February 2023

We welcome the opportunity to comment on the Request for Information; Identifying Ambiguities, Gaps, Inefficiencies, and Uncertainties in the Coordinated Framework for the Regulation of Biotechnology. As a consumer organization representing vegetarians and vegans, we have a unique perspective on issues related to biotechnology, especially those involving the use of genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA).

4. Describe any specific issues the agencies should consider in developing a plan to implement regulatory reform including any updated or new regulations or guidance documents.

Our response to question 4:

Regulations and guidance documents should require the provision of clear, helpful label information that consumers can use to make informed choices about products produced using new or emerging biotechnology. An example of this is the labeling of foods that were produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA), due to concern for consumer confusion. We believe that the name or statement of identity of meat, poultry, dairy, egg, or other products comprised of or containing cultured animal cells should inform consumers about how the animal cells were produced. Vegetarians, including vegans, do not eat meat or poultry (and eggs and dairy products in the case of vegans) and would want to be aware that a product contains cultured animal cells. We assume that this would also be the case for those with an allergy to meat, poultry, dairy, or egg products and for those who avoid one or more products due to religious beliefs. In addition, consumers may not want to purchase products comprised of or containing cultured animal cells due to concerns about any negative environmental impact of producing these products.¹

The limited acceptance of these products was shown by a survey 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.² Approximately six percent of those surveyed are vegetarian (including vegans) all the time, and half of the vegetarians are also vegan (three percent). More than half (54%) of those surveyed 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.²

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.³

Since so many consumers would choose not to purchase a product produced using animal cell DNA, it is important that consumers be informed about the presence of cultured animal cells in products in clear, easily understood language. This should be indicated in the product name and in the ingredient list on the product label so that consumers can be aware of the product’s composition.

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. This information should also be presented in clear, easily understood language.

Guidance and regulations are also needed to prevent the use of confusing terminology on labels of products produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA). Terms such as “vegetarian,” “vegan,” “animal-free,” or “plant-based” used on product labels of products produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA) are potentially confusing to consumers. Survey research indicates that U.S. consumers are not in favor of labeling products using animal cell DNA or derived from animal genes as “vegetarian,” “vegan,” “animal-free,” or “plant-based.”

A survey, conducted in the United States in March 2022 by YouGov on behalf of The Vegetarian Resource Group, consisted of 2,889 adults.⁴ Over six in ten (62%) vegans didn’t want meat and dairy alternatives that are made using NO animals or animal products but are based on animal cells or DNA extracted years ago from a live animal labeled as vegan. 62%-65% of those that ate vegan meals (not all those individuals are vegan) didn’t want them labeled vegan, animal-free or plant-based, with an even higher percentage at 71% wanting the product to be labeled so it informs consumers that the products use animal cell DNA or is animal-gene derived. ⁴

The terms “vegetarian,” “vegan,” and “plant-based” should not be used in the product name or on the product label of a food comprised of or containing cultured animal cells or produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA). This terminology would be a misrepresentation of the food product. Although neither the USDA nor the FDA currently defines “vegetarian,” “vegan,” or “plant-based,” 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). “Plant-based” has a variety of meanings but it is commonly used to indicate that a product is vegetarian or vegan.⁵ Having “vegetarian,” “vegan,” or “plant-based” on a label of a product containing cultured animal cells would be misleading to consumers.

Additionally, terms such as “non-animal” or “animal-free” should not be used in the product name or on the product label of a food comprised of or containing cultured animal cells or produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA). Use of these terms would be misleading for consumers who, for religious, ethical, philosophical, environmental, or other reasons do not want to purchase products in which animal products were used at some point in production.

The results of our surveys strongly support the need for updated or new regulations or guidance documents related for foods produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA).

5. Describe any new or emerging biotechnology products that, based on lessons learned from past experiences or other information, the agencies should pay particular attention to in their evaluation of ambiguities, gaps, or uncertainties regarding statutory authorities and/or agency roles or processes.

