Tell USDA that lab-raised meat cells need to be clearly labeled

Published November 1, 2011

The USDA has announced plans to adopt rules about the labeling of lab-raised cells that originally came from animals.

The agency’s description is that these are “meat and poultry products comprised of or containing cultured cells derived from animals.” The process starts with taking a sample of cells from an animal, screening them, and storing the cells for future use. When the company wants to make so-called “meat,” the cells are taken out of storage, provided with some sort of liquid nutrients and “other factors to support growth and cellular multiplication.” As they multiply, they continue to be fed the artificial liquid nutrients as well as more growth factors and provided surfaces to attach to, so that they create something that looks and feels like meat.

The language of the USDA’s announcement includes signals that the agency isn’t likely to completely prevent these lab foods from being labeled “beef” or “meat” – but it is looking for some labeling terms to distinguish the lab products from “slaughtered meat products.”

This is just the first stage of a multi-stage rulemaking process. After considering this round of comments, USDA will publish a proposed rule and there will be a second opportunity for comments – but we are more likely to impact the agency’s thinking at this stage, rather than after they have written their proposal.




Submit your comment online at

Deadline: 11:59 pm Eastern, Tuesday, November 2

Below is a sample comment you can use if you are short on time and/or having trouble thinking what to write. If you can, though, take a moment to look at the questions that follow this sample – these are some of the key questions that USDA is seeking comments on, and you will have an even greater impact by addressing one or more of those in your own words. Even picking just one question and focusing your comment on that can be very effective!

Note that the federal register has a 5,000-character limit (about 1½ pages) if you type your comment into the box. If you want to do a longer comment, write it as a word document and upload as an attachment.


Cells grown in a petri dish on artificial nutrient solutions are not meat. They are legitimate food items that businesses can manufacture and that consumers can choose to buy. But labels that imply in any way that these products are equivalent to meat from livestock are false and misleading.

(1): Consumers should be clearly informed that a product was derived from cell cultures grown under artificial conditions rather than from live animals fed whole foods. Numerous scientific studies show that a live animals’ diet significantly changes the nutrient profile of its meat. Given that, it is certain that raising isolated cells on synthetic nutrients and added chemicals “alters the biological, chemical, nutritional, or organoleptic properties of meat or poultry to the extent that the resulting product no longer aligns with consumers’ expectations.” These lab-raised foods are fundamentally different from what normal people consider “meat.”

(2) In describing these products, the agency should not use the word “cultured.” In the context of food, the word “cultured” has been used to describe fermented foods, which takes a naturally grown or raised agricultural product (such as a vegetable or dairy) and uses a low-tech process to increase its nutritional value, flavor profile, and storability. This is both a completely different process and a completely different result from lab-based animal cell products. Using the term “cultured meat” would mislead many consumers who may believe that this is analogous to things such as “cultured dairy products” (e.g. sour cream) or “cultured vegetables” (e.g. fermented carrots).

Other terms would be clearer, such as “lab raised” or “cell cultivated.”

As a consumer, I urge the agency to either prevent these foods from being labeled as “meat” at all or, at a minimum, to require clear terminology that provides consumers with unambiguous information as to the source of the product.




Below are some of the key questions USDA is seeking comments on. We’ve kept the original numbering, so you can reference which one(s) to which you’re responding. You can also read all the USDA’s notice with all the questions here, or simply write your own comment without reference to the specific questions.

1. Should the product name of a meat or poultry product comprised of or containing cultured animal cells differentiate the product from slaughtered meat or poultry by informing consumers the product was made using animal cell culture technology? If yes, what criteria should the agency consider or use to differentiate the products? If no, why not?

2. What term(s), if any, should be in the product name of a food comprised of or containing cultured animal cells to convey the nature or source of the food to consumers? (e.g., “cell cultured” or “cell cultivated.”)

a. How do these terms inform consumers of the nature or source of the product?

b. What are the benefits or costs to industry and consumers associated with these terms?

c. If meat or poultry products comprised of or containing cultured animal cells were to be labeled with the term “culture” or “cultured” in their product names or standards of identity (e.g., “cell culture[d]”), would labeling differentiation be necessary to distinguish these products from other types of foods where the term “culture” or “cultured” is used (such as “cultured celery powder”)?

4. What term(s), if used in the product name of a food comprised of or containing cultured animal cells, would be potentially false or misleading to consumers? For each term, please provide your reasoning.

6. Should names for slaughtered meat and poultry products established by common usage (e.g., Pork Loin), statute, or regulation be included in the names or standards of identity of such products derived from cultured animal cells?

a. If so, is additional qualifying language necessary? What qualifying terms or phrases would be appropriate?

b. Do these names, with or without qualifying language, clearly distinguish foods comprised of or containing cultured animal cells from slaughtered products?

9. What nutritional, organoleptic (e.g., appearance, odor, taste), biological, chemical, or other characteristics, material to consumers’ purchasing and consumption decisions, vary between slaughtered meat or poultry products and those comprised of or containing cultured animal cells?

12. Should FSIS-regulated broths, bases, and reaction flavors produced from cultured animal cells be required to declare the source material in the product name, ingredient sub-listing, or elsewhere on the label?

14. What label claims are likely to appear on FSIS-regulated products comprised of or containing cultured animal cells? Should FSIS develop new regulations or guidance on such claims to ensure they are neither false nor misleading?





You can read the USDA’s notice, which includes some of the history of the discussions around this issue as well as the full list of questions.