How should cell-based meat be labeled? What 1,179 comments to USDA say about stakeholders’ priorities

As companies making meat from cells raise money, create prototypes and improve their technology, they are getting closer to having products to make available.

And that leaves a question hanging in the air: What can those products be called?

The USDA — which formally agreed in 2019 to jointly regulate products in the cell-based space with the FDA — put out a formal request for input in September. The department asked a battery of questions about how these products should be described on packaging labels, especially compared to animal derived products. Which terms work best for this type of product? Which terms would be misleading?

The comment period was open for two months. And in that time, 1,179 comments came in. 

Eighty-seven of them came from companies, trade groups, policy groups and international entities. State agriculture departments, companies involved with cell-based meat, traditional meat producers and an array of groups connected to the food industry commented. A total of 157 individuals left comments anonymously. One U.S. senator made his opinion known.   

And while the comments offered a wide variety of viewpoints on cell-based meat, one sentiment was nearly universally shared: These new products represent something new and different, and they deserve regulators’ attention and specific labeling.

Deepti Kulkarni, a partner at law firm Sidley Austin LLP who previously worked in the FDA’s general counsel office on agency oversight and regulatory pathways for new and emerging technology, said that the process of inviting public comments and using them to inform new regulations uses significant governmental resources. However, it signifies the importance of this new area. And the fact that questions about labeling drew more than 1,000 comments makes sense to her.

Future Meat Technologies’ pilot plant in Israel.

Courtesy of Future Meat Technologies


“That underscores the significant interest in these products and the technology,” she said. “That should not be surprising to anyone, right? What we feed ourselves and our families is a big part of our individual and cultural identity. And I think you see that in comments.

“Meat is a very big part of American culture, and so there’s a lot of people really interested and passionate about these issues,” Kulkarni continued. “At the same time, the world’s population is growing, and we understand more and more of the potential impacts of climate change. So a good number of people are reevaluating how and what they eat.“

Food Dive accessed, read and analyzed all of the comments that came in from companies, interest and industry groups, state and foreign government agencies and officials, and prominent individuals. All of these comments, complete with analysis on their preferred labeling terminology, can be explored in this tracker.

‘A direct threat’

The feelings about these products as reflected by the comments ran the gamut. While some were extremely supportive of the innovation cell-based meat represents, some were defensive about the threat the sector may pose to traditional animal agriculture.

Cell-based meat proponents are building an entire industry on the promise of removing the need to raise and kill animals from the food equation, and in doing so, avoid the livestock industry’s inherent environmental and ethical issues. The comments from those defending traditional agriculture are some of the most impassioned. 

“Laboratory manufactured proteins from cultured cells is a direct threat to the livelihood and economic well-being of U.S. producers nation-wide,” wrote Agri Beef, a small company of cattle producers. “Manufacturers of cultured cell proteins have a goal to not only replace traditionally raised meats but also demean and disparage the natural production process of traditional meats, while obscuring and withholding their process of production process to consumers.”

The North Dakota Farmers Union, made up of those in that state’s agricultural industry, agrees with that sentiment in its comments.

“Allowing products comprised of or containing cultured animal cells to be labeled ‘meat’ or ‘poultry’ would place family farmers and ranchers at a disadvantage because it will be difficult for them to differentiate their products from cultured animal cell products,” the group’s comments read. “Family farmers and ranchers want fair competition between their slaughtered meat and poultry products and products comprised of or containing cultured animal cells. Fair competition requires truthful and accurate product names and labels for products comprised of or containing cultured animal cells, which will allow consumers to make informed choices about their purchases.”

Cattle near Stoneville, South Dakota.

Cheung, Lance. (2021). “20210721-NRCS-LSC-0752” [photograph]. Retrieved from Flickr.


But not every agriculture industry commenter seemed opposed to the concept of cell-based meat. The American Farm Bureau Federation — an advocacy group which has members from all areas in agriculture — passed a policy that supports limiting common meat terms to products from slaughtered animals in 2019. While the group quoted from this policy resolution in its comments, it also noted that the comments were not an attempt to keep new technologies out of the marketplace.