Mandatory Labeling of Genetically Modified Organisms & the Food Movement

Is Mandatory GMO Labeling the Hero We Deserve… or the One We Think We Need Right Now?

harvey dent

(I am the food movement.)

batman-gmo

Chelsea Clarke

December 13, 2015


Table of Contents

Introduction

The Food Movement

Mandatory GMO Labeling Current Policy

Vermont, Northeast States, & Others

What Does the “Right to Know” Mean?

Current Federal Legislative Actions

Defining Natural

GMOs By the Numbers

GE Crops & Acreage in the U.S., the Northeast, & Vermont

Projected Impacts of Mandatory Labeling

Farmers

Food Industry

Consumers

Future Federal Policy Options

Buying Time with Preemption?

An Alternative Route?

Conclusion

References


 

Introduction

The Food Movement

There is no formal definition or mission statement of the food movement. Michael Pollan, a well-known author and voice on food issues, begins with a broad definition in terms of unity: “the ‘food movement,’ or perhaps I should say ‘movements,’ since it is unified as yet by little more than the recognition that industrial food production is in need of reform because its social/environmental/public health/animal welfare/gastronomic costs are too high.” Pollan continues, “It would be a mistake to conclude that the food movement’s agenda can be reduced to a set of laws, policies, and regulations, important as these may be. What is attracting so many people to the movement today (and young people in particular) is a much less conventional kind of politics, one that is about something more than food. The food movement is also about community, identity, pleasure, and, most notably, about carving out a new social and economic space removed from the influence of big corporations on the one side and government on the other.”1 Mark Bittman, another outspoken voice on food issues and previously the New York Times lead food columnist, wrote in 2013, “we’re the pioneers of a food movement that’s just beginning to take shape.” He identified a need to be specific and state our goals, as there “…isn’t even a general acknowledgment of a problem in need of fixing.”2

Pollan and Bittman tend to agree that the food movement is nebulous and about much more than changing government food policies. However, there is a sense that the food movement is lacking in political clout and should direct effort toward changing food policies, rather than simply fostering a growing cultural connectedness.2,3,4 Bittman and Pollan have previously glorified mandatory labeling of genetically modified organisms (GMOs) in foods as a potentially important step for the movement to establish political reach. To this end, their highly broadcasted voices garnered public support nationwide.4,5 However, Bittman has tamed his opinion in recent articles, omitting GMO labeling from his list of top priorities to improve our food system.6 Yet, the push for mandatory labeling is still alive and well. If the demand for mandatory GMO labeling arose from food movement activists’ sense of urgency for political change to address the lack of transparency of our food system, it marks the ongoing lack of direction and undefined goals of the food movement. Once enacted, mandatory labeling may turn out to be an ultimate disappointment when consumers fail to fully grasp their coveted “right to know.” A label will not provide a truly transparent window for them see beyond the packaging to what is truly our food system, healthy and sustainable, or not.

Supporters of mandatory labeling of GMOs in our food have simplified the complex pieces of legislation and overarching food policy debates into one visceral phrase: the right to know. Proponents have also decried legislation that does not endorse mandatory labeling, for example, renaming H.R. 1599 as “Deny Americans the Right to Know,” or the DARK Act. Legally, this idea of the “right to know” can be made much more complex, which I will delve into later. Additionally, proponents of the “right to know” think that winning this battle in food policy will enhance transparency, provide consumer choice, and perhaps even lead consumers to inquire how other food is produced.5 Michael Pollan has even gone so far to say that the outcome over the mandatory GMO labeling law in California in 2012, or Prop 37, would show “whether or not there is a ‘food movement’ in America worthy of the name—that is, an organized force in our politics capable of demanding change in the food system”.4 While Prop 37 in California didn’t pass, the Northeast states of Connecticut, Maine, and Vermont seem to have taken up the responsibility of defining the political side of the food movement.

Overall, mandatory GMO labeling appears to be on the frontlines of food movement policy, persistently hitting newspaper headlines and social media newsfeeds as a hotly contested food policy issue in state and federal government. I respect the public visibility and political spotlight that food movement activists have fought so hard to gain with mandatory GMO labeling. Unfortunately in the process, this issue has become manipulated and distorted on both sides. An important question has gotten lost in the debate: if federal or state legislation enacts mandatory GMO labeling, will it really uphold food movement values by improving transparency, expanding consumer choice, and leading consumers to inquire how other food is produced? Or will the costs to farmers, food industry, and consumers outweigh the sense of security obtained from a “right to know” what’s in our food?

