By Margot Pollans
The Federal Food and Drug Administration is currently accepting public comment on the question of whether it should define the word natural. It is asking the wrong question.
The word natural is already all over your food packaging—on your cereal, on your milk carton, on your frozen dinner. What does it mean? Many consumers think it means the product is good for them and for the planet. In fact, producers slap the label on almost anything, and the FDA has not yet done anything to stop them. It is considering doing so now in response to loud calls for a uniform legal definition. But can a label actually help make food better for us and for the planet?
Probably not. But in recent years labeling has taken center stage as the regulatory tool of choice for the food system anyway. The fight over genetically modified organism labeling is a prime example, as both proponents and opponents have poured millions of dollars into state-level voter referendums and legislation. Just Label It, a pro-labeling advocacy organization, estimates that opponents spent $45 million to defeat California’s Proposition 37, which would have required labeling of all foods with GM ingredients. Vermont, Maine, and Connecticut have passed laws mandating GMO labels, and legislation is currently pending in many other states. Congress continues to explore options for federal labeling regulation; a recent bill that would have preempted mandatory state laws and created a voluntary scheme passed in the House but failed in the Senate.
Labeling is frequently applauded as less invasive than traditional regulation and more protective of consumer choice. The theory behind labeling as an alternative to direct regulation is that, armed with good information, consumers will make good choices for themselves and, if they want to, for the environment. Producers will respond to these market signals and produce healthier and more sustainable food.
But the food system is messy. Even the experts can’t always tell which food is healthiest. In the environmental context, assessing whether the local, organic option is better than a conventional imported product requires a complicated life-cycle analysis. It matters not only how many miles the item traveled to market and whether pesticides were used but also the farm’s soil conservation and runoff management practices, the fuel efficiency of the mode of transportation, the type of fertilizer used, the source of irrigation water, etc.. Most labels focus on one or two of these factors, arbitrarily prioritizing certain data points, such as whether a product was grown with pesticides, in the case of the organic label, over others, such as whether a farm practices sustainable crop rotation. In other words, “transparency” obfuscates.
The difference between natural and unnatural, like the difference between organic and conventional and GMO and GMO-free, is, itself, meaningless. These labels provide very little information either about how healthy the product is or about the size of its environmental footprint. Instead, these labels create opportunities for food producers to take advantage of the subset of consumers willing to pay more for perceived benefits. Indeed, the organic label is administered not by the U.S. Department of Agriculture’s Natural Resources Conservation Service or even its Food Safety Inspection Service but instead by the Agricultural Marketing Service.
Even if we assume labels can help consumers identify healthier or more sustainable foods, reliance on labeling to regulate the food system risks leaving some, or even most, consumers behind. Not only does it take money to buy truly high quality food but consumers must also have the time and resources to research the available options. Label advocates argue that transparency protects consumers’ freedom to prioritize. Some prioritize health, and others prioritize affordability. But is this a trade-off consumers should really have to make? Relying on transparency alone essentially creates two food systems: one that provides nutritious, safe, and environmentally responsible food to the wealthy; and a second, much larger system that provides chemical-laden food to everyone else, with dire environmental and health consequences.
Even more fundamentally, do we want consumers to be responsible for arbitrating this trade-off? Transparency burdens consumers with the responsibility to wade through reams of information armed only with their disposable income, such as it may be, as a means to fix massive systemic problems. More powerful food system actors—corporations that process, distribute, and market the vast majority of food eaten in this country and government agencies that regulate them—are off the hook.
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