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August 29, 2000


GE Food Labeling Pros and Cons; Precautionary Policies on


August 28, 2000 Bangor Daily News Mario F. Teisl

The labeling of genetically engineered foods has been a topic of much
public debate. At one end of the debate are those who feel that
genetically engineered foods should not be labeled unless the food is
significantly altered or presents a health concern (this is the Food and
Drug Administration's traditional position). At the other end of the
debate are the right to know proponents who desire that all genetically
engineered foods exhibit a label stating something like "this food may
contain genetically engineered components."

Both of these positions are shown to be limited when one's viewpoint is
that a labeling policy is justified only if the policy's benefits are
greater than its costs. The benefit of labeling is that it allows
consumers to make choices to match their preferences. Labeling policies
makes the information initially held by the food producer also available
to the consumer. Labeling is beneficial to consumers as they are now more
informed as to the exact attributes of the product. Producers that make
goods with desirable attributes also gain as they are rewarded for their
provision of these attributes.

However, labeling is not free. The financial costs of labeling include the
costs of providing and verifying the information (that is, separating and
then verifying whether a food product does or does not include components
that are genetically engineered). These costs are apt to be significant
for producers who purchase their product inputs from many different
(possibly international) suppliers, suppliers that may change with the
seasons. Importantly, some proportion of these costs will be passed on to
consumers in the form of higher food prices or reduced product choice. In
addition to the financial costs, labeling can impose cognitive costs on
some consumers. Simply increasing the amount of information content on a
label may actually decrease the consumer's ability to process other more
important label information. In addition, requiring specific information
to be placed on a label imposes a cost in that the limited space on the
product label could have been devoted to other, potentially more useful
and important information. Because information content is competing for
valuable space on the label, labeling requirements have to be justified in
terms of the importance of the required information. A prescription such
as "more information is better" does not necessarily characterize an
optimal labeling policy.

Under the benefit-cost paradigm, FDA's policy is seen as justified, but
limited. Justified because when health and safety are concerned the
benefits of a labeling policy are likely to outweigh the costs. However,
the policy is limited in that there may be many other consequences (e.g.,
environmental) that are important enough to consumers that a regulated
labeling program makes sense. However, the "consumer's right to know"
position is also limited in that, taken to the extreme, all product
attributes, no matter how irrelevant, would have to be disclosed. A
decision to impose labels should recognize both its benefits and costs.
When a labeling policy is justified then the policy needs to be designed
so as to maximize its effectiveness. The success of most labeling programs
is contingent upon whether the label information: is understood by the
average consumer; allows consumers to differentiate products; and is seen
as important by a significant portion of the population.

Let's analyze these points in the context of a simple genetically
engineered label for food.

Point 1: The label information is understood by the average consumer. Here
is the first problem. Although most consumers in the United States are
aware of the term genetically engineered, the majority does not correctly
understand this term.

Point 2: The label information allows consumers to differentiate products.
Again, here is a problem. A simple genetically engineered label will not
allow most consumers to differentiate products in the manner they most
desire because the process of genetic engineering can produce a wide
variety of "consequences." When making food choices, a consumer may want
to know whether the food contains peanut allergens, whether the food
contains higher than normal levels of anti-oxidants or whether the food's
production harms butterfly populations. A label that simply states, "may
contain genetically engineered components" is not helpful because it does
not provide enough detail.

Point 3: The label information is seen as important by a significant
portion of the population. Given the previous point, a genetically
engineered label would provide important information only to consumers who
want to avoid genetically engineered foods simply because of the genetic
engineering process. I do not know of any directed research that has
indicated that a significant portion of the U.S. population desires such a
label solely to avoid this process. I want to pause here to clarify what I
mean by "directed research"; it is a common tendency for consumers to
state that they want more information. If you simply ask them if they want
more information about genetically engineered foods they will say yes.
However, you may find that consumers don't actually use this information
if you experimentally test it. Given the above, a sound labeling policy
for genetically engineered food would probably include the following:
. Mandatory labeling of genetically engineered foods that are
significantly altered from consumer expectations of the food; . Mandatory
labeling of any foods (not just genetically engineered foods) that provide
significant "consequences." Further, the labeling should focus on the
consequence, not the process;

Only if directed research indicates that a majority of Americans want to
know about genetically engineered foods, over and above knowledge of the
consequences, should a genetically engineered label be mandatory. Barring
this condition, a voluntary labeling approach, similar to the kosher
label, would be more appropriate.

Given the low level of consumer understanding of genetic engineering
concepts, the complex nature of genetic engineering and its many possible
consequences, a product label stating that a food is genetically
engineered is likely to generate confusion which may lead to misdirected
choices. Any "genetically engineered" labeling program will require a
significant information campaign to educate consumers.