On the following pages, I will cover aspects of current state policy on mandatory GMO labeling, including a discussion of the “right to know” and the federal legislative responses to state actions. Then, I investigate GMOs in our food system, from crop acreage to food products, and the potential repercussions that mandatory labeling will have on farmers, food industry, and consumers. Finally, I propose an alternative solution that may better represent values of transparency and consumer choice, in support of a healthier and sustainable food system.

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Mandatory GMO Labeling Current Policy

Vermont, Northeast States, & Others

Whether Americans identify with the food movement or not, public concerns have arisen about the safety of GMOs in food products and the environmental and health detriments associated with the use of genetically modified crops in agriculture. These concerns have led to the emergence of state legislation on mandatory labeling of GMO foods. Setting precedent in the Northeast, Vermont in 2014 passed the Genetically Engineered Food Labeling Act (Act 120) that requires labeling of foods and beverages produced with genetic engineering.7 Two other states, Maine and Connecticut, passed mandatory labeling legislation before Vermont, but these laws contained a “trigger clause,” with implementation contingent on surrounding state labeling laws.8,9 Massachusetts and New Jersey have active bills, and New York had proposed a bill on the topic of mandatory labeling earlier this year. Across the U.S., 70 bills have been introduced in more than 30 states, with separate efforts gaining momentum from the nationwide coverage of California’s Prop 37 in 2012.10

GE Labeling Bills Interactive Map

Source: Center for Food Safety. (2015). State Labeling Legislation Map. Retrieved from: http://www.centerforfoodsafety.org/issues/976/ge-food-labeling/state-labeling-initiatives

Vermont Act 120 defines genetic engineering (GE) as “a process by which a food is produced from an organism or organisms in which the genetic material has been changed through the application of: in vitro nucleic acid techniques… fusion of cells… or hybridization techniques that overcome natural physiological, reproductive, or recombination barriers.”7 The bill specifically requires all GE foods or GE-containing foods to be labeled as “produced with genetic engineering” or “partially produced with genetic engineering” either on the package or on the retail store shelf. The compliance date has been set for July 1, 2016. In addition to the mandating labeling requirements, Vermont Act 120 restricts such foods from displaying any claim of “natural” or other variations on the term.7 In concordance, Connecticut’s mandatory labeling law also contains a clause restricting the use of “natural” on GE foods, while Maine’s legislation does not.11 To support the mandate for labeling GE foods, Vermont Act 120 cites consumers’ health, personal, religious, and environmental values as reasons, essentially summarizing activists’ call for the “right to know.”7

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What Does the “Right to Know” Mean?

In the vaguest of notions, the “right to know” refers to consumers’ desire to have certain information at their disclosure regarding the goods that they purchase daily—“I want to know what’s in my food, or how it’s been produced.”5 In a more political or legal sense, a “right to know” suggests the existence of a written policy, such as the First Amendment free speech clause, that grants the consumers a right to accurate, non-misleading information that they reasonably desire.12 Previous court findings in relation to recombinant Bovine Growth Hormone labeling have found that “consumer interest” in itself does not give reason enough to grant this “right to know” in mandatory labeling laws.13 However, the FDA has taken a “need to know” approach in which any alterations to food that introduce potential allergens or otherwise change the composition of the food must be disclosed. The difference between “want to know” and “need to know” can be demonstrated in the FDA’s decision to label irradiated foods in 1966.12 Irradiation can be used to kill microbes on fruits, vegetables, spices, and meats, but its use remains limited today. The Center for Disease Control and Prevention estimated that using irradiation technology to sanitize meat could prevent 900,000 cases of infection, 8,500 hospitalizations, 6,000 illnesses, and 350 deaths per year.12 Unfortunately, the FDA decision to label irradiated foods may have prompted consumers to misinterpret it as a warning, hindering use when the technology first emerged. In the absence of mandated labeling, irradiation could be more widely used as a method to prevent the spread of foodborne pathogens today.12 Opponents of mandatory labeling for GMOs share this concern, worrying that consumers’ misunderstanding of the label and subsequent purchasing decisions may lead to a stagnation or decline in the use of GMO technology. Indeed, this trend has been seen in Europe.12

