How To Do GMO Food Labeling Right

Written by Steve Savage

Shopping, from Anthony Albright.

A Modest Proposal

Should food with ingredients from genetically engineered crops – “GMOs” – be labeled?  Many argue that consumers have a “right to know” about this.  Ok, if the real reason for labeling is to provide consumers with knowledge, then the label should read:
“Contains ingredients from biotech enhanced crops approved by the USDA, FDA and EPA”
That would tell people what is unique about these crops.  Humans have been genetically modifying crops for centuries using a variety of methods.  The difference for genetically engineered crops is that they must be fully characterized and tested in order to gain approval from three different regulatory agencies – the USDA, the EPA and the FDA (there is a description of this process below if you are interested).  Crops modified in other ways including those generated by conventional breedingmutation breeding or “wide crosses” or hybrids or doubled haploids don’t have to be tested or approved at all.  The clear, international scientific consensus is that genetic engineering involves no unusual risk relative to all the other methods of genetic modification, but this testing was instituted out of an abundance of caution.  Thus, any label should let consumers know about this extra level of scrutiny conducted for their benefit.


We have a precedent for a positive, official label designed to communicate government oversight. This is the federally regulated “USDA Organic” label that signifies that the agency governs the certification process for that food.  The biotech food labeling should be of this same affirmative nature because of the extraordinary review from three agencies.  We also have warning labels for real risks like certain allergens and for trans-fats, but that kind of labeling is inappropriate for genetically engineered crops.  On the contrary, there are hundreds of peer reviewed scientific studies that looked for and failed to find health issues associated with these foods.

Let’s Really Make It About Knowledge

If we label genetically engineered foods, we should accompany that with supporting educational resources.  We have some experience as a country about what happens if you label but don’t educate. Back in 1994, Congress passed the “Nutrition Labeling and Education Act” that lead to that list of nutrient contents you see on food packages.  The lawmakers never followed through to provide the funding for the education part (imagine that!)  So the law effectively became the “Nutrition Labeling in a Vacuum Act” and many consumers get little benefit from the labels.  Let’s not repeat that mistake with a “GMO Labeling in a Vacuum” law.

Code stamp, from

Accompanying the label I have described, there should be a URL or a code stamp to take you to web sites that explain how these crops are developed, how they have been evaluated, and also about some of their advantages. The site could talk about how:

Congress could even fund an educational program to provide basic nutrition education which should have started 18 years ago.
If some politician will introduce a bill to require labeling of the type I have described and include guaranteed funding for real education, they could get the enthusiastic support of the scientific community.

Needled tomato from Global Research Canada

Would my labeling suggestion satisfy the groups that have been promoting “GMO labeling?”  Probably not. There is pretty strong evidence that their goal is not really about what consumers would “know.”  It seems more likely that it is about wanting consumers to be afraid and thus to buy more of the organic, certified non-GMO, or under-regulated supplements they sell (look who provided the money to push prop 37 in California).  The clue is the typical imagery used by these labeling promoters and their allies.  It usually involves the meme of a large, scary looking hypodermic needle filled with a suspicious, liquid being injected into something like a ripe tomato.
That image bears absolutely no relationship to how plants are genetically engineered.  It is a transparent attempt to frighten people.  Thus, if the labeling were to actually let consumers know enough not to be afraid, it wouldn’t accomplish the financial goals of many of the groups pushing labeling. It might even reduce their sales.
I salute my fellow Californians for voting down Proposition 37, a deeply flawed GMO labeling initiative which would have been a consumer knowledge disaster for the financial benefit of certain folks who really don’t deserve it.  As a scientist and someone who cares deeply about food, I could endorse a food labeling law like the one in my modest proposal.
You are welcome to comment here and/or to email me a  I tweet from time to time at @grapedoc.

Additional Background About How These Crops Are Regulated

For those that are interested here is some background.  GMO crops, those that have been modified using the tools of genetic engineering, go through a degree of composition and safety testing which has never been required for other means of improving crops – even methods such as mutation breeding or wide crosses which have far more potential for undesired effects.  These new crop varieties are scrutinized by no less than three federal regulatory agencies under a system called “The Coordinated Framework” that was hammered out in the 1980s and 1990s well before any GMO crops were commercialized.  Historically most regulation of industries has been instituted after there has been a problem.  GMO foods are rather unique in that the regulations were designed before there was any commercialization and in the absence of any problematic events.

How Does The Regulation Work?