Our response to question 5:

We are concerned that the rush to market foods produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA) may not allow for adequate time to evaluate the safety of these foods for human consumption and for the environment. We urge the statutory authorities and/or agencies to develop rigorous requirements for safety evaluation.

7. What is the highest priority issue for the agencies to address in the short term and in the long term?

Our response to question 7:

As a consumer organization, we prioritize providing clear, helpful label information that consumers can use to make an informed choice. As discussed in our response to question 4, we believe that this is a high priority need that should be addressed in both the short term and the long term. Food labels should clearly indicate that products are animal DNA replicated, so that those with allergies, religious, or other concerns can differentiate these products from similar looking items.

Thank you for the opportunity to comment on this issue.

References

1. Meat Atlas. https://eu.boell.org/en/MeatAtlas. 2021; pp. 60-61.
2. 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.
3. How many youth in the U.S are vegan? How many teens eat vegetarian when eating out? https://www.vrg.org/nutshell/Yougov2021youthteenwriteup.pdf. 2021.
4. How many vegetarians and vegans are there? https://www.vrg.org/nutshell/CulturedMeatYouGov2022.pdf. 2022.
5. What does plant-based actually mean? https://www.vrg.org/journal/vj2018issue4/2018_issue4_plant_based.php. 2018.

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Photo from Casa Borinqueña

The Vegetarian Resource Group maintains an online Guide to Vegan/Vegetarian Restaurants in the USA and Canada. Here are some recent vegan restaurant additions. The entire guide can be found here: http://www.vrg.org/restaurant/index.php

To support the updating of this online restaurant guide, please donate at: www.vrg.org/donate

Here are some new additions to VRG’s guide:

Algorithm Queen Village, 705 E. Passyunk Ave., Philadelphia, PA 19147

Select from signature plates, burgers, sandwiches, grain bowls, tacos, soup, and fries. Hot and cold brew coffee, milkshakes, non-alcoholic beer, milkshakes, and desserts also available. Many gluten-free options as well.

Casa Borinqueña, 6211 Shattuck Ave., Oakland, CA 94609

Enjoy vegan Puerto Rican food! Try the Chicken sampler plate and bori fries (deep fried plantain topped with onions, Impossible meat, mojo, and mama spread).

Karyn’s Kitchen, Flossmoor Commons, 3331 Vollmer Rd., Flossmoor, IL 60422

Karyn’s Kitchen is a plant-based restaurant that serves pizzas, sandwiches, and soups. Pizzas include the meat lover’s made with plant-based meat and the veggie pizza made with hummus, mushrooms, and artichoke hearts. Potato wedges and soup are included with the meatball sub, falafel sandwich, and other sandwiches. The black bean soup is served with shredded jackfruit and coleslaw. Chef’s specials such as vegan mac & cheese are also available.

Ice Queen, 2012 SE 11th Ave., Portland, OR 97214

Enjoy vegan popsicles and Thiccflurries with toppings based on classic paletas flavor. This is 100% plant-based Mexican inspired street food.

Likkle Patty Shop, 80 Poquonock Ave., Windsor, CT 06095

If you’re the type of person who loves new things and always down for an adventure, you’ll be overjoyed to try the goodies at the Likkle Patty Shop! A women-owned vegan Jamaican bakery, Likkle Patty Shop serves a delicious array of patties, coco bread, soups, pasta, pizza, and more! Some favorites include the Jerk Spiced Eggplant Patty: A blend of eggplant, onions, garlic, soy sauce, herbs, spices, and sea salt wrapped in a signature flaky coconut oil crust, and the Baby Got Broc! Patty: A spinach-infused crust filled with broccoli, potato, vegan cream, garlic, red pepper flakes, and nutritional yeast. For those with a sweet tooth, cookies and scones are also available! Packaged meals like “RastaPasta” and “Yumus Hummus” are also included on the menu to purchase.

