When it comes to labeling dietary supplements or ingredients, does the term “mushroom” only apply to the fruiting body of a fungus, or does it refer to the entire organism, mycelial structure, spores, and all?  
 
The Natural Products Association is the latest of many to weigh in on how nomenclature on supplement labels should be enforced in a petition submitted to the FDA.
 
Presently, the U.S. Food and Drug Administration (FDA)’s labeling policy requires that labels distinguish between mushrooms and mycelium, however, the ambiguity of the language has become a sticking point in how ingredients should be marketed and dietary supplements are labeled. 
 
“Any food in which mushroom mycelium is used should be labeled to state that fact. Labeling should not suggest or imply that the food contains mushrooms,” the guidance reads. “For example, a soup in which mushroom mycelium is an ingredient should not be labeled or sold as "mushroom soup" since that name by long consumer understanding and usage is preempted by soup containing real mushrooms.”
 
With the boom in mushroom-containing supplements experts in the mycological field are calling for more enforcement against products which are labeled strictly as mushrooms in dietary supplements but actually contain mycelium, and even the substrate on which the fungus was grown.
 
Specifically, some players in the industry take umbrage at “mushroom mycelium,” or “mushroom spore,” and instead feel that “mycelium” and “spore” are more accurate terms, while widespread consumer understanding is that “mushroom” specifically denotes the fruiting body of the fungus.
 
NPA believes that it should be required to specify which part of the organism is included in an ingredient, but that “mushroom” should apply to the entire organism.
 
“Mushroom dietary supplements are extremely innovative and as the business grows, require a standard nomenclature,” said Daniel Fabricant, PhD, president and CEO of NPA. “By requesting that the FDA incorporate AHPA [the American Herbal Products Association]’s labeling guidelines or exercise enforcement discretion until the agency publishes its own standard of identity regulation, we aim to protect domestic farmers who continue to be economically harmed by foreign entities damaging the credibility of this evolving market.”

To emphasize the volatility of this burgeoning marketplace, Fabricant pointed to a report in The Packer which found that certain companies were importing shiitake from China due to lower costs, but what they claimed to be importing was in fact mycelium and not spawn and is not undergoing the correct certification process. He also pointed to a high-profile case in which mushroom brand Fungi Perfecti discovered counterfeit products imitating its brand.  

NPA’s Request

The Natural Products Association is the latest authoritative voice within the dietary supplements industry to weigh in with a petition submitted to the FDA. They concur with AHPA and others that as long as other parts are specified, the use of the term “mushroom” should be generally permissible.
 
Specifically, NPA requested that the agency either:
 
-       Amend labeling policy to incorporate the recommendations of the American Herbal Product Association’s labeling guidance for mushrooms, or;
-       Commit to exercising enforcement discretion until the agency provides guidance or publishes a regulation concerning a standard of identity for dietary supplements or ingredients from fungal ingredients, including mushrooms, mycelia, and fruiting bodies.
 
AHPA’s guidance for labeling fungal products allows for the term “mushroom” to be used in products containing spores or mycelium, so long as the description also “identifies the parts.” AHPA calls for allowing brands to use mushroom in a marketer’s company name, and ahead of specified parts, i.e. “mushroom mycelium.” The fungal parts present should always be disclosed in order of predominance by weight in nutrition labeling, AHPA reports.

Nammex’s Petition

Mushroom ingredient supplier Nammex and its founder, Jeff Chilton, were the initial actors in the present debate to submit a Citizen Petition on mushroom nomenclature. Chilton and company, for years, have stood against the use of “mushroom mycelium” over mycelium, and consider there be a mislabeling problem.
 
“We hope to raise awareness of the mislabeling problem that exists today in the US, and obtain FDA regulatory guidance on the labeling of mushrooms and other fungal ingredients to ensure truth-in-labeling,” Chilton said at the time of submitting the petition. “When consumers buy a product labeled as ‘mushroom,’ they should feel confident that they are getting a genuine mushroom product.”
 
Nammex requested that FDA correct what it considers to be ambiguity about which part of a fungal organism an ingredient is derived from, and to issue a glossary of mycological terms to the industry in order to promote the distinction. Products which are labeled as “mushroom” when they contain other fungal parts should be treated as mislabeled, according to the company’s petition.

Other Mushroom Experts

Fungi Perfecti, M2 Ingredients, Gourmet Mushrooms, and Monterey Mushrooms also jointly wrote an open letter unified in response to Nammex’s petition.
 
Contrary to Nammex, Fungi Perfecti stated that “the word ‘mushroom’ describes the organism as a whole, whereas terms like ‘mycelium’ and ‘fruiting body’ refer to distinct parts of the mushroom organism. This is perfectly parallel to saying ‘plant roots,’ ‘plant seeds/spores,’ and ‘plant flowers.’ Both sets of terminologies describe parts of the organism.”
 
Interestingly, in The Mushroom Cultivator, a book co-authored by both Chilton and Fungi Perfecti founder Paul Stamets, a Modern Life Cycle Diagram depicts stages of the mushroom life cycle as such. In the open letter, Stamets described Nammex’s Citizen Petition as a source of public confusion.