While the USDA and the FDA have outlined a regulatory framework for foods containing cultured meat and seafood cells (which has yet to be finalized), they have not yet nailed down the nomenclature, which is challenging, as it has to both convey what the products are, and differentiate them from existing products, without disparaging them.
Over the years, a variety of terms from ‘cell-based’ and ‘cell-cultured’ to ‘cultivated’ or ‘slaughter-free’ have been bandied around. ‘Clean meat/seafood’ is still used by some commentators although it carries the tacit implication that the regular stuff is dirty, so has fallen out of favor.
Other terms such as ‘fake meat/seafood’ and ‘synthetic/artificial/faux meat/seafood’ are more typically deployed by opponents of the technology, while many media outlets still use the less-than-consumer-friendly moniker ‘lab-grown.'
So what does the consumer research show?
There have been several consumer studies testing nomenclature for this new category. However, few have rigorously examined whether – without help or additional information - consumers reading said terms on a food label can distinguish them from conventional products already on the market, a key requirement for coming up with a 'common or usual name.'
'Cultivated’ – a term that resonated the most with consumers in research conducted by Mattson with the Good Food Institute in 2019 – performed particularly poorly in this respect, according to an online study* of 3,186 Americans conducted by Dr Bill Hallman at Rutgers University that was published in the peer-reviewed Journal of Food Science last year:
“More than half [of consumers surveyed] assumed by 'cultivated,' it meant farm-raised.”
In fact, said Dr Hallman, “'Cultured,' 'Produced Using Cellular Aquaculture,' and 'Cultivated' fail to differentiate these products from conventional seafood.”
In contrast, he added: “’Cell-Based’ and ‘Cell-Cultured’ both do a good job of signaling that the product is different from both ‘Wild Caught’ and ‘Farm Raised.’”
In the second phase of his research (under peer-review), which tested the names 'cell-based seafood' and 'cell-cultured seafood' with 1,200 US consumers, Dr Hallman found that both terms "differentiated the product from conventionally sourced products and effectively communicated the food is made from fish cells."
‘Factual, neutral, and descriptive …’
While both terms seem to fit the bill, 'cell-cultured' ultimately worked best for both seafood and meat/poultry, said a super-majority of the Alliance for Meat, Poultry and Seafood Innovation and The National Fisheries Institute in a comment submitted to the FDA this week (responding to the agency's recent request for information on cell-cultured seafood labeling).
“In order to clearly differentiate from conventionally produced wild or farmed seafood products, an appropriate qualifier [ie. ‘cell-cultured’] should be used to denote seafood products that are produced using the method of cell cultured technology. The qualifier should be science-based, accurate, and informed by peer-reviewed, published consumer studies."
Such products should also be subject to allergen labeling, “to put those with seafood allergies on notice that the same risks apply as with conventional seafood,” they said.
Memphis Meats: ‘It would simply be misleading for labeling to indicate that cell-cultured products are made primarily from plants’
In a separate submission filed with the FDA, AMPS Innovation member Memphis Meats said it was critical to ensure “that consumers understand that they are purchasing a real meat, poultry or seafood product and not another product like a plant-based alternative.
“It would simply be misleading for labeling to indicate that cell-cultured products are made primarily from plants.”
Memphis Meats’ own consumer research, conducted in partnership with marketing firm NorthStar, further indicated that "use of 'cell-cultured' also conveyed differentiation with plant-based proteins," said the company.
Should material differences in nutritional, organoleptic, or functional characteristics warrant additional labeling?
The FDA has long held the position that it “cannot require labeling based solely on differences in the production process if the resulting products are not materially different,” added Memphis Meats, noting that USDA has in turn, “only required disclosures for products produced through novel processes where there is a food safety risk or potential for consumers to be misled.”
Whether differences in nutritional, organoleptic, or functional characteristics are material enough to warrant additional labeling “will require careful evaluation and an iterative, data-driven dialogue with industry,” it added.
The fact that the National Fisheries Institute and the North American Meat Institute have found common ground with cell-cultured meat startups on labeling suggests the broader industry is approaching a consensus, although there will always be some groups with different perspectives, said David Kay, director of communications at Memphis Meats, which counts some big meat players (Cargill, Tyson) among its investors.
"I do think this is a big moment for the industry... we're starting to see a coalition building."
Eat Just: 'Cultured' or 'cultivated' continues to be our preference'
Not every AMPS Innovation member is on exactly the same page, however, with Eat Just telling FoodNavigator-USA that consumers it has surveyed can be put off by anything with the word 'cell' in it: "In thinking about nomenclature, Eat Just has been guided by accuracy first and palatability second, which is why 'cultured' or 'cultivated' continues to be our preference."
"As the only company in the world currently allowed to sell this new kind of meat, we are learning in real time about purchase intent from hundreds of guests who have enjoyed our chicken at a restaurant. That feedback, in addition to a new survey of thousands of consumers conducted in partnership with a leading management consulting firm, gives us confidence that we're on the right track."
Good Food Institute: 'Any single term chosen by FDA today runs the risk of becoming quickly outdated'
The Good Food Institute, a nonprofit which promotes a range of alternative meat, egg and dairy technologies, said there are risks associated with nailing down nomenclature before a new industry has launched, suggesting that, "the most constructive approach at this point would be for the agency to give guidance on permissible labeling approaches.
"In doing so, FDA should also consider that at this stage of developing consumer understanding, descriptive phrases (e.g. 'grown from cells') may convey the nature of the production process more clearly to consumers than any single term, and new terminology may yet be adopted in common usage."
It added: "Any single term chosen by FDA today runs the risk of becoming quickly outdated if consumers adopt different terminology for referring to cultivated products. At this point producers and FDA lack direct, demonstrated experience with the language that will be clearest to consumers. A restrictive approach, moreover, would hamper the free-speech interests of producers who seek to communicate with consumers on their level (which is likely to change over time)."
More stakeholder comments...
Stakeholder comments are still coming in (read them all HERE) but here is a selection:
- CSPI: Consumers expect certain nutritional components in a seafood product, such as omega three fatty acids from some fish species. If the cell-cultured product has a significantly greater or lesser amount of a nutrient compared to its traditional counterpart, FDA should ensure those differences are identified on the label. FDA and USDA should use identical terms for the different animal products they regulate. It would be needlessly confusing to consumers if meat and poultry products used one term for cell-cultured products (e.g., cell-cultured) while seafood products used a different term (e.g., cell-based).
- New Age Meats: We are a data driven company, and the data show that ‘cell-cultured’ is the best term that allows consumers, regulators, and producers to come together to make meat a better way.
- BlueNalu: We applaud the National Fisheries Institute and AMPS Innovation for uniting behind the term ‘cell-cultured’ and are delighted that a super-majority of AMPS member companies have agreed to this term. Now is the time for disparaging and misleading terms such as ‘clean’ and ‘lab-grown’ to be laid to rest.
- The Vegetarian Resource Group: We believe that the use of a descriptor such as ‘engineered using cultured catfish cells’ is more informative than assigning a product a new name… We urge the FDA to forbid labeling products containing cultured seafood cells as vegetarian or vegan.
- Anonymous: Instead of using cell-based seafood or cell-cultured seafood labeling terminology how about using ‘cell-built’ seafood labeling instead?
- Berzin Bhandara: The product should be fairly labeled ‘cultivated fish’ as the composition is the same as fish from the ocean, but the fish has come to the user through the cultivation process.
*The study was funded by cell-based seafood startup BlueNalu (which had no control over the methodology or the final text).