Tandem Bakery and Café, 1221 Helen Ave., Missoula, MT 59801

Treating yourself to delicious vegan desserts and hot foods is a piece of cake with your local Tandem Bakery and Cafe! From soups and sandwiches to baked goods, a wide selection of vegan and gluten-free options are available to meet your needs. Some popular choices at the café include the Grilled Chz, soft and melty vegan cheese on Multigrain bread buttered and grilled to perfection; Tomato Bisque, a warm and comforting tomato soup with fresh herbs and cashew cream; and the House Salad, a blend of apple sage quinoa, roasted root veggies, and pickled red onions on a bed of mixed greens topped with roasted pecans and served with your choice of house-made dressing. For those with a sweet tooth, donuts, cupcakes, and cakes are also available in-house! Some options include the Hazelnut Espresso Cupcakes, a fluffy vanilla cake infused with espresso and coffee liqueur finished with hazelnut buttercream and garnished with toasted hazelnuts, and the Lavender Lemon Cake, a vanilla cake filled with house-made lemon curd, topped with lavender buttercream, and garnished with dried lavender flowers. All flavors and options are listed on the website or refreshed in-store. For custom treats, please visit the website for more information on lead times, limits, and more.

Willowbeez SoulVeg, 59 Spruce St., Columbus, OH, 43215

Operating as a pop-up in Columbus’ North Market, Willowbeez SoulVeg offers a menu the mere reading of which starts to feed your soul. From the BBJerk Bella with its authentic Jamaican jerk and side of cornbread to the No*Fish Fry made with a breaded Banana Blossom to the Rich Boi comprised of Oyster mushroom drizzled with house-made Remoulade, you may find yourself making multiple trips to North Market in order to try it all. Make sure you visit one Wednesday, as that’s when they serve up their So’Lasagna, which includes eggplant, kale, mushrooms, vegan cheese—and, of course, Love—all rolled in a lasagna shell.

Broccoli Casserole by Rissa Miller

By Rissa Miller, Vegan Journal Senior Editor

Ingredients:

1 medium yellow onion, roughly chopped

2-4 cloves garlic, chopped

1 Tablespoon olive oil

1-2 cups broccoli, chopped (or frozen and thawed florets)

2-3 cups additional veggies, chopped (you can use carrots, corn, celery, mushrooms, spinach, bell pepper, zucchini…)

One 15-oz. can tomato sauce

1 Tablespoon dried oregano

1 teaspoon dried basil

1/2 cup shredded vegan cheddar (optional)

Handful of breadcrumbs

Salt and pepper, to taste

Tabasco sauce, to serve (optional)

Instructions:

Preheat the oven to 400 degrees and spray a 9- x13-inch casserole dish with olive oil.

In a deep pan or cookpot, sauté onions and garlic in oil until soft and fragrant. Add all veggies. Cover and cook for 10-15 minutes on medium heat until veggies reduce. Add water as needed to keep from sticking. When veggies are soft, add dried herbs and tomato sauce and simmer for another 5-7 minutes to combine flavors.

Pour into the prepared casserole dish and top with cheddar shreds and breadcrumbs. Bake in the oven, covered, for 10-15 minutes until the cheese is melty and top is lightly toasted. Serve immediately while hot. Season to taste with Tabasco sauce or more oregano/basil.

Thank you to more generous donors, in 2023 The Vegetarian Resource Group will be awarding $30,000 in college scholarships! Deadline is FEBRUARY 20, 2023.

We will accept applications postmarked on or before FEBRUARY 20, 2023. Early submission is encouraged.

Applicants will be judged on having shown compassion, courage, and a strong commitment to promoting a peaceful world through a vegetarian (vegan) diet/lifestyle. Payment will be made to the student’s college (U.S. based only). Winners of the scholarships give permission to release their names to the media. Applications and essays become property of The Vegetarian Resource Group. We may ask finalists for more information. Scholarship winners are contacted by e-mail or telephone. Please look at your e-mail.

