In-Vitro Meat

 Fortification of IVM 

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Vitamins and Minerals

The FDA’s Fortification Policy is a "set of principles to serve as a model for the rational addition of essential nutrients to food. It must be stated that this policy only applies to “certain conventional foods," and, thus, does not apply to meat. However, this policy is cited and used under the USDA’s Food Safety and Inspection Service (FSIS) labeling requirements, and thus becomes applicable. 

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Based on these two regulatory guidelines, it is not recommended or appropriate to fortify meat with nutrient additives, such as vitamins and minerals (FDA). In other words, vitamins and minerals are not allowed to be added to meat to-date because there is no demonstrated need for fortification. If this policy is applied to IVM, IVM would not be allowed to be fortified with vitamins and minerals rendering the current fortification claims about IVM false. 

 

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Omega-3s

Under the FSIS Statement of Interim Labeling Guidance, the FSIS does not object to the addition of Omega-3 Fatty Acids as long as the safety of the product has been established. The addition of Omega-3s to meat is different from those of vitamins and minerals because unlike the addition of vitamins and minerals, Omega-3 Fatty Acids are not specified in the FDA’s fortification policy (FSIS Guidelines). 

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One has to keep in mind that what is considered to be a safe and nutritional amount of added Omega-3s to IVM remains to be determined, as well as the kind of Omega-3s and method of addition. Currently, Omega-3s are incorporated into meat through the supplementation in animal feed, which contains mostly alpha-linolenic-acid (ALA). With IVM, a new method of incorporation will have to be designed where the cells can uptake the omega-3s. Once this method is determined, safety testing will have to be conducted.

 

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Antibiotics

Antibiotics are commonly used in today’s meat industry "to treat, prevent, and control animal diseases and increase the productivity of animals and operations" (Sneering et al., 2015). However, there has been concern about how this use may be contributing to antibiotic resistance both in humans and animals. One of the claims behind IVM is that it will reduce the use of antibiotics in meat production: the mass number of cattle will no longer be needed, growth will be promoted in the laboratory, and the spread of disease will be significantly reduced as production will be done in a sterile environment. 

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It is likely that the use of antibiotics will be allowed for the production of IVM, if necessary. Currently, antibiotics are not needed, but other chemicals and products will be used in order to keep a sterile laboraty environemnt. 

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Growth Hormones

The use of steroid hormone drugs, including natural and synthetic estrogen, progesterone, testosterone, in beef cattle has been approved by the FDA since the 1950s (Steroid Hormone, 2015). Given the allowed use of growth hormones today, growth hormone usage will most likely be approved for IVM.

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 Packaging and Labeling 

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False and Misleading Information

The Food, Drug and Cosmetic Act (FD&C) prohibits the sale of food that is misbranded, meaning that the label cannot contain false or misleading information (Guidance, 2015). Under this policy, the FDA finds labeling to be misleading if "it fails to reveal facts that are material in light of representations made or suggested in the labeling" (Guidance, 2015). Currently, genetically engineered (GE) crops and food do not have to be labeled as bioengineered or GE, bringing up the question whether the same standards will hold for IVM.

 

One way to approach this, is to keep in mind the "false and misleading information" portion of the FD&C Act. This section, as well as the requirement to label a product as "natural," suggest that IVM should be labeled in a way that informs consumers that the product was produced using biotechnology. The exact phrasing would be the producer's choice, but one can go with the direct phrases of "Cultured Meat" or "In Vitro Meat."

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"Natural" Label

IVM will not be allowed to be labeled as "natural" under today’s labeling laws. The reason for this is that meat "products labeled 'natural' cannot contain any artificial flavor or flavoring, coloring ingredient, chemical preservative, or any other artificial or synthetic ingredient," all of which are necessary for the production of IVM (Beef from Farm to Table).  

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"Healthy" Label  

In 2006, the FSIS announced that "individual meat and poultry products bearing the claim 'healthy' (or any other derivative of the term 'health') must contain no more than 480 milligrams (mg) of sodium (Rules and Regulations, 2006)." In such case, the labeling of a product as "healthy" is dependent solely on the amount of sodium it contains, and not on any other nutrient. If this requirement is met by producers of IVM, then it could be labeled as "healthy." However, one has to keep in mind that the possibility of IVM being treated as a biotechnology and not a meat product, per se, which may change the application of this rule. Nonetheless, it is interesting to note how this rule’s basis of "healthy" can be perceived as misleading, as it does not take into account amounts of saturated fats or the whole meat product. 

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Omega-3s Label 

This is a tricky one. Under the FIFS Statement of Interim Labeling Guidance, the source of the Omega-3s on the meat must be disclosed ("e.g., 250 mg Omega-3 Fatty Acids per serving from fish oil in breading"). The reason for this is because omitting the source of Omega-3s creates the impression that the meat is the source of the substance (FSIS). However, in the case of IVM, IVM will be the source of Omega-3s, and thus the source may be omitted from the label. The presence of the substance must be disclosed, though, and the amount of Omega-3 fatty acids per serving must be labeled. 

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