The USDA scrutinizes any potential for the crop to be a “plant pest risk” and any sort of gene transfer issue for other crops or weeds.  The EPA scrutinizes any pesticide-related issues such as the Bt-based insect resistance traits or the herbicides that would be used on herbicide tolerant crops.  The FDA scrutinizes the data that the companies submit to demonstrate that their new varieties are functionally identical to non-modified versions of the crop. They don’t have specific requirements because each crop and modification would be unique in terms of what matters. Still, that does not mean what is often alleged that there is “no required testing.”  The submission is technically voluntary, but all biotech crop developers have always submitted data to the FDA.  Again, new crop varieties from all other mechanisms of genetic modification have no testing requirements at all, so if there is any testing it is on a purely voluntary basis. “GMO crops” are unique in that they must be tested and approved.
With all this analysis of GMO crops, it is should not be surprising that even though this technology has been adopted for billions of acres of crop production over 16 years, there have been no legitimate health or environmental problems, and rather a great many benefits.

Written by Guest Expert

Steve Savage has worked with various aspects of agricultural technology for more than 35 years. He has a PhD in plant pathology and his varied career included Colorado State University, DuPont, and the bio-control start-up, Mycogen. He is an independent consultant working with a wide variety of clients on topics including biological control, biotechnology, crop protection chemicals, and more. Steve writes and speaks on food and agriculture topics (Applied Mythology blog) and does a bi-weekly podcast called POPAgriculture for the CropLife Foundation.


  1. “Would my labeling suggestion satisfy the groups that have been promoting “GMO labeling?” Probably not.”
    I suppose I’m a “member” of those groups, but I’m fine with your proposal. I wish we could all just come together on this instead of the most extreme members of each side volleying extreme rhetoric at one another that’s largely unsubstantiated. Are GM foods going to save the world? Highly unlikely. Are they going to destroy it? Also highly unlikely. But do people deserve to know how their food is grown? Hell yes. So let’s stop arguing about it and come up with something we can all agree on.

  2. I’m all for a more relevant label and would love one that somehow linked to online information about the actual traits involved (I wonder if it’s feasible but while I’m dreaming, why not?) I do have to take issue with this wording though: “Contains ingredients from biotech enhanced crops approved by the USDA, FDA and EPA”. If a straight “contains GMOs” would be political fear-mongering, then this is the opposite (or, rather, to be fair the purveyors of irradiated food, meat sellers and many others would want to change their labels to add “enhanced” phrasing and noting the approving bodies!)
    But really I’m all for any label at this point if it will move public discussion on to more important topics like land use, carbon costs, etc.

  3. I also wrote recently about the idea of putting QR codes on food to give consumers the ability to make better choices:
    The industry ought to do this voluntarily now as I suggest there (label everything that might possibly contain GM-derived ingredients without setting up the supplier chains for validation). They can control the labels and set the tone and defuse the entire issue.
    I also agree with Rachael that “enhanced” is a loaded word that implies to the consumer there’s more nutritional value. Not all traits that enhance GE crops are there to improve the nutritional benefits, so I think it borders on propaganda.

  4. At first read I agree with the “strawman” of what you are proposing above – it makes sense and I would support putting it forward in a debate on GMO labeling. I don’t have the years of sector specific scientific knowledge and experience that you have Steve but I do have a science background and don’t agree with all your points for example a) that GMO’s are unequivocally safe b) that GMO labeling proponents over simplify the issue c) that there is enough (independent!) testing d) that GMO’s don’t affect the environment etc.
    Let’s remember one thing: We are at the infancy of this sort of science and yet we (industry and their government supporters) feel we already have solved everything and so we can now genetically manipulate every food source known to man without pausing for a period of reflection and (independent) review of the consequences. When people are amassing in protest at the levels that I observe today there is clearly something wrong with the picture. It is one litmus test that albeit not scientific – is clearly significant and cannot be ignored. Maybe not everyone is expressing themselves in the best and most accurate way (but neither are companies when they tell me that “nutrasweet” is good for me). GMO’s are not the panacea. They are a convenient (industrial, capitalist – these aren’t necessarily negative terms) step in a new paradigm of agro-chemical farming which I believe is unsustainable. I want to know about GMO’s in my food like I want to know where it comes from and how it was grown, farmed and by whom. There are health implications but also environmental and socio-economic (eg, fair trade). This is not an unreasonable request. I support companies and organisations who at least try to do this.
    Keep up the good work and debate!