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Current Federal Legislative Actions

House and Senate Bills have surfaced in response to rising concern in the food industry over the misinterpretation of these mandatory labels combined with questions on whether or not Vermont has exceeded its regulatory authority. H.R. 1599, also known as the Safe and Accurate Food Labeling Act of 2015 (or the DARK Act), was proposed by Rep. Mike Pompeo (R-KS) and passed by the House on July 23, 2015. The bill has been referred to and remains in the Senate Committee on Agriculture, Nutrition, and Forestry. The bill preempts state and local requirements for labeling GMO food and the term “natural,” and establishes a voluntary genetically engineered food certification program that discusses labeling foods as either non-GMO or GMO.14 Alternately, H.R. 913, the Genetically Engineered Food Right-to-Know Act, aligns with mandatory labeling efforts at the state level by mandating GMO labeling at the federal level, and it contains a clause prohibiting the use of “natural” on GE foods.15 This bill, proposed by DeFazio (D-OR), remains in the House Subcommittee on Health. Another bill, S. 511, introduced in the Senate by Sen. Barbara Boxer (D-CA) contains similar language for the use of “natural” and mandatory GMO labeling.16 Senator Debbie Stabenow (D-MI), a former chair of the Senate Committee on Agriculture and Forestry, is leading the push for a proposal to address these issues on a federal level, has stated that she wants to address the “patchwork” problem that could arise from 50 different state regulations on GMO labeling, without stigmatizing biotechnology, at the same time providing transparency to consumers.17 Juggling such conflicting demands, Stabenow has voiced support for “preemption with a sunset to it,” which would force industry into creating voluntary labeling system with the threat of the federal preemption expiring.18 In a timely debut, Hershey’s recently introduced its SmartLabel system, which can be presented as a potential labeling solution for the food industry that would provide transparency to consumers.19

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Defining Natural

On November 12 of this year, the FDA requested comments on the term “natural” on food labeling. Interestingly in March 2014, the Grocery Manufacturers Association (GMA) sent a letter requesting that the FDA define this term, perhaps to combat the Vermont Act 120 “natural” clause. The Sugar Association and Sara Lee Corp also submitted requests to the FDA, while the Consumers Union suggested that the term “natural” be banned.34 Ultimately, a definition of the term “natural” could be another roundabout way of GMO labeling, an expansion on USDA organic labeled foods. If GMO-containing products were excluded from displaying the “natural” label, consumers could infer that any product labeled “natural” is GMO-free.11 The public may be satisfied with this accepted definition of the term “natural,” but the food industry would likely remain unsatisfied with the assertion that GMO-containing products are not “natural.” However, it seems the food industry has weighed the positives and negatives of this policy measure. Based on the GMA, the Sugar Association, and Sara Lee Corp. requests to the FDA, they seek to pursue a definition of “natural” at the risk of exclusion of certain products from the criteria, in the hopes that additional, more explicit state mandatory GMO labeling legislation will not hold up in court.

It is clear that policymakers are struggling to appease all stakeholders involved, from food industry to consumers, with farmers caught in the middle. To grasp the complexities of the mandatory labeling debate, many readers coming from a consumer standpoint would benefit from a broad understanding of GE crop acreage and prevalence of GE ingredients in food products in the United States, which I will discuss next.

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GMOs By the Numbers

GE Crops & Acreage in the U.S., the Northeast, & Vermont

The most common GE crops include soybean, corn, cotton, canola, and sugar beet, with soybean, corn, and cotton representing the largest share in the US.20 Products from these crops are common ingredients in many processed foods. Yes, even cottonseed oil.[1] The Grocery Manufacturer’s Association (GMA) estimates that GMOs are present in 70-80% of all processed foods in stores.21 GMOs are ubiquitous in our food system, from farmland to the supermarket. Across the United States, farmers planted 169 million acres of GE corn, cotton, and soy crops in 2013, which is almost half of the estimated total cropland in the US.20 GE herbicide-tolerant (HT) seeds were used to plant 93% of soybean acres, 85% of corn acres, and GE Bacillus thuringiensis (Bt, pest-resistant) corn also accounted for 76% of corn acres in 2013.20

[1] Fun fact: Crisco’s name is short for crystalized cottonseed oil, and today’s formula still includes cottonseed oil.

