Current Status of Current Status of Food Traceability Food Traceability and Labeling in and Labeling in

USA*USA*Alan McHughen, D.Phil., Alan McHughen, D.Phil., University of CaliforniaUniversity of California

Riverside, Ca USARiverside, Ca USA

alanmc@ucr.edualanmc@ucr.edu*- and some EU info from Willy *- and some EU info from Willy

DeGreefDeGreef

Grounds for EU GM food Grounds for EU GM food traceabilitytraceability

European traceability rules are European traceability rules are intended for food safety management intended for food safety management AND for consumer choice.AND for consumer choice.

This dual purpose has created an This dual purpose has created an unwieldy regulation which has proven unwieldy regulation which has proven difficult to apply and unsatisfactory for difficult to apply and unsatisfactory for some consumerssome consumers

(W. DeGreef)(W. DeGreef)

Starting pointStarting point

Farmer buys certified seed, highest Farmer buys certified seed, highest purity obtainable for commodity purity obtainable for commodity cropcrop Purity is guaranteed to 95%Purity is guaranteed to 95%

Farmer may instead use saved, Farmer may instead use saved, common or “brown bag” common common or “brown bag” common seed seed Purity level is unknown.Purity level is unknown.

Sources of impurity: Sources of impurity: FarmFarm

From Farm to PortFrom Farm to Port Seed transport and storage on farmSeed transport and storage on farm Seeding equipmentSeeding equipment Volunteers and weeds in fieldVolunteers and weeds in field Pollen and seed flow from other fieldsPollen and seed flow from other fields Harvesting equipmentHarvesting equipment Storage and Transport.Storage and Transport.

Sources of impurity: Sources of impurity: DeliveryDelivery

Admixtures of grain at local elevatorAdmixtures of grain at local elevator Throughout the grain handling systemThroughout the grain handling system Barges, rail cars, port storage, Panamax Barges, rail cars, port storage, Panamax

vesselsvessels Delivery portDelivery port

Unloading and local delivery.Unloading and local delivery.

TraceabilityTraceability

Traceability demands i.p., Traceability demands i.p., segregation and a paper trail with segregation and a paper trail with verification at every step.verification at every step.

Historically used only for high value Historically used only for high value specialty productsspecialty products Due to high costDue to high cost No need for segregation of bulk No need for segregation of bulk

commodities.commodities.

Commodity vs discrete Commodity vs discrete productsproducts

Corn seeds vs papayas or pumelosCorn seeds vs papayas or pumelos Corn seeds are bulked, treated as Corn seeds are bulked, treated as

populationpopulation Papayas are discrete, can be treated as Papayas are discrete, can be treated as

unitsunits Cost of i.p. increases with degree of Cost of i.p. increases with degree of

purity demandedpurity demanded Feasibility based on number of units, and Feasibility based on number of units, and Number of contact/branch/transfer pointsNumber of contact/branch/transfer points

Traceability of Traceability of commodity graincommodity grain

Is not feasible except at a cost greater Is not feasible except at a cost greater than the value of the commodity than the value of the commodity (affidavits, testing, etc. at each step)(affidavits, testing, etc. at each step)

Cannot achieve purity higher than best Cannot achieve purity higher than best starting point (5%) without great coststarting point (5%) without great cost

Adds nothing to public confidence in Adds nothing to public confidence in food safetyfood safety

Or in regulatory systemOr in regulatory system (30% of non-GM food imports to Korea (30% of non-GM food imports to Korea

were actually GM: KFDA)were actually GM: KFDA)

Why does USA not have Why does USA not have mandatory GM food mandatory GM food

labeling?labeling? Labeling in US is based on Labeling in US is based on productproduct, ,

not not processprocess Labels are required with changes to Labels are required with changes to

product compositionproduct composition If new allergens or toxicants are presentIf new allergens or toxicants are present If changes to nutrient contentIf changes to nutrient content Regardless of method of breeding.Regardless of method of breeding.

