Dear Secretary Perdue,
Applegate is the nation’s leading natural and organic meat company, with a reputation built on trust and transparency. That is why the company has always supported GMO labeling.
Nine out of ten Americans consistently report they want the right to know if their food is produced with genetic engineering. Consumers in 64 other countries already have this right. In 2016, recognizing the consumer’s right to know about genetically engineered (GE) foods or foods made with genetically modified organisms (GMO), Congress passed the National Bioengineered Food Disclosure Standard (Pub. L. 114-216) to require the Secretary of Agriculture establish a mandatory, national disclosure standard for GMO foods.
As your department moves forward with implementation, we believe it is critical that the U.S. Department of Agriculture (USDA) create a meaningful disclosure standard for GMO foods that is based on Congress’ clear intent to cover all GMO foods and GMO technologies, uses terms that consumers understand like GE or GMO, is consistent with federal and international standards, has strong rules governing electronic or digital disclosures, and is inclusive of all Americans – including consumers without smartphones, rural residents and the elderly.
The current proposal put forth by the department and open for public comment is rife with loopholes, is inconsistent and adds to consumer confusion.
Applegate communicates regularly with consumers on this topic, and I fear that using the term "bioengineered" will further exacerbate consumer confusion, not lessen it. Since 2015, the company has been voluntarily disclosing to consumers that products are made with Non-GMO ingredients, and we are pursuing third-party verification of GMO avoidance.
In addition, we believe the proposed symbols released by the department should more clearly and neutrally communicate that the product contains genetically engineered or contains ingredients derived from genetic engineering. The proposed symbols do not clearly indicate the presence of GMOs or that food is genetically engineered. USDA proposed three options of symbols to be used, each of which contains the letters “BE” for bioengineered or statements using the terms “bioengineered food.”
Two of the three symbols incorporate smiling faces and one appears to be a winking face – far from the neutral symbology that Congress intended. These symbols are misleading and could convey to consumers that GMO foods are safer than non-GMO foods, which is expressly prohibited by the statute.1
We look forward to seeing revisions in the department’s GMO labeling proposal that will ensure a more transparent food system.
John Ghingo, President
1 Pub. L. 114-216 specifically states: “For the purpose of regulations promulgated and food disclosures made pursuant to paragraph (2), a bioengineered food that has successfully completed the pre-market Federal regulatory review process shall not be treated as safer than, or not as safe as, a non-bioengineered counterpart of the food solely because the food is bioengineered or produced or developed with the use of bioengineering.”