“Bioengineered” or “GMO?” The Impact of Mandatory Labeling
By Navi Hansra and Stephen Lamb
In 2020, walking down the aisles of your local Safeway, Kroger, or insert-name-of-American-grocery-store-here is probably going to look a bit different. You’ll soon be surrounded by packages of food containing little descriptions, images, or QR codes referencing something like this:
Bioengineered. The word triggers mental pictures of scientists in lab coats, perfect looking veggies, and - if you’ve been following the glamorous world of US Department of Agriculture news - a new law.
That law is the National Bioengineered Food Disclosure Standard (NBFDS). Aside from being a mouthful, the NBFDS is a proposed rule that - when made final - will likely “require food manufacturers and other entities that label foods for retail sale to disclose information about BE food and BE food ingredient content.” Basically, the foods in your grocery store will soon have labels (or some indication) stating that it is bioengineered or has bioengineered components.
But what does “bioengineered” technically mean? If you ask many Americans, they will come up blank or begin to reference “GMO” and “genetic engineering.” But – given the many different contexts in which these phrases are slung around – do many of us even know what “genetic modification” and “genetic engineering” really mean?
Regular people and academics alike are bombarded by conflicting and overlapping use of these terms, so it’s no wonder that we find it difficult, if not impossible, to understand them. This lack of clarity may have been tolerated in the past, but better understanding is going to become key now that the NBFDS is here.
So, to begin clearing up the confusion, let’s attempt to define what words like genetic engineering, genetic modification, and bioengineering actually mean.
Genetic engineering (GE)
Of the three terms we are attempting to define, genetic engineering (GE) is by far the most straightforward. There is near total consensus that genetic engineering involves the use of modern biotechnology techniques (one example being recombinant DNA technology) to specifically and deliberately rewrite the genetic code of an organism. Take Merriam Webster’s definition of genetic engineering: “the collection of techniques utilized in biotechnology to cut up and join genetic material (especially DNA) from one or more species and to insert the rearranged product into an organism in order to change an organism’s characteristic(s).”
A example of GE is Golden Rice, a set of unique rice varieties built to address Vitamin A deficiency in the developing world. The researchers who built Golden Rice did so by taking DNA from other organisms – in this case daffodils, bacteria, and corn – and inserting that DNA into the genetic code of rice so that the rice would produce high levels of the Vitamin A precursor beta carotene.
Multiple aspects of this process – the incorporation of foreign DNA, the deliberate and specific alteration of DNA at the most granular base-pair level, and the achievement of a result in so short a timeframe (impossible to do using traditional plant breeding methods) – make this as a very clear example of genetic engineering.
Genetic modification (GM)
But what about genetic modification (GM) and its partner term genetically modified organism (GMO)? This is where we start to see confusion. That confusion splits along technical/non-technical lines.
According to the Cambridge Dictionary, genetic modification (GM) is the process of altering the makeup of an organism’s genes in order to make the organism stronger, healthier, or more functional for human beings. Importantly, by this definition, GM is not limited to the techniques associated with modern-day biotechnology; any organism that has been intentionally genetically manipulated by humans qualifies as GM, even if that modification took centuries of “traditional” breeding techniques. GM includes GE, but it also includes old-school methods of biological manipulation.
Keith Edmisten, Professor of Crop Science at North Carolina State University, makes the distinction clear when he states that genetic modification encompasses a large range of methods, including old-school techniques like selection and hybridization. These techniques have been used by the common man over thousands of years to cause changes in crops before the field of modern biotechnology was established – changes like giving carrots their orange color, enlarging tomatoes from their original marble size, and altering corn to eliminate its original hard coating and low digestibility.
The definition of GM and GMOs as inclusive of old-school breeding methods is consistent across the technical community. It has been adopted by organizations run by technical people, including, most importantly in the United States, the US Department of Agriculture (USDA).
But the same definition has not been adopted by regular, non-technical people. One reason for the difference is the fact that advocacy groups like the Non-GMO Project use an alternative definition, one that makes a distinction between old-school and new-school methods of genetic manipulation.