(National Cottonseed Products Association, http://www.cottonseedoiltour.com/facts/)

Screen Shot 2015-10-09 at 10.56.02 AM

Source: Economic Research Service. United States Department of Agriculture. (2015). Genetically Engineered varieties of corn, upland cotton, and soybeans, by State and for the United States. Retrieved from: http://www.ers.usda.gov/data-products/adoption-of-genetically-engineered-crops-in-the-us.aspx

Thus, GE crops comprise a majority of crop acreage planted in the US. In contrast, organic corn and soy crops make up 0.26% and 0.17% of total US production in 2011, respectively.20 While the Northeast states are not top producers of corn and soy crops, GE seeds are used for 90% of all corn planted and 94% of all soybeans planted in “other states,” a category that lumps Northeast states with all other lower producing states.22 Farmers in the Northeast also rely on GE corn, alfalfa, and soybeans used for cattle feed in dairy and meat operations.

In Vermont, sales of GE seeds are reported to the state Agency of Agriculture, Food, and Markets. Only corn, soybean, and alfalfa GE seeds were sold in 2014. In the most recent years, the estimated acreage from GE corn seed sales comprises close to 100% of the total corn acres planted, representing an estimated 92,905 acres of GE corn planted in 2014. In contrast, estimated acreage of GE corn accounted for only 8% of total corn acres planted in 2002. About 8,220 acres, or 85-95% of total soybean acres, are planted with GE seeds, while only 287 acres, or 4.8% of new alfalfa seedling acres are from GE seeds.23 It is evident that many farmers livelihoods depend on GE corn and soy across the U.S. and in Vermont.

Vermont GMO corn planted

Source: Vermont Agency of Agriculture Food & Markets. (2015). Reported Genetically Engineered Seed Sales in Vermont 2002 to 2014. Retrieved December 13, 2015, from: http://agriculture.vermont.gov/sites/ag/files/PDF/2014%20GE%20Seed%20Sale%20Summ%20wo%20dealers%201.pdf
Note: “In 2011, significant acreages of corn, all purposes, were reported as having been reseeded as a result of late spring germination failures (flooding, late thaws, killing frosts after seedling emergence, etc.), which may help explain this overage. Additionally, seeding rates and #seeds per pound conversions (below) are likely contributing to imprecision in the overall calculation, as well as imprecision in the annual estimated acreages planted provided by USDA. Regardless, the overall trend in Vermont since 2002 has been an overall increase in the amounts of GE corn seed sold annually.”

However, farmers groups’ stances on the issue are divided. Groups such as the National Milk Producers Federation (NMPF) and the National Council of Farmer Cooperatives (NCFC) have voiced their support of a federal preemption in H.R. 1599.24,25,26 Cedar Circle Farm, Northeast Organic Farming Association of Vermont (NOFA-VT) and Rural Vermont continue to support Vermont Act 120 in court.27 Organic farmers are protected from any indirect effects of mandatory labeling, but conventional farmers may see a shift in demand for non-GE crops.

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Projected Impacts of Mandatory Labeling

Farmers

GE crops are pervasive in American agricultural practices because farmers often have economic incentive to grow them. Analysis shows that Bt corn is more profitable to farmers than planting conventional seeds.20 While HT crops do not always have a positive association with net returns to farmers, with studies finding positive, negative, or no difference in net return between adopters and non-adopters, HT crop adoption is associated with an increase in off-farm income, and farmers value convenience, flexibility, and worker safety that may arise from use of HT seeds.20 Unfortunately, economic analyses overlook the indirect impacts of mandatory labeling on farmers, and the media often only pits consumers against “Big Food” or Monsanto, leaving farmers out of the picture, or lumped in with “Big Food.” Cost analyses of mandatory labeling that will be discussed in the next sections have focused on benefits and detriments to industry and consumers and have neglected the potential negative effects GMO labeling could have on conventional U.S. farmers.