If you would like to donate to additional scholarships or internships, go to www.vrg.org/donate

Applications

Please click here to download a PDF of the application. However, applicants are not required to use an application form. A neatly typed document containing the information below will also be accepted as a valid application.

Please send application and attachments to [email protected] (Scholarship application and your name in subject line) or mail to The Vegetarian Resource Group, P.O. Box 1463, Baltimore, MD 21203.

If emailing, please put your essay in a separate attachment with your first name and last initial. A PDF or Word document is preferred, but if you send a Google document, make sure permission is given so readers can access it. For more information call (410) 366-8343 or email [email protected].

Each issue of Vegan Journal, Chef Nancy Berkoff pens the Vegan Cooking Tips column. One of her columns focused on eggplant. She offers a variety of ways to prepare eggplant including:

• Roast an eggplant whole, in the oven or on the grill, until soft enough to mash with a fork. Scoop out pulp and add oil and vinegar, garlic, and black pepper to use as a dip or salad dressing. This dish is sometimes called “eggplant caviar.”
• For homemade baba ganoush, purée roasted eggplant and mix with garlic, tahini (sesame paste), lemon juice, chopped parsley, and olive oil. Use it as a dip for vegetables or as a sandwich filling.
• Mix diced, grilled eggplant with grilled peppers,lentils, onions, and garlic. Serve cold, topped with balsamic vinaigrette, or hot, atop grains, pasta, or pizza.
• Skip-the-Frying Baked Eggplant: Peel eggplant and cut into ½-inch slices. Create a breading with your favorite crumbs (bread, cornmeal, etc.) and dried Italian herbs (garlic powder, oregano, parsley, red pepper flakes, etc.). Spray eggplant slices with vegetable oil, coat with breading, place on non-stick pan, and bake until soft. Layer baked eggplant into a deep baking dish, alternating layers with thick tomato sauce; drained, diced, canned tomatoes; sliced mushrooms (if desired); and either shredded vegan cheese or thinly sliced extra-firm tofu. Cover and bake until bubbly.
• Mini Japanese or Thai eggplant stuffed with a mixture of diced smoked tofu, tempeh, or veggie crumbles; pine nuts; and roasted peppers. Wrap in foil and bake.
• Make Eggplant Frisbees: Preheat oven to 375 degrees. Place slices of unpeeled eggplant (about ½-inch thick) individually on a non-stick baking sheet. Sprinkle with grated vegan cheese, minced onions, sunflower seeds, and nutritional yeast. Bake until bubbly and the eggplant is slightly soft. The Frisbees may also be used as eggplant burgers served on a hearty roll with fixins.

Find the complete article here: https://www.vrg.org/journal/vj2021issue4/2021_issue4_cooking_tips.php

Subscribe to Vegan Journal in the USA only by visiting https://www.vrg.org/member/2013sv.php

We welcome the opportunity to comment on Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug, and Cosmetic Act (Edition 5): Guidance for Industry [Draft Guidance].

As a consumer organization, we prioritize providing clear, helpful label information that consumers can use to make an informed choice. We commend the FDA for their consideration of newer methods of food production and trends in food choices and for promoting the provision of clear information to consumers.

Specifically, we were pleased to see guidance specifying that products packaged in containers or in bulk to be used by food manufacturers that contain a major food allergen must comply with the allergen labeling requirements (B.2, B.3). This is important to help assure proper handling and clear labeling of the finished products. We were also pleased with the guidance for declaration of incidental additives in spice mixes which might be major food allergens (B.4). This guidance will also protect consumers. We also agree that an incidental additive that contains a major food allergen would have to be declared as a food source of the major food allergen (D.10).

Allergic reactions have been associated with the consumption of milk from other ruminants in addition to cows. In order to protect consumers, we are in favor of a revision of the FDA’s interpretation of “milk” for this guidance (C.1). We propose a revised phrase “animal milk” or “animal-derived milk” which would distinguish cow, sheep, goat, buffalo and other ruminant species’ milk from “plant milk” which would include milk derived from plant sources and that does not contain animal products. These revised phrases would be used in educational and informative materials about major food allergens. On food labels, the source of the animal milk should be identified similar to the way in which the specific species of fish or Crustacean shellfish or type of tree nut are identified.