Center For International Development At Harvard University John Mugabe,

The growing international debate on safety of genetically modified
products of modern biotechnology and the adoption of the Cartagena
Protocol on Biosafety are likely sources of increasing uncertainty in
technology and food import policies of many African countries. Confronted
with a strong international lobby against genetically modified (GM) foods
and with scanty scientific knowledge and information on these foods, these
countries are unsure about investing in modern biotechnology, importing
grain or accepting relief food from countries such as Canada, Argentina,
Brazil, Australia and the US.

In Kenya, for example, there is a growing debate on whether the government
should be receiving genetically modified corn from the USA and Canada to
feed the more than 5 million people who are already starving as a result
of severe drought and growing food insecurity. While some
environmentalists oppose food relief from the USA and Canada, they have
not offered alternative sources of food for the hungry.

In the meantime, many African countries are also faced with new policy
challenges arising from the pressure to apply the precautionary principle
in decision-making. Many of these countries have formulated and adopted
biosafety regulations that they are seeking to implement. The regulations
-- as in the case of Cameroon, Egypt, Uganda and Zambia -- contain
explicit reference to the precautionary principle. However, the extent to
which the principle is translated in specific policies needs to be
carefully assessed. What is even more urgent is to determine how the
precautionary principle can be applied in situations of famine and food

The decision by Kenya to accept GM corn from the USA and Canada was not
based on any risk assessment exercise. As one senior government official
remarked, "the government and Kenyans did not have time and the necessary
scientific capacity to undertake risk assessment. Our confidence was
established in the fact that if Americans are eating it, it should be safe
our starving people." Faced with food crises and absence of verifiable
information on harm from the consumption of GM foods, few African
countries will reject GM foods. Effective application of the precautionary
principle in decision-making is likely to be realized as the countries’
range of technological options widens and their level of economic and food
security grows.

In Kenya and Zimbabwe GM crops are still in experimental field trial while
in South Africa they are ready for commercialization. In granting permits
to release GMOs regulators in the countries have relied on results of
scientific risks assessments conducted by applicants -- institutions
seeking to release and/or test GMOs. For example, the South African
Committee for Genetic Experimentation relied largely on the South African
Sugar Association Experimentation Station (SASEX) to provide scientific
information on risks associated with the development and release of
pest-resistant (Bt.) sugarcane. In the absence of such information it is
difficult to apply the precautionary principle. However, decision-makers
or regulators should have the ability to verify the scientific information
given to them by applicants.

The problem of how to regulate the development, importation, and release
of GMOs in the face of scientific uncertainty cannot be effectively
addressed by the mere integration of the precautionary principle in
national biosafety measures. Countries can only effectively apply or
invoke the precautionary principle as their scientific knowledge and
information on GMOs grows. In other words, as their knowledge and
information grow they are also able to determine the nature and level of
scientific uncertainty. Those that do not invest in scientific inquiry are
likely to misuse the precautionary principle to unduly control or restrain
technological change. Implementation of precautionary policies should
therefore focus on promoting scientific research and technological

Effective and equitable biotechnology risk assessment should also be
guided by a clear view of short-term with problems that cannot wait for
future technological solutions. In this regard, the application of the
precautionary principle should take into account technological
opportunities to address immediate and serious malnutrition and human
health problems. This is not to suggest that Africa should sacrifice its
long-term sustainable development aspirations on the altar of quick
technological fixes. To the contrary, precaution should be integrated into
scientific experimentation and technological learning. Policy-makers that
are guided by mere appeals to scientific uncertainty will become unwitting
advocates of environmental authoritarianism.

For more details, please see Mugabe, J. et. al. 2000. "Global
Biotechnology Risk Management: A Profile of Policies, Practices and
Institutions." UNEP and ACTS. (Forthcoming)

From: Andrew Apel

Subject: A Bit Of Irony

654-4400, EXT: 229


Dr. Vananda Shiva to present the keynote at this milestone anniversary

(Oakland, CA) The Institute for Food and Development Policy, also known as
Food First, will celebrate its twenty-fifth anniversary on September 18,
2000, at the Oakland Ballroom in Oakland California. Dr. Vananda Shiva,
world acclaimed activist and author of several books will be the featured
speaker. Leading activists including Francis Moore Lappé and Joseph
Collins, founders of Food First, will be awarded at the event.

Called one of the country’s “most established food think tanks” by the New
York Times, the Institute for Food and Development Policy is a radical
peoples’ think tank with the mission to mobilize people to take action to
end the injustices that cause ecological devastation and hunger throughout
the world.