Labelling and traceability of Genetically Engineered Foods

Labelling commercialized products dates back to the times of the Roman Empire. Over the centuries the product label has become a means of product identification, establishing Intellectual Property Rights, brand presence and market position, by the manufacturer. For the authorities labeling is a tool of protecting consumer interests and of tracing the antecedents of the product, to check any regulatory violations by the manufacturer and the marketing outlets. Over the years, labeling, a simple means of providing information to the consumer to make educated choices, became a very complex and contentious issue, in almost every sphere.

Plants and animals, that are source of food and feed, are genetically engineered (GE) to enhance flavor, quality and yield, to increase nutrients, and to improve resistance to pests and diseases. GE plants and animals have turned out to be one of the most controversial issues today, as the opponents of technology have raised questions of safety and the ethics behind such technology.

Labelling and traceability regulations for non-GE food products have existed for decades in almost every country. All countries that are involved in the development, cultivation and marketing of GE crops, have now a regulatory frame work for consumer safety of food derived from GE plants and animals. Procedures and regulations of testing GE foods for different safety parameters and mandatory labeling practices, to facilitate traceability of a food product to its genetic and production source, have unfortunately become international controversies. However, a uniform international policy is essential to smoothen international trade in such products.

The Food and Drug Authority of the US is satisfied with the establishment of Substantial Equivalence between a GE product and its isogenic, and does not have mandatory labeling regulations. However, labels and symbols for GE foods, are used voluntarily in the US, to indicate if a product is ‘GM free’. The tag ‘Identity Preserved’ is used to refer to the record of a product's specific traits through the entire process from the crop to the product.

The European Union has detailed regulatory procedures, to ensure the safety of GE food products to the consumers and labeling to provide product information to both the user and the authorities. The EU’s regulations are so stringent that they sparked protests from the product developers and raised doubts whether any GE product will at all qualify to be considered safe under these regulations.

Codex Alimentarius Commission (CAC) is the international organization established in 1963, jointly by the FAO and WHO, under the Food Standards Programme.   CAC is an inter-governmental body whose membership is open to all Member Nations and Associate Members of FAO/WHO, and currently comprises of over 165 countries. International non-governmental organizations, such as consumer, academic or industry bodies, may attend Codex meetings as observers.
The objectives of CAC are, protecting health of the consumers, ensuring fair trade practices in the food trade, and promoting co-ordination of all food standards work undertaken by international governmental and non-governmental organizations.   The Codex has framed detailed policy guidelines to establish safety of products of modern biotechnology and foods derived through GE plants and micro-organisms.   However, a number of gray and conflicting areas dog consensus.
The Cartagena Protocol is not relevant to food safety and labeling issues as it is primarily concerned with international trans-boundary movement of GE plants and animals and neither with foods nor their labelling.
Some of the much debated questions are:
        -   What kind of label would serve the objective of consumer and regulatory needs?
        -   Should it be linguistic or symbolic or a combination of the two?
        -   What a label should include?
        -   Should it be mandatory or voluntary?
        -   What is threshold of GE content in a food product?
        -   Should refined products derived from GE plants and animals, but do not contain any
            GE component be labelled?
        -   What kind of scientific procedures be adopted in the qualitative and quantitative analysis of
            GE component in foods?

In multilingual countries, the choice of languages in providing label information is also a serious emotionally charged question. At the end of all this time consuming and expensive exercise, the question that remains is, ‘how many consumers actually read the label information and are guided by it in their choice?’.

Many countries that introduced strict labelling and import regulations for GE products have already been threatened under WTO trade agreements, for example, the EU by the US.

In India, the ‘Prevention of Food and Adulteration Act’ of 1954 was aimed to prevent the adulteration and misbranding of food. The label was required to indicate the name or description of the food, the name and business address of the manufacturer or importer, the net weight of the food, ingredients, batch/code number in Hindi or English (or regional languages), the month and year of manufacture, packing and expiry and If preservatives, coloring agents, antioxidants, or vitamins have been added to the food. Recently, a symbolic label was introduced to distinguish entirely vegetarian foods from foods that have a non-vegetarian component.

India should now consider framing internationally compatible regulations on labelling and traceability of GE food products. The issues have to be addressed case-by-case basis.

The only GE crop now grown in India is Bt cotton and it has no serious implications for use as food. Though there are several GE crops in development, both in the public and private sectors, no GE food product is likely to emerge in India in this decade. Framing rules for labelling and traceability of GE foods at this point of time would be without a focus. However, it would immensely benefit, if a working group reviews the provisions of international instruments and the regulations adopted in different countries and draft a basic policy, with a provision to suitably modify as and when a GE product would reach the market. The product developers and stakeholders should be involved in the process in order to arrive at consensus. A move in this direction has recently been made by the Indian Council of Medical Research, Government of India, New Delhi. This process will be a little easier if the working group has authentic information on the probable datelines of release of different GE products, both in the public and private sectors.

Summary of talk delivered at the International Conference on ‘Foods derived from genetically modified crops: issues for consumers, regulators and scientists’ at New Delhi, September 26-27, 2005.