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Food Industry

Industry groups’ opposition to mandatory labeling laws arises from the increase in direct costs associated with labeling, as well as the indirect costs borne by sourcing non-GMO ingredients or the loss in profit if the processor opts to discontinue sales in the region. 28

Concerns over the labeling laws have caused industry to consider their options: costs of labeling, costs of sourcing non-GMO ingredients, and costs of dropping certain products in Vermont altogether.28,29 These industry decisions have implications for consumers who may see increases in food prices due to labeling costs passed down, or a reduced availability of cheaper foods produced with GMO ingredients. Industry estimates that 70-80% of food products contain genetically modified ingredients.21 With a likely majority of food products processed with GMO ingredients, industry decisions on how to address mandatory labeling would have broad effects on food products sold in stores in Vermont, and possibly other Northeast states. While labeling laws could sway processors to source non-GMO foods, some researchers estimate that the cost of GMO ingredients in processed foods accounts for only a small portion of the final product. Foods typically sold as whole fresh fruits and vegetables may more directly reflect different costs between GMO and non-GMO foods.30

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Consumers

Various reports have estimated costs associated with direct labeling, in-store display costs, costs passed on to consumers, and state government costs associated with the legislation.31,32,33 Due to differing formulas, variations in state legislation, and variable definitions of labeling costs, these reports show a wide range of possible costs to consumers. One cost study review for mandatory labeling for Oregon Ballot Measure 92 found that the median direct cost of formulating and printing a GMO label on foods was $2.30 per capita per year, varying from $0.32 to $15.01 among all cost studies.32 The authors caution that these costs do not always directly reflect price increases for consumers. However, this study only focused on direct costs from labeling. It did not address costs associated with reformulation using non-GMO ingredients or governmental regulatory costs. Reformulation could significantly increase food prices for consumers, while regulatory costs would not alter food prices.

Price increases are not the only possible harm to consumers. Loss of consumer choice could also result from reformulated products or products pulled from state or regional shelves, and this loss of choice could affect food spending. This phenomenon can be better explained through willingness to pay (WTP) studies. Research has shown that some consumers are willing to pay more for non-GMO products, while others chose to pay less for GMO products. For example, two studies showed that US customers’ WTP was 5-14% more for non-GMO food, while another found that their WTP was 14% lower for GMO foods.20 From a savings perspective, some customers would choose GMO foods for a lower price. From a premium vantage point, some customers opt to pay more for non-GMO foods. In the absence of mandatory labeling laws, consumers in the US can only choose to pay for organic or voluntarily labeled non-GMO foods. Consumers who do not choose these options are arguably paying less for processed foods with the possibility of consuming GMO ingredients. Yet with the introduction of mandatory labeling, economists argue that consumer choice to buy GMO foods is significantly reduced. Food processors will choose to source non-GMO foods, as a “winner takes all” rational decision, and consumers will not have the option to purchase GMO foods at a discounted price.30 Mandatory labeling could increase costs to everyone, but voluntary labeling allows consumers to seek out premium-priced, non-GMO products.31

Overall, mandatory labeling of GMO foods has the potential to influence industry choices to reformulate product ingredients. Quantitative estimates of this cost to consumers vary depending on many factors, notably inclusion or exclusion of reformulation costs. Costs to farmers are difficult to determine because they depend upon industry decisions to reformulate or to discontinue sales within a region. However, farmers who grow corn, soy, and other GE crops nationwide and in the Northeast region depend upon purchase of their products by food processors and the dairy and meat industries. Industry decisions to reformulate products to non-GMO ingredients could cause a major shift in production over time, reducing farmers’ profit and other benefits they reap from planting GE crops.

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Future Federal Policy Options

Buying Time with Preemption?

As the state and federal debate between mandatory and voluntary GMO labeling heats up and the Vermont Act 120 July 1st date looms closer, Congress may feel pressure to take action one way or another: towards a national law mandating labeling or preempting state mandatory labeling with, possibly, additional voluntary labeling guidance. And in case the federal government fails to act, manufacturers are preparing to make decisions that could have implications for food products sold across the US. Any law preempting mandatory labeling gives consumers the uneasy feeling of “What are they trying to hide?” with fingers pointed at the food industry and the federal government.35 If a federal law is passed that preempts state mandatory labeling, in lieu of convoluted conspiracy theories and cover-ups, consumers should realize that mandatory GMO labeling may not be the pivotal, turning point moment for food system transparency. Indeed, food industry and retailers have heard consumer demand for a transparent food system loud and clear.

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An Alternative Route?