Similarly, due to the potential risk of allergic reaction from various bird species, the definition of “egg” (C.2) should be revised to include eggs from other bird species in addition to chickens. On food labels, the source of the egg should be identified similar to the way in which the specific species of fish or Crustacean shellfish or type of tree nut are identified.

We support the proposed guidance that proteins from major food allergens, produced in other sources through the use of genetic engineering are subject to the food allergen labeling requirements of the FD&C Act (B.14). This type of labeling will help to protect people with food allergies who may be misled by product labels containing statements such as “animal-free” or “vegan.” We propose that food allergen information on these products should be in readable type or a readable background, not only in the ingredient listing but also along with any other declarations on the labels which may be confusing to the consumer related to the presence of the allergen. These could include terms such as “animal-free” or “vegan.” We do not think that these terms (“animal-free” or “vegan”) should be used on labels of foods that were produced through genetic engineering based on the DNA of animals (whether based on actual DNA, cell lines, or virtual DNA), due to concern for consumer confusion

We are concerned with the response to question D.8 that does not clearly state what is needed in order to “ensure that the ingredient does not contain protein.” In order to protect the consumer, products containing lactose or ghee should be required, without exception, to declare milk on the label. The possibility that a product may contain residual protein from milk is of great concern for those with food allergies.

We agree with the statement in response to question D.13 that good manufacturing practices should be used to protect against food allergen cross-contact. We are concerned that sometimes allergen advisory statements to warn consumers about potential allergen cross-contact are confusing to consumers. The allergen advisory statement may list an ingredient that does not appear in the product. It would be helpful to consumers to clarify that shared equipment or other cross-contact is the source of the allergen. Thank you for the opportunity to comment on this issue.

Blueberry muffins photo by Rissa Miller

By Rissa Miller, Vegan Journal Senior Editor

Ingredients:

Non-stick spray

1-1/2 cups fresh blueberries

1 Tablespoon all-purpose flour

1 banana

1 cup unsweetened, plain soymilk

1/2 cup unsweetened applesauce

2 Tablespoons maple syrup

1-1/2 cups oat bran

1 cup all-purpose flour

2 teaspoons baking powder

1 teaspoon cornstarch or arrowroot powder

1 teaspoon cinnamon

Pinch nutmeg (optional)

Pinch ground allspice (optional)

Pinch salt (optional)

Instructions:

Preheat the oven to 375 degrees. Prepare a muffin tin with non-stick spray and set aside.

In a small bowl, toss blueberries in 1 Tablespoon flour to coat. Set aside.

In a large mixing bowl, mash banana until very soft/pourable. Stir in soymilk, applesauce, and maple syrup. Gradually add oat bran and mix thoroughly. Then add 1 cup flour, baking powder, cornstarch, cinnamon, nutmeg, allspice, and salt. Stir until just combined but do not overwork. Gently fold in flour-coated blueberries.

Pour into the prepared muffin tin, filling each compartment to the top, and bake for 18-20 minutes. A Toothpick will come out of the batter cleanly when done (blueberries will still be moist). Cool for 20-30 minutes before removing from the muffin tin.

Citrus fruit is readily available this time of year. The articles below offer a wide variety of vegan recipes featuring citrus fruit.

