As you’ve probably heard, the House of Representatives voted last week to pass the GMO labeling bill. A pretty decisive act. The bill is now headed to the White House where President Obama is expected to be equally decisive and sign the bill. But, for the food industry – and, ultimately, for consumers -- now is where the truly heady decisions have to be made. Although the U.S. Depart of Agriculture (USDA) will be charged with creating the final rules for the law, food makers will have to chose among three labeling options outlined in the bill: an as-yet-to-be-determined symbol, a statement on the package or a scannable QR code that will lead consumers to a website a la the Smart Label program initiated by the Grocery Manufacturers Association. Smaller companies will have a fourth option: provide a website or phone number were consumers can get more information. While one could certainly debate the merits of each of these labeling methods, at the heart of the decision is how food companies will chose to communicate with their consumers. When consumers vote with their pocketbooks, will they want you to provide your full platform on GMOs or will the packaging equivalent of a campaign sign do the trick? (C’mon, it’s convention season. How could I resist?) For the past several years, companies have gone with that campaign sign, relying on the Non-GMO Project Verified label to quickly signal to GMO-fearing consumers whether or not a product is for them. Pretty straight forward. But what would a similar symbol for products containing GMOs convey to consumers? If you’re a consumer that will forgo any product that has a GMO symbol on it, then that’s all you’ll need. But what if you’re undecided? What if you’re ok with some GMO ingredients and not others? Or you understand the difficulties of verifying some ingredients as non-GMO, like honey? Are you going to give up your favorite brand because you don’t know where the bee was hanging out before it came back to the hive? Or will text provide more, well, context? That depends on how much real estate a company wants to give up to explain its GMO ingredients. You could go the route of the Campbell Soup Company, whose GMO label states, “Partially produced with genetic engineering. For more information about GMO ingredients visit Whatisinmyfood.com.” Other than scaring me off with the word engineering, I’m not sure that would tell me, as a consumer, much more than a symbol would, except now I know I could go to a website to find out more information. That is, if I was willing to juggle my shopping cart, fish in my handbag, pull out my phone, type in a URL and start reading in the middle of the canned soup aisle. Not to mention the fact that my over-50-year-old eyes probably wouldn’t have been able to have read that statement in the first place. Of course, that leaves us with the controversial QR code. Please raise your hand if you have scanned a QR code in the last 12 months. No one? There’s a reason why a trade journal published an article titled, “Why QR Codes Are More Outdated Than Your Pog Collection.” And that was published a year ago. In theory, QR codes are awesome. You hold your phone up to them, they scan the code and take you right to a website with all types of information. They probably would be a great way to convey the information consumers need to decide whether or not they want to purchase GMO-containing products. But, if they are all but obsolete now, can we really suggest them as a solution for a labeling law that won’t go into effect for another three years? So what’s the best choice here? That’s something that companies are going to have to decide over these next few years. Clearly any of the methods described above is going to require additional information to make sense to consumers and companies are going to have to be ready to provide it. We certainly don’t want consumers to feel like they’re getting the same level of fine print they get whenever they buy a prescription or over-the-counter drug, so perhaps we can start educating them now. A picture may be worth a thousand words but, in this case, I don’t think that’s enough.
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December 2020
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