Labels on all packaged food must provide consumers with truthful, clear and non-misleading information. For this reason, we support the current Food and Drug Administration (FDA) policy, which requires, among other things, that food be labeled if it poses a safety concern, as is the case for all foods. Safety issues can arise where food produced through biotechnology or other means is significantly different from its traditional counterpart.

The FDA currently requires biotechnology-enhanced foods to be labeled if, for example, the food is significantly changed from its traditional form, such as when its nutritional content has been significantly altered or when it could cause an allergic reaction in some people, or other safety problems. Where none of these or other significant differences exist, generally speaking biotechnology-enhanced food is not materially different from other foods and does not need to be labeled differently from other foods.

Every food product on a grocery store shelf must meet the law’s requirements for safety and labeling. Federal regulation has never required that food labels describe the plant development process by which food is produced. Such processes are not material information that must be labeled. Because the law is aimed at ensuring safe food and informative labels, biotechnology products should not be singled out for special regulatory treatment unless there is a significant difference in composition or, otherwise, a safety problem exists, or where material information is missing.

Current Law and Policy

The FDA established a policy in 1992 that all foods derived through biotechnology be regulated in the same fashion as those developed through traditional methods. This means:

	Products of food biotechnology are subject to the same FDA labeling and safety policies applied to all foods in the U.S. marketplace.
	Different labeling is required when, for example, biotechnology results in a significant change in the composition of a food product. Putting new proteins into a tomato for enhanced processing capabilities is an example of a substantial compositional change.
	FDA requires a label on biotechnology products, as needed, to inform consumers of any potential health or safety risk, such as if a protein poses an allergy risk, unless scientific data show that the allergen is not present. Common allergens include milk, eggs, wheat, fish, crustacia, tree nuts, and legumes (such as peanuts and soybeans). Peanuts are a common allergen. If a peanut gene is inserted into potatoes or corn – products where consumers would not expect to find peanut allergens – the resulting product would need a label to inform sensitive consumers.
	A label also is required if a food is changed so that its nutritional content no longer conforms to the normal expectations. Altering the Vitamin C content of an orange to levels significantly above or below the normal range is a good example.
	The FDA is able to evaluate the safety of biotech ingredients added to foods in the same way it evaluates any new ingredient, such as a new preservative or a new food-coloring agent.
	The FDA can stop a food product from being sold at any time if it determines that a product or ingredient is unsafe for public consumption or if it is mislabeled.
Key issues:
	Labels provide a consumer’s first impression of most packaged food products. Labels list ingredients, describe features, give instructions, explain benefits and deliver advisories and warnings. Information considered essential to health and safety is mandated by law to appear on the label.
	Labels on food identifying the presence of ingredients derived through biotechnology could unduly alarm consumers about potential safety risks. In fact, the FDA and the manufacturer must address any potential safety risks of a food product before the product enters the marketplace and, if a safety problem exists, the food will not be marketed or will be labeled to identify the safety risk.
	Labeling of biotech foods differently from their traditional counterparts would have the unintended and unfortunate consequence of misleading consumers into thinking that biotech products have different health effects. This would lead to the kind of consumer confusion that labels are designed to avoid.