01.05.16
The Natural Products Association (NPA) submitted comments regarding the U.S. Food and Drug Administration’s (FDA) Draft Guidance for Industry on Voluntary Labeling Indicating Whether Foods Have or Have Not Been Derived From Genetically Engineered (GE) Plants. The FDA’s position on the labeling of genetically engineered foods is unchanged from its initial 1992 policy statement. While NPA applauded FDA for speaking out on the subject of genetically modified organisms (GMO) and GE ingredients for the first time in almost a quarter of a century, NPA described how the draft guidance falls short in defining terms and providing for enforcement over voluntary labeling.
NPA requested additional information on how FDA would enforce voluntary GMO labeling and whether it has considered a permissible threshold level for products to contain GE ingredients before they would be considered false and misleading. NPA also expressed concerns that absent an enforcement strategy, foreign imports could hold a competitive advantage through false and misleading labels and advertising over U.S. domestic foods fully compliant with non-GE labeling advice from FDA. NPA stated that clarifying the definition of non-GE products by providing a threshold and an enforcement strategy would be better suited in a public rulemaking.
“The Natural Products Association has long supported and encouraged the voluntary labeling of non-GMO foods,” said Dan Fabricant, PhD, executive director and CEO of NPA. “Consumers have a right to know what is in their food, and a national standard is the best, most cost-effective, and least-confusing way to deliver on this commitment to ensure the continued growth and sustainability of the natural products industry.”
FDA also pointed out that natural and non-GE are intertwined by state laws. NPA used this opportunity to call on Congress to pass federal legislation that would preempt state labeling laws over GE and “natural.”
“Federal legislation for GE and ‘natural’ will have all companies under one overarching federal law instead of multiple state laws,” said Dr. Fabricant. “NPA believes federal legislation would resolve consumer confusion and lawsuits surrounding the labeling of ‘natural’ and non-GE food products, thereby creating consistent and equitable labeling requirements for manufacturers and retailers.”
While the guidance is voluntary, NPA also requested FDA to provide an economic impact analysis on companies that voluntarily choose to label their products. “Just because the proposed guidance is voluntary, it doesn’t mean there’s not an economic impact of doing so,” said Dr. Fabricant. “It’s important for us to fully understand how this could impact our members’ cost of doing business, and ultimately if any of those costs would be passed onto consumers.”
Comments can be found HERE.
NPA requested additional information on how FDA would enforce voluntary GMO labeling and whether it has considered a permissible threshold level for products to contain GE ingredients before they would be considered false and misleading. NPA also expressed concerns that absent an enforcement strategy, foreign imports could hold a competitive advantage through false and misleading labels and advertising over U.S. domestic foods fully compliant with non-GE labeling advice from FDA. NPA stated that clarifying the definition of non-GE products by providing a threshold and an enforcement strategy would be better suited in a public rulemaking.
“The Natural Products Association has long supported and encouraged the voluntary labeling of non-GMO foods,” said Dan Fabricant, PhD, executive director and CEO of NPA. “Consumers have a right to know what is in their food, and a national standard is the best, most cost-effective, and least-confusing way to deliver on this commitment to ensure the continued growth and sustainability of the natural products industry.”
FDA also pointed out that natural and non-GE are intertwined by state laws. NPA used this opportunity to call on Congress to pass federal legislation that would preempt state labeling laws over GE and “natural.”
“Federal legislation for GE and ‘natural’ will have all companies under one overarching federal law instead of multiple state laws,” said Dr. Fabricant. “NPA believes federal legislation would resolve consumer confusion and lawsuits surrounding the labeling of ‘natural’ and non-GE food products, thereby creating consistent and equitable labeling requirements for manufacturers and retailers.”
While the guidance is voluntary, NPA also requested FDA to provide an economic impact analysis on companies that voluntarily choose to label their products. “Just because the proposed guidance is voluntary, it doesn’t mean there’s not an economic impact of doing so,” said Dr. Fabricant. “It’s important for us to fully understand how this could impact our members’ cost of doing business, and ultimately if any of those costs would be passed onto consumers.”
Comments can be found HERE.