The recent rise in state and federal legislative efforts dealing with GMO labeling and calls to define “natural” can be partially attributed to consumers’ desire to know what is in their food for health, environmental, ethical, religious or other values aligned with the food movement. In 2010, Hannaford Supermarkets launched a sustainable seafood sourcing program, developed in partnership with the Gulf of Maine Research Institute (GMRI). Hannaford only sources from suppliers who demonstrate their seafood comes well-managed fisheries that meet certain standards. In addition, the seafood products must have information about where they were harvested, with full traceability to the port of landing or farm.36 Similar announcements about sustainable sourcing have been cropping up in press releases of major food companies, such as Nestlé’s promise to source sustainable cocoa worldwide, and Chipotle’s announcement to use only non-GMO ingredients.37,38

With large companies making big promises, consumers may become wary of green-washing, in which a company tracks numbers and advertises efforts of sustainability, but in reality continues business-as-usual practices under the guise of transparency and accountability. Food labels and their claims, “non-GMO” and “natural” among them, carry the same potential for green-washing (barring any outright lies about ingredients) and often invoke misconceptions about nutrition and health, leading to an undeserved “health halo” surrounding the product.39 We deserve to have accountability built in at every point in our food system, but labeling places the heavy burden of information and misinformation on the consumer. Transparency in our global food system cannot be simplified and posted on a label, not even a SmartLabel.

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Conclusion

To restate the question I initially posed: If federal or state legislation on mandatory GMO labeling is enacted, will it really uphold food movement values by improving transparency, expanding consumer choice, and leading consumers to inquire how other food is produced?

GMO labeling and the “right to know” draws on consumers’ desire for food system transparency. It would allow them to make purchases that reflect their diverse values pertaining to health, environment, animal welfare, equity, culture, religion, and more. As Pollan mentions, the food movement is unified by all of these values, not any one in particular. The food movement has coalesced upon the acknowledgment that these values are reflected in our food system. It is understandable that individuals seeking to make sense of a complex and not-so-transparent food system would latch onto a policy such as GMO labeling that is promoted as the “right to know” and a path to transparency. Yet, even a “right to know” or a “want to know” can have unintended consequences that may limit consumer choice and safety when the information is misinterpreted as a warning, as seen in the past with irradiation technology. Mandatory labeling can also reduce consumer choice and potentially increase prices if the food industry opts to reformulate products. As for the potential for mandatory labeling policy to further inquiries about how our food is produced, the lack of information and discussion of its effects on conventional farmers points to the myopic concerns of the consumer in this issue. The economic benefits of Bt corn and the improved quality of life seen with HT crops are not small claims for conventional farmers. These values should be reflected somewhere in our quest for a transparent food system.

Ultimately, the food movement is about so much more than government policies and regulations. A retailer’s sustainable seafood sourcing program, a food giant’s commitment to sustainable cocoa, and a restaurant chain’s announcement to source all non-GMO ingredients are all examples of encouraging progress toward a more transparent food system. We deserve to have accountability built in at every point in our food system, rather than placing the burden on the consumer to scrutinize labels. Instead of pushing for a mandatory labeling policy that has failed to live up to its expectations as a hero for the food movement, I advocate for more voluntary disclosure of ingredient sources and public commitments to sustainable, ethical, equitable, and healthful sourcing from food industry and retailers. This approach, I believe, will enhance transparency and improve choice. Above all, it will prompt everyone, at every point in our food system, to ask more questions about how our food is produced.