Citrus Magic, by Debra Daniels-Zeller, provides recipes for Blood Orange Salad Dressing, Chipotle-Citrus Tofu Marinade, Raw Kale and Avocado Salad with Lemon Dressing, Tangerine Dream Cake, Broiled Grapefruit, Zesty Lemon-Mustard Dip, Parsley Rice with Carrots, Lime, and Pistachios, Orange Oats and Cranberries, and Grapefruit, Apple, and Avocado Salad with Satsuma Vinaigrette. See: https://www.vrg.org/journal/vj2013issue4/2013_issue4_citrus_magic.php

Another article by Debra Daniels-Zeller titled Lighten Up with Citrus offers Orange Buckwheat Porridge with Toasted Pecans, Guacamole, Creamy, Spicy Black Bean Soup, Cabbage, Carrot, and Raisin Salad with Citrus-Tahini Dressing, Orange-Almond Dressing, Citrus Baked Tofu, Lemon-Kale, Caramelized Onions, and Basmati Rice, Lemon-Banana Cashew Cream, Kumquat-Cardamom Coconut Pudding, and Lime Granita. See: https://www.vrg.org/journal/vj2005issue1/2005_issue1_lighten_up.php

To subscribe to Vegan Journal, visit: www.vrg.org/party

By Jeanne Yacoubou, MS

Israeli startup Redefine Meat creates meat substitutes (alternative meat or alt-meat) from plant-based ingredients using a version of 3D-printing it calls additive manufacturing. According to the website, their products are “…plant-based, made with non-GMO ingredients, and do not contain any animal-based ingredients or by-products.”

What is additive manufacturing in alt-meat production?

Redefine Meat offers this explanation of additive manufacturing on its FAQ page: “Additive Manufacturing/3D printing…is precise, flexible, and can eliminate supply chain inefficiencies…3D printing…enables the production of exact formations that can duplicate the muscle and fat structures found in…whole-muscle cuts…3D printing also offers flexibility, facilitating the printing of different shapes, sizes, or combinations of “fat” and “muscle” without having to retool or reset the machines.”

More details on the technology behind additive manufacturing appear in a Vegconomist article by Daniel Dikovsky, Head of Innovation and Technology at Redefine Meat. In that article, Dikovsky describes how 3D printing is used to replicate slaughtered animal tissue.

In a process known as multi-material food printing, “…designed especially for alt-meat, the Redefine Meat 3D printer lays down blood, fat, and protein simultaneously at a voxel-level according to the digital structure mimicking that of animal meat. Furthermore, these ingredients can also be precisely combined on-the-fly during the printing process itself to create entirely new digital materials designed to replicate a specific animal composite…Using the same 3D printer, companies can print different meat types…and different meat cuts…by simply changing the digital file.”

Redefine Meat alt-meat products

An October 2022 article in Food Navigator reports that Redefine Meat offers meat analogs of beef and lamb flank cuts, ground beef, sausages, burgers, lamb kababs, and pulled meat. They are currently available in the foodservice sector in select countries including UK, Germany, the Netherlands, Austria, France, and Israel.

A website FAQ states that Redefine Meat products “…are certified Kosher Pareve (non-dairy) by the relevant authorities, according to where each product is manufactured. For details on each Kosher certificate, please consult each package.” In another FAQ about Halal certification, the Company says their products are not certified Halal but “they meet the criteria.”

Ingredients in Redefine Meat

Based on the ingredient statements listed on their website, Redefine Meat products contain various combinations of all or most of the following primary ingredients:

• wheat, soy, pea, or potato proteins
• barley malt
• yeast extract
• coconut butter
• canola, sunflower oils

Spices, flavors, colors, or ingredients used to help regulate taste or texture of the final product vary.

VRG communication with Redefine Meat

The VRG asked Redefine Meat about its alt-meat. We wanted to confirm that no animal products, including animal or dairy genetic material, were involved in making them.

Here is our October 2022 email exchange with Robin Fine, a Business Development Representative with Redefine Meat:

The VRG: Could you please confirm:

1. Your products contain no animal-derived ingredients.
2. There is no animal- or dairy-derived genetic material used to make your products at any step in the process. This includes no animal DNA (including genes coding for dairy ingredients) from a digital library.