  5. Stephan,
    I don’t think we are at the “infancy” of this science since it got started in the early 1970s and the first major conference on safety was in 1975. There is also lots of “pausing for reflection.” To have three regulatory agencies review each and every new product is extraordinary. There is no product that gets that sort of scrutiny. As for what is sustainable, I have been following that question for over 30 years and it is very clear what direction is sustainable. It is definitely not organic. I’ve summarized the conclusions from the leading, completely independent experts in these two posts
    Speaking of wanting to know where your food comes from. A great deal of organic now comes from places like China which is actually scary because of soils contaminated with heavy metals and a high frequency of mycotoxin contamination. There was a Hepatitis A outbreak recently because an Oregon berry producer who touts their localness sourced pomegranates from Turkey and exposed lots of customers who bought that at Costco. If you worry about your food, you should do it about inadequately regulated things like that, not the most regulated food in history

  6. Steve,
    I DO think it’s still at a state of “infancy”. Early 1970’s? 30 or 40 years?? for something that can potentially permeate every living being affecting our health and our environment? Yes, of course it needs a lot more time than that! And yes of course it needs all these agencies to review and approve it – again (intentionally repeating) because this affects human health from a consumption perspective, human health from an environmental perspective (eg, chemicals – this GMO stuff only works with all the agro-chemicals they have to pour on it – let’s not kid ourselves – they just happen to be mixed a little differently but they are just as bad (if not worse) than the other “traditional” chemicals) and the environment (pollution from agro-chemicals, gene-altered plants that cross pollinate and affect the ecology, etc…).
    I’ve actually spoken to a few farmers where I live and they say that it is not sustainable and I happen to concur with their observations: They are observing superweeds in GMO corn fields that they have been planting for over 10 years and are told by the supplier (in this case Monsanto) to not worry and just dump more chemical on them. Really?! Albeit only anecdotal I hear these sorts of stories more and more. I’m sorry Steve – but that is not the definition of sustainable. (There are social and ethical issues that also start to surface that we won’t go into now but also become relevant – bring on another agency I presume…).
    The whole thing about China is a mess – I agree. And we should be concerned. Clearly a problem of control and of a market that is taking advantage of consumers naivete. But they will eventually learn and shun their products as well and become even more paranoid demanding even more regulations of the industry making even that much more difficult for products to get to market… like GMO.
    There will always be issues of quality control and outbreaks of this and that – especially as we continue to increasingly mono-crop and have industry trying to achieve ever increasing economies of scale: industrial farming. I’m sorry it doesn’t take a rocket scientist to figure that out – nor an agriculture scientist for that matter! (But it does to confirm it in our current society). You can’t have ecology in a mono crop farm. Most (real) farmers understand this. You need a healthy environment/ecology to support a sustainable farm that provides good healthy food – sustainably.
    Don’t you feel we are slowly losing the plot? I do. Industry does not care enough about the intangible issues arising from their activities. For them it is about quantity and manageable time frames (eg, careers, money, shareholders). However, it is actually not about quantity but about quality. Those two terms get mixed up in the whole discussion – especially in North America I’ve observed. (fyi – I’ve lived in Europe for half my life). For example, here it’s about the bigger the zucchini the better (quantify = quality) as “I can serve more meals with it and feed more people!” where it really doesn’t taste anything like a zucchini where a small (organic) zucchini (in Europe) is much more tasteful and is packed with more nutrition then that big one (yes, scientifically proven)! We do have enough food to feed everyone btw. And we can have enough food… less (quantity), but better (quality), healthier food. And that equals healthier and happier people. Isn’t that what it’s really all about?
    I continue to be concerned about my/our food…

  7. Stephan,
    Food is more than just necessary for life, it can be a source of great enjoyment, particularly today when we have such diverse options. I am sincerely sad for you (and many others) because you are not able to simply enjoy food because you have bought into the full conspiratorial narrative of the Fear Industry. I find that the people who are most able to enjoy food are those that know the most about how it is produced and about the science. That is why I’m working on a book titled “Food Without Fear” to hopefully prevent others from going down the path you seem to have taken. My suggestion to you would be to grow all your own food so that you don’t have anyone to trust. You will find that its not so easy, that weather can be problematic, and that pests are real.