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References

Image Sources:
http://38.media.tumblr.com/05eadbd67d6937faaa3f3825f51290c8/tumblr_mzjn9nbt6t1srdmzjo1_500.gif
http://thelogicofscience.com/2015/02/21/gmos-are-unnatural-but-so-is-everything-else-that-you-eat/
  1. Pollan, M. (2010, June 10). The Food Movement, Rising. Retrieved December 13, 2015, from http://www.nybooks.com/articles/2010/06/10/food-movement-rising/
  2. Bittman, M. (2013, January 1). Fixing Our Food Problem. Retrieved December 13, 2015, from http://opinionator.blogs.nytimes.com/2013/01/01/fixing-our-food-problem/
  3. Paarlberg, R. (2013). Food politics: What everyone needs to know. Oxford University Press.
  4. Pollan, M. (2012, October 10). Why California’s Proposition 37 Should Matter to Anyone Who Cares About Food. The New York Times. Retrieved December 13, 2015, from http://www.nytimes.com/2012/10/14/magazine/why-californias-proposition-37-should-matter-to-anyone-who-cares-about-food.html
  5. Bittman, M. (2012, September 15). G.M.O.’s: Let’s Label ’Em. Retrieved December 13, 2015, from http://opinionator.blogs.nytimes.com/2012/09/15/g-m-o-s-lets-label-em/
  6. Bittman, M. (2015, May 6). Let’s Make Food Issues Real. The New York Times. Retrieved December 13, 2015, from http://www.nytimes.com/2015/05/06/opinion/lets-make-food-issues-real.html
  7. Vermont Legislature. (2014). An Act Relating to the Labeling of Food Produced with Genetic Engineering. H. 112 (Act 120) [legislation]. Retrieved December 13, 2015 from: http://www.leg.state.vt.us/docs/2014/bills/Passed/H-112C.pdf
  8. 126th Maine Legislature. (2014). LD718 HP490. An Act to Protect Maine Food Consumers’ Right to Know about Genetically Engineered Food [legislation]. Retrieved from: http://www.mainelegislature.org/legis/bills/bills_126th/billtexts/HP049001.asp
  9. Connecticut General Assembly. (2013). An Act Concerning Genetically-Engineered Food. Public Act No. 13-183 [legislation]. Retrieved from: https://www.cga.ct.gov/2013/ACT/pa/pdf/2013PA-00183-R00HB-06527-PA.pdf
  10. Center for Food Safety. (2015). State Labeling Legislation Map. Retrieved from: http://www.centerforfoodsafety.org/issues/976/ge-food-labeling/state-labeling-initiatives
  11. Muller, J. M. (2015). Naturally Misleading: FDA’s Unwillingness to Define Natural and the Quest for GMO Transparency through State Mandatory Labeling Initiatives. Suffolk UL Rev.48, 511.
  12. Noah, L. (2013). Genetic Modification and Food Irradiation: Are Those Strictly on a Need-to-Know Basis. Penn St. L. Rev.118, 759.
  13. Rich, M. (2003). Debate over Genetically Modified Crops in the United States: Reassessment of Notions of Harm, Difference, and Choice, The.Case W. Res. L. Rev.54, 889.
  14. Pompeo, M. (2015, July 24). H.R.1599 – 114th Congress (2015-2016): Safe and Accurate Food Labeling Act of 2015 [legislation]. Retrieved December 13, 2015, from https://www.congress.gov/bill/114th-congress/house-bill/1599
  15. DeFazio, P. (2015, February 13). H.R.913 – 114th Congress (2015-2016): Genetically Engineered Food Right-to-Know Act [legislation]. Retrieved December 13, 2015, from https://www.congress.gov/bill/114th-congress/house-bill/913
  16. Boxer, B. (2015, February 12). S.511 – 114th Congress (2015-2016): Genetically Engineered Food Right-to-Know Act [legislation]. Retrieved December 13, 2015, from https://www.congress.gov/bill/114th-congress/senate-bill/511?q={%22search%22:[%22GMO+labeling%22]}&resultIndex=14
  17. Fatka, J. (2015, October 23). Compromise nearing in ‘GMO’ labeling solution. Farm Futures. Retrieved December 13, 2015, from: http://farmfutures.com/blogs-compromise-nearing-gmo-labeling-solution-10316
  18. Purdy, C. (2015, November 19). Senators look to approps fix for GMO labeling, with a catch. Retrieved December 13, 2015, from http://www.politico.com/tipsheets/morning-agriculture/2015/11/senators-look-to-approps-fix-for-gmo-labeling-with-a-catch-211364
  19. HERSHEY’S Shared Goodness | Hershey shares what’s inside SmartLabel. (n.d.). Retrieved December 13, 2015, from http://www.thehersheycompany.com/social-responsibility/shared-goodness/our-ingredient-conversation/story/hershey-shares-whats-inside-smartlabel
  20. Fernandez-Cornejo, J., Wechsler, S., Livingston, M., Mitchell, L. (2014). Genetically Engineered Crops in the United States, ERR-162. U.S. Department of Agriculture, Economic Research Service. Retrieved from: http://www.ers.usda.gov/media/1282246/err162.pdf
