Foods Produced from Animal Cells: What’s in a Name?
Industry and government authorities continue to debate the regulatory pathway regarding the approval framework for foods produced from animal cells, also known as cell-based foods. One of the topics yet to reach consensus is nomenclature: what do we call these new foods made by animal cell culture technology? Let’s take a closer look to see how this is playing out across the globe.
The Food and Agriculture Organization of the United Nations (FAO) has published three technical background documents for cell-based foods[1]. One of the documents focuses on “terminologies” of cell-based food[2]. Specifically, FAO reviewed different expressions and names used for cell-based foods by government authorities, academia, consumers, and industry players around the world. These names included cultured meat, cultivated meat, lab-grown meat, fake meat, cell-based meat, synthetic meat, clean meat, artificial meat, healthy meat, imitation meat, in-vitro meat, animal-free meat, slaughter-free meat, test tube meat, cruelty-free meat, etc. FAO concluded that, overall, “cell-based,” “cultivated,” and “cultured” are the three major terminologies used or preferred by consumers, industry, and the authorities, while advising that national authorities should establish clear and consistent terminologies that align with their nation and language contexts to mitigate potential miscommunication related to the nature of cell-based foods.
This past October in Singapore, the Good Food Institute APAC and APAC Society for Cellular Agriculture, along with other key industry stakeholders, met and announced their alignment with the term “cultivated” as the preferred English-language descriptor for food products grown directly from animal cells[3].
In early 2020, Professor Shouwei Wang, from the Chinese Meat Food Research Center, recommended that “cultured meat” (in Chinese: 培育肉 (pei yu rou)) is the most appropriate name to describe cell-based meat[4].
In November 2022, the United States Food and Drug Administration (FDA) completed the first pre-market consultation for a cell-based chicken product, which in its announcement, referred to the term, “human food made using animal cell culture technology”[5]. FDA clarified, however, that this is not FDA’s recommendation of the appropriate common or usual name for declaring the substance in accordance with the United States Department of Agriculture (USDA), Food Safety and Inspection Service’s (FSIS) labeling requirements[6] given that FSIS is the agency that has oversight of issues associated with labeling and the common or usual name for cultured animal cell human foods that incorporate livestock or poultry cells. Thus, FSIS’s recommendations and guidance in terms of nomenclature of cell-based foods remain to be seen[7].
We are still at the early stage of cell-based food technologies and now is the time to ask ourselves: what’s in a name? The answer will have far-reaching implications and will help educate consumers to better understand the nature of these new foods. One example in this regard is the term, “genetically modified food” (in Chinese: “zhuan ji yin shi pin”) used in China. Many consumers in China attach a negative connotation to the term “genetically modified food,” and some even interpret “genetically modified” as having an impact or potentially altering our genetic makeup after consuming the food. Undoubtedly, nomenclature, along with proper public education, can have a more positive impact on consumer perception and purchasing decisions. Since countries have not yet developed rules for nomenclature regarding this new form of alternative protein technology, now is the time to give careful consideration and thought to how this new technology is characterized because whatever name is attached to these foods will have, for good or bad, a lasting impact on consumer perception. Industry should closely monitor developments at the international, regional, and national levels and advocate collectively, with careful thought, whenever the opportunity arises.
If you have any questions on the above topic or other regulatory matters pertaining to cultured meat or other alternative protein products, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), or your existing contact at Keller and Heckman LLP.
Keller and Heckman represents the food industry on regulatory matters, including alternative protein companies around the world. Please sign up for our newsletters here to keep up with the latest developments.
[1] These documents discuss “generic production processes,” “terminologies,” and “regulatory frameworks” of cell-based foods. Please see https://www.fao.org/food-safety/scientific-advice/crosscutting-and-emerging-issues/cell-based-food/en/.
[2] https://www.fao.org/documents/card/en/c/cc2241en.
[3] https://www.apac-sca.org/post/leading-apac-cellular-agriculture-stakeholders-announce-historic-agreement-in-singapore.
[4] WANG Shouwei, LI Shilei, LI Yingying, et al. Classification of artificial meat and suggestions on normalization of nomenclature for related terms[J]. Food Science, 2020, 41(11): 310-316. (in Chinese with English abstract) DOI:10.7506/spkx1002-6630-20200331-443 http://www.spkx.net.cn.
[5] https://www.fda.gov/news-events/press-announcements/fda-spurs-innovation-human-food-animal-cell-culture-technology.
[7] Notably, on September 3, 2021, FSIS published an advanced notice of public rulemaking (ANPR) to solicit comments and information regarding the labeling of cell-cultured meat and poultry products. Please see https://www.dailyintakeblog.com/2021/09/anpr-on-labeling-cell-cultured-products-published/.