New Hampshire Commissioner of Agriculture Lorraine Merrill recently testified in front of members of New Hampshire's House Environment and Agriculture Committee regarding House Bill 1674, a bill that requires the labeling of genetically engineered foods. NASDA's policy statement on biotechnology can be found here.
Thank you for the opportunity to comment on behalf of the New Hampshire Department of Agriculture, Markets & Food (DAMF) regarding House Bill (HB) 1674 An Act requiring the labeling of genetically engineered foods. Promoting agriculture in the public interest, including advocating for agricultural literacy and an understanding of where our food comes from, is a core component of the department’s mission. The department recognizes the growing interest of consumers who want a better understanding of what they are eating, however HB 1674 does not advance that understanding, and DAMF does not support the bill as introduced.
The bill proposes additions to RSA 146, which falls under the Department of Health and Human Services. One concern of the Department of Agriculture is whether the bill intends to include animal foods and feeds in its labeling requirement. (See the referenced definition of food in RSA 146:2, I) Requiring labeling of foods for animals would be burdensome and expensive for the livestock feed and pet food industries, and these costs would be passed on to farmers and consumers who purchase animal food and feed products.
Whether for humans or animals, food-labeling requirements belong at the federal, not state level. State by state patchworks of labeling laws are chaotic for commerce, difficult to enforce and will deliver many unintended consequences. Mandatory labeling of foods produced using biotechnology at the state level would result in higher food costs, and likely reduced product availability, for NH consumers.
Consumers who choose not to buy food products made with biotechnology can already do so by purchasing foods with a certified organic label or those voluntarily labeled ‘GMO free’.
Foods and food crops produced using biotechnology are among the most reviewed, studied, scrutinized and regulated products in the world. In the United States, three federal agencies, the USDA, EPA, and FDA, oversee such crops. Further regulation at the state level would be redundant and costly.
Labeling advocates assert the public right to know what is in their food. It’s hard to argue with that sentiment. But what useful or verifiable information would the proposed labeling requirement provide? “Produced with Genetic Engineering” or “Partially Produced with Genetic Engineering” labels would merely convey the information that the food contains or may contain some ingredient from a crop that was derived through biotechnology. By whatever preferred name—biotechnology, genetic engineering, genetically modified—this describes a broad category of plant breeding techniques or methods. Each engineered plant variety has different specific attributes—but the proposed label only identifies the use of GE, not the genetic traits or characteristics of the crop.
HB1674’s stated purpose is to “Assist consumers who are concerned about the potential effects of genetic engineering on their health, beliefs and the environment to make informed purchasing decisions;” and “Reduce and prevent consumer confusion and inadvertent deception…” Proponents most frequently express concerns about the risk of allergies to foods derived through genetic engineering. But the proposed labels would provide no useful information on specific genetic traits of the crop or crops.
In fact, foods derived from biotechnology are the only foods screened for allergenicity, and genetic engineering methods allow for more precise transfer of specific genes, resulting in reduced risks. Genetically modified non-allergenic varieties of popular food plants such as peanuts and soy are being developed.
Ninety percent or more of the corn and soybeans grown in the U.S. are biotech products. Sugar beets and canola are other typically biotech crops. Taken together, this means most of the vegetable oils and many sugars in our food supply are derived from GM crops. But processing of oils and sugars leaves no detectable proteins or DNA in the food product—so the genetically modified origin of the foods cannot be detected or verified. What is the meaning of GM labels for these products?
HB1674 exempts alcoholic beverages (GM content also undetectable) and food sold through restaurants and food service—where Americans now spend half or more of their food budgets annually. While retailers get loopholes from enforcement, farmers who produce and sell their own foods to the public get no loopholes. Farmers are the food marketers best positioned to engage in meaningful conversations with customers about how their crops are grown.
The department is concerned about the fears of advanced genetic techniques that are generated or exacerbated by labeling, and even more so by mandatory labels—often referred to as the ‘skull and crossbones effect.’ Consumers are being led to assume that “Genetically Engineered” indicates inferior, unsafe or unhealthy products—just as the trend of ‘gluten-free’ labeling has convinced so many consumers that gluten is unhealthy for all, and to be avoided. Biotech crops have been widely grown and safely consumed over the last two decades and more. If consumers and food manufacturers migrate to more GMO-free products, food costs will go up, and more land and resources will be needed to produce the same amount of food.
Labeling advocates claim GE crops have resulted in increased pesticide use. The increase in pesticide use results primarily from significantly increased acreages planted to corn to meet the demand for ethanol—under government mandates. Use of the herbicide glyphosate has increased along with crops engineered for resistance—but most often replacing or reducing the use of more toxic and/or persistent herbicides. Insect-resistant crops are engineered to incorporate Bt (Bacillus thuringiensis) proteins from a naturally occurring soil bacterium, which has long been a popular insecticide with organic farmers and gardeners. Widespread adoption of Bt crop varieties has yielded dramatic reductions in insecticides used on crops and soil. These are examples of environmental benefits derived from biotech crops, with more to come.
No one seems to challenge the extensive and growing use of genetic engineering in medicine and pharmaceuticals. Food and agriculture should not be asked to address present and future challenges of growing human populations, increasing climate and weather challenges to food production, and the rapid transit of pests and pathogens brought by global trade and travel, with 100 year-old tools and science.