December 2, 2021
U.S. Department of Agriculture
Food Safety and Inspection Service
1400 Independence Avenue SW
Washington, DC 20250-3700
RE: Docket ID Number FSIS-2020-0036; Labeling of Meat or Poultry Products Comprised of or Containing Cultured Animal Cells
To Whom It May Concern:
On behalf of Pennsylvania Farm Bureau (PFB), the state’s largest general farm organization, I am writing to submit comments related to Docket ID Number FSIS-2020-0036; Labeling of Meat or Poultry Products Comprised of or Containing Cultured Animal Cells. We ask the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) to consider Farm Bureau’s perspective on the labeling of meat or poultry products comprised of or containing cultured animal cells.
Pennsylvania Farm Bureau supports the comments submitted by the American Farm Bureau Federation (AFBF) and asks that this support be noted as part of the comment record. AFBF’s comment letter specifically provides answers to all questions posed by FSIS regarding regulation of “cell-cultured meats” where Farm Bureau has applicable policy. In addition to our statement of support regarding AFBF’s comment letter, I’ve highlighted several key points of Farm Bureau policy below which can be applied to several of the questions posed by FSIS in the ANPR:
- We support prohibiting the use of commonly known and industry recognized “meat” terms in the labeling and advertising of all lab-grown and plant-based alternatives.
- We support that if any lab-grown protein product is comingled with traditionally produced meat products, this fact and at what percentage shall be clearly disclosed to the consumer on the product label.
- We oppose the use of any nomenclature used to refer to this product in the marketplace, and on the labeling of this product, other than cell-based food product derived from meat and poultry.
We oppose the use of commonly used nomenclature or specific “meat” terms such as beef, chicken, pork, turkey, lamb, veal and fish or specific cuts of meat such as roast, steak, ground, breast, chop, filet, etc. on a lab-grown product label.
USDA-FSIS oversight of the labeling of meat or poultry products containing cell-cultured protein is critical. Cell-cultured proteins should be subject to the same rigorous inspection procedures as traditional protein such as meat and poultry. Additionally, ensuring consumer-friendly, science-based, and truthful labeling for any food product intended for human consumption is of vital importance, and USDA-FSIS is key to making that happen.
We look forward to a further discussion on this issue, and encourage USDA to continue to include stakeholders in this process moving forward. Thank you for your consideration.
Rick Ebert, PFB President