In contrast to the technical community, the Non-GMO Project defines a GMO as “a plant, animal, microorganism or other organism whose genetic makeup has been modified in a laboratory using genetic engineering or transgenic technology.” Put another way, GM = GE.
And here is the upshot of all this confusion. If the technical community defines GM one way, but regular people define GM another way, what happens? Lawmakers tasked with using these terms need to either pick a side or do something completely different. Up until this year we weren’t sure which way they would turn, but following the release of the proposed mandatory labeling rules, it is now clear that they chose the latter course.
Bioengineering (BE) used to be a relatively broad term. Before 2016 and the NBFDS, BE was commonly defined by dictionaries and academics as the transfer of principles/techniques from engineering to biology in order to create biological products. The term loosely referenced a broad set of technologies, including things like genetic engineering, biochemical engineering, and bioprocess engineering. It was an industry term with hardly any adoption by regular people.
But the BE labels soon to be on our food don’t use this old definition; they use a new legal definition – one that can be directly traced to the definitional debate about GMOs.
This legal definition:
The term "bioengineering". . . refers to a food (A) that contains genetic material that has been modified through in vitro recombinant deoxyribonucleic acid (DNA) techniques; and (B) for which the modification could not otherwise be obtained through conventional breeding or found in nature. (7 U.S.C. 1639(1))
The rulemakers who crafted this new BE definition were clearly inspired to make sure that BE encompassed only those technical methods associated with genetic engineering while adhering to the regular person’s understanding of a GMO. At the highest level, the term BE accomplishes this goal.
But only at the highest level.
In reality, the definition of BE being adopted under the NBFDS simply adds another layer of confusion to an already confusing space. The new rules are riddled with exclusions, contingencies, and exceptions. Just one simple example is the provision that multi-ingredient products for which the principal ingredient is egg, meat, or poultry are excluded from BE labeling entirely, even if other ingredients in that product are fully BE (NBFDS II.B).
What does this mean for the regular person? It means that the lack of a BE label is no guarantee that something was built without genetic engineering. While scientists criticize the perceived stigma that comes with increased GMO labeling, all can agree that a more complicated web of definitions only serves to confuse the dialogue, not help it.
Putting it all together…
If that was all incredibly confusing, don’t worry. You’re not alone. It’s difficult to meaningfully differentiate these terms. The distinctions are nuanced.
But as BE-labeling takes effect and as genetically engineered becomes more prevalent, those distinctions are going to matter. Understanding them, and going through the (admittedly tedious) work required to do so, will be important.
Our take on all this
While the NBFDS ironically may serve to muddy waters it was meant clear up, it will be fascinating to see the downstream implications of mandatory labeling.
As mentioned before, there is a fear amongst some individuals that labeling will serve to stigmatize science. As an obviously pro-GE company, we at ZBiotics are definitely opposed to unnecessary fear-mongering of genetic engineering. In this light, labeling has historically been presented as an opportunity for food brands to fan the flames of misinformation in order to sell “clean label” products at a premium price.
However, the ultimate goal of NBFDS is transparency, right? In service of this specific goal, there may be some interesting consequences of mandatory labeling that actually favor companies taking a responsible approach to genetic engineering.
For instance, in the wake of NBFDS, as these labels start hitting the shelves in earnest, we believe this post will be one of many that are written to clarify what these terms actually mean. People will start understanding these words in earnest, resulting in buying decisions that are more informed than the surface-level connotations of a label.
In addition, a fascinating study was published regarding consumer perceptions following the imposition of similar NBFDS-style labeling requirements in the state of Vermont. In that study, researchers found that consumers became more accepting of GE foods – not less – in the wake of mandatory labeling. Furthermore, official definitions on the table could provide a crystallization point for real informed discussion, as opposed to the dialogue today, in which technical and consumer understandings of these terms remain disconnected.
Ultimately, we believe that the most important action we can take is to provide accurate information about what these terms mean. Transparency is key, and if Vermont is any indication, positive labeling of GE foods (e.g. “contains a bioengineered food product”) alongside the negative (e.g. “GMO-free”) may serve to normalize rather than stigmatize.