial expense of marketing the products, as well as the sustainment of a possible initial loss in revenue when the labeling is implemented, reaching the certified labeling stage will already have compensated the investment. Furthermore, with continued marketing, promotion and sale of the GM products, the increased consumer’s confidence in the safety and reliability of the food will allow the expansion of the industry by promoting the formation of new methods of development and testing novel foods, as well as by encouraging the creation of healthier foods that may even be engineered for specific diets.
According to Angus Reid, an international polling corporation, American’s worries on the health benefits and trust worthiness has been steadily increasing over the past years (Genetically Modified Foods). The same nation-wide poll that found the trend of increasing worry on GM food safety and reliability, however, also found that the number of consumers likely to buy the GM product after labeling were elevated when compared to data obtained two year previous (Genetically Modified Food). The growing trend in labeling advocacy and support, as well as the increasing awareness of food content will play a vital role in the future of GM foods, the growth of the agriculture and biotechnology industry, and the development and progression of existing methods of GM food production. Currently, seventy to seventy-five percent of foods in our markets are or contain genetically modified foods (Bren). The increased production of GM crops as well as ever-increasing foods demands in the United States will likely increase the prevalence of GM food products for sale. The increased practice of GM food sale, however, has yet to unveil to consumers the many benefits of these foods. This promotion of ignorance and bias, which continuously feeds the growing stigma on GM foods, may only be overcome through cooperative legislation of mandatory labeling. Mandated labeling would promote the education of the public on the many benefits of GM foods through necessary marketing of the products, thus attenuating the existing stigma. Continued advertisement of the foods, as well as carefully designed and gradually increased labeling of GM products, would further decrease consumer bias, while increasing the safety of and confidence in the foods and progressively augment the profits of the industry. As the Fair Packaging and Labeling Act states, “Informed consumers are essential to the fair and efficient functioning of a free market economy” (HHS). Defend the right of consumers to be informed of the composition of their foods by supporting the labeling of GM foods.
Works Cited
Bittman, Mark. “Why Aren’t G.M.O. Foods Labeled?” New York Times 15 Feb. 2011. Web. 18
July 2012.
Bren, Linda. “Genetic Engineering: The Future of Foods?” FDA Consumer Nov. 2003. Web. 3
Aug. 2012.
“Genetically Modified Food.” World Public Opinion. Web. 7 Aug. 2012.
Hensley, Scott. “Americans Are Wary Of Genetically Engineered Foods.” National Public Radio
12 Nov. 2010. Web. 3 Aug 2012.
Lalonde, Michelle. “Cost to label genetic food is overblown.” The Montreal Gazette. 18 March
2007. Web. 6 Aug. 2012.
Moskin, Julia. “Modified Crops Tap a Wellspring of Protest.” New York Times. 7 Feb. 2012.
Web. 3 Aug. 2012.
Scholder Ellen, Pam. Fitzgerald Bone, Paula. “Stained by the Label? Stigma and the Case of
Genetically Modified Foods.” Journal of Public Policy & Marketing 27.1 (2008): 69-82.
Web. 18 July 2012.
U.S. Department of Human Health and Services (HHS). “CHAPTER 39 – Fair Packing and
Labeling Program.” Fair Packaging and Labeling Act. 20 May 2009. Web. 8 Aug. 2012.
U.S. Food and Drug Administration (FDA). “Guidance for Industry: Voluntary Labeling
Indicating Whether Foods Have or Have Not Been Developed Using Bioengineering;
Draft Guidance” Food and Drug Administration Jan. 2001. Web. 3 Aug 2012.
“U.S. Food Industry Overview.” Plunkett Research. 2012. Web. 6 Aug 2012.
Whitman, Deborah. “Genetically Modified Foods: Harmful or Helpful?” Cambridge Scientific
Abstracts. Apr. 2003. Web. 3 Aug. 2012.