Practical problemsPractical problems

Labelling of foods which do not contain Labelling of foods which do not contain any GM genes or expression productsany GM genes or expression products

No labelling of animal products No labelling of animal products Tracing agricultural commodities Tracing agricultural commodities

through international tradethrough international trade Testing and identificationTesting and identification The possibility of fraudThe possibility of fraud

(DeGreef)(DeGreef)

The possibility of fraudThe possibility of fraud

The tracing and labelling requirements for The tracing and labelling requirements for products in which no GM can be detected products in which no GM can be detected is an invitation for fraud, if there is a price is an invitation for fraud, if there is a price differencedifference

The absence of large differences between The absence of large differences between GM and non-GM commodities suggests GM and non-GM commodities suggests that much food export to the EU does not that much food export to the EU does not comply with the regulationscomply with the regulations

(De Greef)(De Greef)

What are the motivations for mandatory process based

labels? Public “right to know”Public “right to know”

Informed choiceInformed choice

Possible health or environment Possible health or environment effectseffects

Distrust in Government regulators.Distrust in Government regulators.

Conceptual problems with Conceptual problems with process- based GM labelsprocess- based GM labels

GM Corn, soybean or canola oil sold to GM Corn, soybean or canola oil sold to consumers is identical to non-GM oil.consumers is identical to non-GM oil. The label is misleadingThe label is misleading Cannot be independently verified by Cannot be independently verified by

analysisanalysis Ripe for abuseRipe for abuse Leads to consumer distrust in labels in Leads to consumer distrust in labels in

generalgeneral And distrust in the regulatory system in And distrust in the regulatory system in

general!general!

Which processes get Which processes get labeled?labeled?

AgrobacteriumAgrobacterium ? ? Biolistic ?Biolistic ? Irradiation mutagenesis ?Irradiation mutagenesis ? Somaclonal variation ?Somaclonal variation ? Embryo rescue ?Embryo rescue ? Wide crossing genes from distant Wide crossing genes from distant

relatives ?relatives ? Genes from same species?Genes from same species?

What about ‘derived from’ What about ‘derived from’ products?products?

Soybean GM with soybean gene Soybean GM with soybean gene Soybean with bacterial geneSoybean with bacterial gene Tofu from Soybean with bacterial Tofu from Soybean with bacterial

genegene Oil from Soybean with bacterial Oil from Soybean with bacterial

genegene Lecithin from Soybean with bacterial Lecithin from Soybean with bacterial

genegene

Label problems: Special Label problems: Special casescases

Soybean from wild-type Soybean from wild-type segregant segregant

Fruit from branch grafted onto Fruit from branch grafted onto rDNA rootsrDNA roots

Bread from wheat with rye genesBread from wheat with rye genes

Common wheat with Rye Common wheat with Rye DNADNA

Friebe et al., Crop Science 39:1692-1696 (1999)

Economic: Who pays?Economic: Who pays?

In capitalist society, those making In capitalist society, those making marketplace demands pay to have those marketplace demands pay to have those demands fulfilled.demands fulfilled.

But with GM labels, demand is from those But with GM labels, demand is from those wishing to wishing to avoidavoid purchase; the consumer purchase; the consumer is forced to pay to fulfill demands of is forced to pay to fulfill demands of others.others.

How do we charge the ‘demanders’ to pay for GM food labels?

Mandatory process based Mandatory process based labels satisfy few and cost labels satisfy few and cost

everyoneeveryone Exceptions, tolerances and allowancesExceptions, tolerances and allowances

frustrate those philosophically opposed to frustrate those philosophically opposed to biotechbiotech

‘‘reverse-onus’ of label liability raises costs to reverse-onus’ of label liability raises costs to all, especially small farmers and poor peopleall, especially small farmers and poor people

Alternatives exist. Based on concern:Alternatives exist. Based on concern: If a health safety issue, fix regulatory credibilityIf a health safety issue, fix regulatory credibility

(real hazards are in the product, not process)(real hazards are in the product, not process)

If concern is philosophical, voluntary labels work If concern is philosophical, voluntary labels work well.well.

Solution to problemsSolution to problems

Traceability of commodity grains Traceability of commodity grains adds unnecessary burden to farmers adds unnecessary burden to farmers and unnecessary cost to consumers. and unnecessary cost to consumers. Traceability should be used only for Traceability should be used only for

high value, specialty and hazardous high value, specialty and hazardous materialsmaterials

Labels should be based on food Labels should be based on food composition, not the breeding composition, not the breeding process.process.

ConclusionConclusion

Traceability and Labeling are Traceability and Labeling are feasible only for physical feasible only for physical products, products, not the process not the process by which they were by which they were made.made.

Laws and policies requiring Laws and policies requiring traceability and labeling for process traceability and labeling for process are impracticableare impracticable

Leading to loss of public trust in Leading to loss of public trust in politicians and regulators.politicians and regulators.