BIO Comments on FDA Natural Food Labeling
Division of Dockets Management
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
The Biotechnology Innovation Organization (BIO) is pleased to submit these comments to FDA in response to FDA’s request for information on the use of the term “natural” on food labeling (docket no. FDA-2014-N-1207). BIO is the world's largest biotechnology trade association, representing companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than thirty other nations. BIO members are involved in the research and development of healthcare, agricultural, industrial and environmental biotechnology products.
BIO respectively notes the following as a general matter:
First, we believe that the term “natural” may permissibly be used for food products irrespective of whether certain production practices, including genetic engineering and other modes of biotechnology, were used in some way that can be traced to the creation, development, production, or finishing of the products. The use of the term ‘‘natural’’ is appropriate in the labeling of food products that are genetically engineered, are derived in some way from genetically engineered organisms, or contain ingredients, additives, enzymes, or processing aids produced through the use of genetic engineering.
Second, we believe that if biotechnology, including a processing aid or enzyme derived from or utilizing biotechnology, was used in the production, processing, or sourcing of a food ingredient, that fact should not affect whether a food containing that ingredient may be labeled as “natural.”
Finally, we offer a brief comment noting the broad scientific and regulatory consensus supporting the safety of foods improved through modern biotechnology, which FDA itself has recently and appropriately reaffirmed....