  8. I’m a member of those groups, but I am OK with your proposal with the addition on the label “modified with” to give the consumer the knowledge at the time of purchase. (ex: on yellow corn/modified with bt toxin)Just an example.
    Would your labeling suggestion satisfy SOME of groups that have been promoting labeling—- Probably not as there are many issues other people have that are not my own.
    What I do know that whenever a Label (if ever) becomes a reality, I will stop my promoting this problem because I do believe GE can “someday” benefit society. I cannot really speak for others.
    One more point the only people in California you need to salute for voting the proposition down in California are those in the Monsanto Camp. He tipped the scale to voters having 47% of the vote, after Monsanto dumped millions ? seven I think, at the last minute of the campaign. This “fixing” of the vote only helped more people in Ca
    to rear up against Big Ag.

  9. It is an interesting proposal Steve. I like it because it is simple, honest and provides information. Putting more information on a label is always a good thing and I’ve always supported that as a basis for labeling.
    The flip side is that while this is honest and simple, the activists are not. All you have to do is watch the websites where fear is cultured to harm public perception of good technology. And the honest ones among them will tell you over a beer that this is not about information about the food, but establishing a means to attack corporations.
    It is an important step in the Wedge Strategy.
    There is no scientific reason to add this information other than a group of angry people have decided it is important. I think we need to let science and evidence dictate policy. If this is important, then companies will do it voluntarily, which they already do with non-GM labels.

  10. Kevin,
    I don’t actually believe that there is any scientific reason to label, but it may be forced because of the substantial funding behind the efforts by those who would benefit from fear. That is why I thought I’m make the point that there has never been a more scrutinized food crop improvement in history.
    Someone could just as easily start a “label it campaign” for “Contains Food Raised With Byproducts of Animal Excrement,” or “Ingredients from Crops Treated with Heavy Metals,” or “Crops Imported from Countries with Highly Polluted Air Soil and Water,” for organic, or “Contains Ingredients That Have Not Been Regulated by the FDA” for something like Mercola’s supplements. In every case there would be far more scientific justification for such a label.

  11. “Would my labeling suggestion satisfy the groups that have been promoting “GMO labeling?” Probably not.”
    I support it.
    There is a very scientific reason to label – so that long term population studies can be done. There are any number of valid lines of research that are partially or entirely obviated when the population at large *does not know* if they have or have not been exposed to specific materials.
    With proper labeling, surveyors could start by asking study participants if they have knowingly consumed food containing genetically modified material – this simple, low cost step is prevented by lack of labels.
    Honest people that support GMO research, production and sales should support labeling. With the post you’ve made here, you’ve put yourself firmly in that group – well done!
    Corporate shills and dishonest people who fear the results of research will of course find ever-changing reasons to campaign against labeling.

  12. I generally like Steve’s approach to the labeling issue assuming we are going to get labels at some point. I can see marketing taking these labels even further. Why not mention that my Bt corn was potentially grown with less fuel, pesticide, water, and machinery than the neighboring product on the shelf? I understand that’s probably going to the other extreme of labeling something Gluten Free that never had gluten to begin with, but I feel like playing devil’s advocate for the sake of discussion.

  13. I wonder why GMO by default CANNOT be organic.
    Just writing that it contains GM DNA does not give you ANY information. It could be perfectly safe or perfectly toxic.
    Therefore I recommend introducing a new label: “organic GMO”.
    Maybe even a classification system like this:
    Contains recombinant DNA:
    Class 1 (“organic GMO): GFP (A.victoria), vitamin pathways, …
    Class 2 (herbicide resistance): roundup resistance
    Class 3 (“antibiotic resistance, toxins”): nptII (E.coli transposon).
    So that would give you the information that your gut bacteria cannot become resistant to antibiotics if you eat a GMO that only contains class1 and class2 genes. Not to mention horizontal gene transfer is unlikely, but it gives you valuable information.
    I would decide to only eat class1 because I know they’re perfectly safe. Class 2 in theory should also be ok, but you gotta draw a line somewhere.
    In conclusion, it would give you the information if you have a product only containing class1 genes, there will be no roundup/herbicide residues on the plant. That may be good for your health.

  14. Andreas, your last claim is wrong: [In conclusion, it would give you the information if you have a product only containing class1 genes, there will be no roundup/herbicide residues on the plant.]
    One of the agricultural uses of glyphosate is restricted to non-glyphosate-tolerant plants. The plants are sprayed with herbicide about a week before harvest, specifically to kill the crop so that the grain will dry out.
    I have to assume that the glyphosate residues on such a crop, with only a week to dissipate or degrade within a dead plant, would be greater than the residue on a crop sprayed several months before harvest, with months to degrade or dissipate in a living metabolizing plant.

Comments are closed.