We welcome the opportunity to comment on Labeling of Foods Comprised of or Containing Cultured Seafood Cells. As a consumer organization, we prioritize providing clear, helpful label information that consumers can use to make an informed choice.

     We believe that the name or statement of identity of foods comprised of or containing cultured seafood cells should inform consumers about how the animal cells were produced. Vegetarians do not eat seafood and would want to be aware that a product contains cultured seafood cells. We assume that this would also be the case for those with an allergy to seafoods and for those who avoid seafood due to religious beliefs.

     In 2020, a survey was conducted online within the United States by The Harris Poll on behalf of The Vegetarian Resource Group from June 22-24, 2020 among 2,074 U.S. adults ages 18 and older. We found that more than half of the U.S. adult population (54%) always or sometimes eats vegetarian (including vegan) meals when eating out. We asked if survey respondents would purchase a meat alternative grown from animal cell DNA obtained ten years ago, which does not currently involve the raising of animals. Only 12% of respondents said they would purchase such a product; 19% of vegetarians including vegans would purchase a meat alternative grown from animal cell DNA; 19% of those that sometimes or always eat vegan meals when eating out and 18% of those that sometimes or always eat vegetarian, including vegan, meals when eating out would purchase this type of meat alternative.1 Similarly a 2021 national survey was commissioned by The Vegetarian Resource Group and conducted online by YouGov, of 8 -17 year-olds. This survey found that more than half (53%) of 8-17 year-olds sometimes or always eat vegetarian meals when eating out. As was done in the adult poll, we asked if survey respondents would purchase a meat alternative grown from cells (DNA) from an animal, which was collected years ago which does not currently involve the raising of animals. Only 9% of respondents said they would purchase a meat alternative grown from animal cell DNA.2

     While we do not have results specifically examining seafood cell DNA, we imagine that results would be similar.  Since so many consumers would choose not to purchase such a product, it is important that they be informed about the presence of cultured seafood cells in products.

     In addition to label information, it is important for companies to have specific information about the source of these cells in their products on their websites since many people look on product websites for information.

     Use of a term such as “engineered using cultured seafood cells” would help consumers understand that the product is based on seafood and that seafood cells are used in production. An educational program would need to be developed to inform consumers about the meaning of “cultured” in this context. This terminology should be prominently delayed on the product’s label so that consumers are aware of the product’s composition.

     Names for conventionally produced seafood products should be included with the phrase “engineered using cultured seafood cells” with the specific seafood whose cells were cultured identified using the common or usual name.  If consumers generally use a specific name for a certain fish or shellfish, this name should be used as long as it is clear to consumers that the products are made using cells of fish. For example, a product might be labeled, “Engineered using cultured catfish cells.” This would allow consumers who avoid certain types of seafood to be aware of the type of seafood used in production. This is especially important for consumers with a shellfish allergy or who keep kosher and do not eat certain kinds of fish or shellfish.

     Creating a new name for a food that is comprised of or contains cultured seafood cells and using it in The Seafood List is likely to confuse consumers. We believe that the use of a descriptor such as “engineered using cultured catfish cells” is more informative than assigning a product a new name.

     In addition, we urge the FDA to forbid labeling products containing cultured seafood cells as “vegetarian” or “vegan.” Although the FDA does not currently define “vegetarian” or “vegan,” these terms are commonly used to imply that products do not contain ingredients from meat/fish/poultry (vegetarian) or from all animal products and by-products (vegan). Having “vegetarian” or “vegan” on a label of a product containing cultured seafood cells would be misleading to consumers.

     Thank you for the opportunity to comment on this issue.

References

1. What vegetarian and vegan products will American adults purchase? Questions asked by The Vegetarian Resource Group in a national poll. https://www.vrg.org/nutshell/harris2020veganadultwriteup2blog.pdf. 2020.

2. How many youth in the U.S are vegan? How many teens eat vegetarian when eating out? www.vrg.org. 2021.