Redefine Meat: Redefine Meat products are made from plant-based ingredients and are 100% vegan. They include ingredients from a variety of food groups recommended in a balanced diet, including proteins, carbohydrates, and vegetable-based fats. Additional information about our products can be found in the product section of our website.

The VRG: The words “plant-based” and “vegan” mean different things to different people. So to get clarity on how you’re using them could you please confirm that your products:

1. Contain no animal-derived ingredients at all (including microingredients like animal-derived stearic acid or dairy-derived whey as well as macroingredients like gelatin or beef fat)
2. No animal- or dairy-derived genetic material – including virtual DNA – was inserted into microbes to produce animal and/or dairy proteins later used in your products. Nor was animal- or dairy-derived genetic material used in any other way during product design or manufacture.

Redefine Meat: Our products do not contain any of the…ingredients or materials [you mention] and are 100% plant-based.

The VRG noticed that in the website descriptions of only four of the 12 items listed in January 2023 were there “allergen advice” that the products “may contain” eggs and milk. We followed up with Redefine Meat:

The VRG: Why the difference in allergen warnings for the beef mince, burger, sausage, and lamb kabab mix, especially if you say all your products are vegan?

Redefine Meat: Currently, some of our products are manufactured in a facility that produces dairy products (not Redefine Meat products). Because multiple products may be manufactured in the same manufacturing facility (even if not on the same machines), they could possibly contain traces of eggs and milk. We prefer to be on the side of caution – thus the inclusion of eggs and milk in the allergen warning.

3-D printing of meat substitutes: animal cells

Several food startups use 3D-printing to create alternative meat. Some of them use animal cells.

Dutch company Mosa Meats created the first lab-grown (also called cell-cultured, cultured or cultivated) beef burger in 2013 using animal cells. Aleph Farms in Israel developed the first beef steak from animal cells in December 2018. Two years later, the American company, Good Meat, created chicken nuggets from cultured chicken cells. The company served them in Singapore, where they are approved for human consumption.

Meatable is a Dutch startup using cells extracted from cows or pigs. They create immortalized animal cell lines so manufacturers don’t need to retrieve cells from live animals each time. The company introduced cultured pork sausage in July 2022.

An Israeli startup, Steakholder Foods (formerly MeaTech 3D), reports that it makes the largest (4 oz.) lab-grown steak. Like other companies using bovine cells, they start with live animal tissue samples. The company transforms the bovine samples into a “bio-ink” that runs through a 3D printer. Later in an incubator, the original cells become the fat and muscle cells in the final alt-meat.

3D printing of meat substitutes: plant-based

A few startups create meat analogs without animal cells via 3D printing. In 2020, three students formed Legendary Vish in Austria to use 3D printing to make vegan fish. Their first prototype was salmon made from mushrooms, pea proteins, plant-based gelling agents, and plant oils. Legendary Vish is in the beginning stages of development.

Since 2018, Spain’s Novameat produces cultivated pork and beef steak with a 3D printer. Pea protein, seaweed, and beetroot juice are some of the ingredients in their products. Based on their website, this company is still in the early stages of product development.

VRG recommendations on 3D-printed alt-meat

Cell-cultivated meat technology is rapidly changing. It is difficult to keep up with it. So far, there are definitely some companies that use live animal cells. Their final products contain these animal cells that have been differentiated into fat and muscle cells. So, they are not vegan, nor are they vegetarian.

If you suspect that a company is using a method involving animal cells, make an inquiry before purchasing their product to be sure. If it’s not clear what they’re doing or what’s in the meat analog, ask for clarification. Use our questions above to Redefine Meat as templates for your own. Please let us know at [email protected] what you discover.

The contents of this posting, our website and our other publications, including Vegetarian Journal and Vegan Journal, are not intended to provide personal medical advice. Medical advice should be obtained from a qualified health professional. We often depend on product and ingredient information from company statements. It is impossible to be 100% sure about a statement, info can change, people have different views, and mistakes can be made. Please use your best judgment about whether a product is suitable for you. To be sure, do further research or confirmation on your own.