  21. Grocery Manufacturers Association. (2014). Grocery manufacturers Association Position on GMOs. Retrieved December 13, 2015 from http://factsaboutgmos.org/disclosure-statement
  22. S. Department of Agriculture, Economic Research Service. (2015). Genetically Engineered varieties of corn, upland cotton, and soybeans, by State and for the United States. Retrieved from: http://www.ers.usda.gov/data-products/adoption-of-genetically-engineered-crops-in-the-us.aspx
  23. Vermont Agency of Agriculture Food & Markets. (2015). Reported Genetically Engineered Seed Sales in Vermont 2002 to 2014. Retrieved December 13, 2015, from: http://agriculture.vermont.gov/sites/ag/files/PDF/2014%20GE%20Seed%20Sale%20Summ%20wo%20dealers%201.pdf.
  24. National Milk Producers Federation. (2015). Congress Focuses on GMO Food Debate as New Voluntary Labeling Law is Introduced. Retrieved December 13, 2015, from: http://www.nmpf.org/latest-news/articles/congress-focuses-gmo-food-debate-new-voluntary-labeling-law-introduced
  25. National Council of Farmer Cooperatives. (2015). GMO Labeling NCFC Position. Retrieved December 13, 2015, from: http://ncfc.org/issues/food-nutrition/gmo-labeling/
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  27. Rural Vermont. (2015, September 2). VT Digger: Vermont Groups Help Defend GE Food Labeling Law. Retrieved December 13, 2015, from: http://www.ruralvermont.org/agriculture-in-the-news/vt-digger-vermont-groups-help-defend-ge-food-labeling-law/
  28. Byrne, P., Pendell, D., and Graff, G. (2014). Labeling of Genetically Modified Foods Fact Sheet No. 9.371. Retrieved from http://extension.colostate.edu/docs/pubs/foodnut/09371.pdf
  29. Thomas, D.E. (2015, October 21). Agriculture Biotechnology: A Look at Federal Regulation and Stakeholder Perspectives. Statement to U.S. Senate Committee on Agriculture, Nutrition and Forestry. Retrieved from: http://www.ag.senate.gov/hearings/agriculture-biotechnology-a-look-at-federal-regulation-and-stakeholder-perspectives
  30. Carter, C.A., and Gruere, G.P. (2003). Mandatory Labeling of Genetically Modified Foods: Does it Really Provide Consumer Choice? AgBioForum, 6(1&2), 68-70 Retrieved from: http://www.agbioforum.org/v6n12/v6n12a13-carter.htm
  31. Shepherd-Bailey, J.M. (2014) Economic Assessment: Proposed California Right to Know Genetically Engineered Food Act (Prop 37) Likely to Cause No Change in Food Prices, Minor Litigation Costs, and Negligible Administrative Costs. Retrieved from: http://www.anh-usa.org/wp-content/uploads/2012/08/GE-Food-Act-Costs-Assessment.pdf
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  33. Marsh, T., Nester, E., Beary, J., Pendell, D., Poovaiah, B.W., and Unlu, G. (2013).White Paper on Washington State Initiative 522 (I-522): Labeling of Foods Containing Genetically Modified Ingredients. Washington State Academy of Sciences. Retrieved from: http://www.washacad.org/initiatives/WSAS_i522_WHITEPAPER_100913.pdf
  34. Federal Register. (2015, November 12). Use of the Term “Natural” in the Labeling of Human Food Products; Request for Information and Comments. Retrieved December 13, 2015, from: https://federalregister.gov/a/2015-28779
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  36. Hannaford Supermarkets. (2010, July 14). Press releases- Hannaford begins sustainable seafood sourcing program. Retrieved December 13, 2015, from: https://www.hannaford.com/content.jsp?pageName=NewsSustainableSeafood&leftNavArea=AboutLeftNav
  37. Nesté. (2015, August 31). KitKat makes global pledge to use only sustainably sourced cocoa. Retrieved December 13, 2015, from: http://www.nestle.com/media/news/kitkat-announce-sustainably-sourced-cocoa-global
  38. (2015, April 27). Press Release: Chipotle Becomes the First National Restaurant Company to Use Only Non-GMO Ingredients. Retrieved December 13, 2015, from: http://ir.chipotle.com/phoenix.zhtml?c=194775&p=irol-newsArticle_print&ID=2040322
  39. Peloza, J., & Montford, W. (2015, March 11). The health halo: how good PR is misleading shoppers. The Guardian. Retrieved December 13, 2015, from http://www.theguardian.com/sustainable-business/2015/mar/11/know-what-you-eat-health-halo

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