The cultivated seafood industry is in its infancy, and its products are still poised for market entry. As such, industry’s cell-based proponents are cautioning against prematurely imposing regulations that would limit cultivated seafood labeling to terms that may distance consumers, such as “lab-grown.” 

Non-profit Good Food Institute (GFI) is urging that cultivated seafood producers should be allowed to use terms like “fillet” and “steak” in labeling products that have the structural and textural characteristics associated with those terms. 

Meanwhile, aquaculture player BlueNalu is championing the term “cell-cultured” to replac other “disparaging and misleading” labels.

FoodIngredientsFirst has reached out to both organizations for comment.

The GFI stresses that an understanding of consumer’s label literacy must be taken into account when identifying what specific terminology to label products with. It recently issued this guidance addressed to the US Food and Drug Administration (FDA).

The non-profit organization flags that consumers who are allergic to specific types of fish will have the same reaction to cultivated varieties of that species, evidencing the need for labeling uniformity.

“Using the common name of the fish or shellfish will be crucial to alerting these consumers to the potential for dangerous allergic reactions,” warns the GFI.

Some early research has been done about consumer understanding of different shorthand terms for labeling these products, including recent studies of cultivated seafood labeling by Dr. William Hallman of Rutgers University and the Yale Center for Customer Insights, US.

“This research contains early insights into consumer thinking, but also reflects the unavoidable limitation that American consumers are not yet broadly familiar with these products,” notes the GFI.

“FDA should ensure that any requirements it imposes are consistent with the way consumers understand the words used on cultivated seafood labels,” it continues.

Calls for uniformity and simplicity
The FDA requires brands to determine the “common or usual name” to put on the label of all its packaged seafood brought to market.

“That’s a tough assignment,” comments Lou Cooperhouse, co-founder and CEO of BlueNalu. “How do you come up with a common or usual name for something that has never existed before? And why does the FDA make you do that?”

For decades, the law FDA administers has required food companies to display a “common or usual name” on their products so consumers know what they are eating.

But, as Cooperhouse notes, a challenge remains in figuring out what to call an entirely new class of seafood products that are not wild-caught or farm-raised, but produced directly from fish cells.

“This descriptive name needs to be as simple and direct as possible, refer to the characterizing properties or ingredients of the product, and needs to not be confusingly similar to the name of any other foods that are within the same family of products,” says Cooperhouse.

“For example, if you go to the grocery store, you’ll see various brands of breakfast products on the shelves – all with the common or usual name ‘cereal’ on their packages,” he continues.

“Artificial sweeteners use a more direct explanation for their common or usual name – whether you like the one in the blue, yellow or pink packet, all contain the term ‘zero calorie sweetener’ on the label so there is no confusion with sugar.”

BlueNalu refers to its seafood as “cell-based” or produced through “cellular aquaculture.” Generally, companies specializing in cellular agriculture have embraced these terminologies, over the “lab-grown” positioning.

Protecting commercial free speech
As the alternative protein sector sees unprecedented growth, plant-based meat producers have faced similar labeling restrictions in proposed “meaty” labeling bans that limit the use of “burger” and “sausage” terms in meat analogs. Dairy-free players have come up against similar regulatory proposals.

Last July, pro-plant-based NGOs slammed the EU-proposed ban on meat terminology in vegan products, calling this an “insult to the public’s intelligence.”

In its campaign to ease the cell-based path to market, GFI is now urging the FDA to offer open-ended guidance on permissible labeling approaches, rather than mandating the use of one specific term through rule-making.

“This approach would allow time for consumer understanding of relevant terminology to develop, and for new data on that understanding to be gathered,” it stresses.

“It also would help prevent possible consumer confusion in the future, while also protecting commercial free speech interests.”

The GFI concludes that labeling related to production processes would be appropriate, if it is shown that there are measurable differences between certain cultivated seafood products and conventional products that are meaningful to consumers.