The US FDA has published guidance for food manufacturers about labeling of food derived from genetically engineered plants. The guidance document discourages the use of the acronym GMO (genetically modified organism), preferring instead the terms ‘genetically engineered’, ‘bioengineered’ or ‘modern biotechnology’.
The intention of the guidance is to prevent claims that could mislead consumers, and the guidance reminds food businesses that it is possible to mislead consumers with information and also with absence of information.
So why not use GMO? Firstly ‘genetically modified’, when used in the strictest sense, applies to almost all of the plant and animal foods we regularly eat. Traditional selective breeding is a form of genetic modification that has been used by humans for thousands of years to improve the foods we grow. When viewed in this context, it is difficult to think of a food that isn’t ‘genetically modified’; the FDA gives the example of berries picked from wild varieties of bushes. With this in mind the term genetically modified becomes open to all kinds of interpretation and wider interpretation means more room for any claim to be misleading.
Secondly, very rarely to do we eat foods that contain actual ‘organisms’, live-culture fermented foods such as yoghurt being the exception. Mixed foods and highly refined foods do not contain organisms and even whole produce comes into question; is a tomato an ‘organism’ or is it merely food derived from the organism known as a tomato plant? Although the FDA acknowledges that consumers can understand the intention related to the use of the phrase GMO, the guidance document is quite specific about encouraging food manufacturers to use alternative phrases to avoid confusion.
It all sounds like a good plan from a legal and compliance perspective, but given that claims related to GMOs are used for the purpose of marketing foods, I have to wonder what the marketing teams of food businesses are going to say when told to replace ‘non-GMO’ with a phrase like this one suggested in the FDA Guidance document: “our tomato growers do not plant bioengineered seeds”. Catchy, huh?