Perception of Society To GE Foods

Volume 9 // Number 3 // Article 5
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Perceptions of Genetically Modified and Organic Foods and Processes

Jon C. Anderson
Minnesota Crop Improvement Association
Cheryl J. Wachenheim
North Dakota State University, Fargo
William C. Lesch
University of North Dakota, Grand Forks
Both organic production and the use of biotechnology have increased dramatically over the past
decade. This study contributes to existing work on consumer acceptance of these practices and
the resulting products through the use of twin survey instruments. Respondents indicated their
level of agreement with statements about genetically modified (GM) or organic processes and
products in the construct areas of health, environment, ethics, and risk. Organic food was
perceived as healthier and safer. Organic practices were perceived to be more environmentally
sound. Respondents expressed some level of concern over the unknown effects genetic
modification could have on the environment and society as a whole. However, participants in
general felt the technology could be used effectively and valued some of the associated benefits.
Key words: Environment, genetically modified, health, organic, perceptions, risk.
Introduction
Consumers in industrialized countries enjoy a plethora of food choices, with increasing

availability of both organic products and those resulting from biotechnology. Genetically
modified (GM) crops were first made available in 1996 to producers for use in major crops.
Since introduction, production has exploded. In 2005, 124 million acres of biotech crops were
grown in the United States alone (James, 2005). An estimated 61% of all corn and 89% of all
soybeans planted in the United States in 2006 were GM (National Agricultural Statistics Service
[NASS], 2006). As a result of the rapid adoption of GM technologies, a majority of processed
food products in the United States are thought to include GM ingredients (Hallman, Hebden,
Aquino, Cuite, & Lang, 2003).
Similarly, the organic industry has also continued to grow and organic products are now
common in retail food stores (Govindasamy, DeCongelio, & Bhuyan, 2005). Two-thirds of US
consumers report using organic products, and 27% report being regular (weekly) users (The
Hartman Group, 2002). The industry is expected to continue to increase its current annual growth
of over 20% and reach $30 billion in sales in the United States by the year 2007 (Scheel, 2004).
1
Both GM and organic foods and ingredients are thus increasingly available to consumers and for
use by firms producing food products. The irony on the GM side is that growing segments of
consumers seemingly want or potentially value a product that does not contain GM ingredients
while producers have been producing record volumes of GM commodities and, with few notable
exceptions, processors have been using them without substantial market reaction. The challenge
on the organic side is that consumer-level organic markets are growing, but production and
processing are more expensive and the organic identity of the resultant food products must be
maintained. There is a growing demand for organic food products, even at a premium price
(Oberholtzer, Dimitri, & Greene, 2005), but the additional cost of supplying them must be met
by increased market premiums (Hill & Lynchehaun, 2002). And, there is some evidence that
price sensitivity for organic foods may be high at retail stores, at least for some food categories
(Glaser & Thompson, 2000).
A growing body of literature examines acceptance of and willingness to pay for non-GM and
organic food products but it is still relatively limited and is often too general to be of much
practical use or it is proprietary. And, to date, public domain research is limited which allows for
direct comparison of attitudes about GM and organic foods and processes. This area of inquiry is
particularly interesting because one of the unique attributes of, and one reason consumers may be
moving towards, organic food is the absence of GM ingredients in them (Dhar & Foltz, 2005;
Larue, West, Gendron, & Lambert, 2004) and there is some evidence that attitudes about organic
foods can be a useful indicator of attitudes about GM foods (Burton, Rigby, Young, & James,
2001). Comparing attitudes about GM and organic foods and processes is the objective and
major contribution of the current study.
Background
It is estimated that 95% of total retail sales of organic food products occurs in the United States
and the European Union (EU) (Dimitri & Oberholtzer, 2005). A review of selected literature
from these markets provides insight into what motivates and what impedes the purchase of
organic foods and thus aids in identification of relevant construct areas for consideration.
Examination of the literature on purchase motivators associated with non-GM food products
focuses on the US market where products containing GM ingredients are much more
commonplace.
Organic Food Market
The market for organic foods in the United States continues to rapidly grow, while it is relatively
mature in other areas, particularly in parts of Western Europe.
Evidence from Europe
2
The EU actively promotes growth of the organic sector (Dimitri & Operholtzer, 2005).
Government subsidies and industry promotion have lowered price premiums (Thompson &
Kidwell, 1998) and there is a higher level of consumer awareness than that found in the United
States.
Grunert and Juhl (1995), Land (1998), and Wier and Andersen (2003) investigated organic
purchase motivators in Denmark. Grunert and Juhl found willingness to pay for organic foods to
be directly related to attitudes about, and behaviors reflective of, a concern for the environment.
Land found consumers chose organic food because of associations with better health and
improved taste, and that consumers considered "pesticide free" to be an important attribute of
organic foods. Wier and Anderson found organic buyers to be mainly concerned about health
and considered the absence of chemical residues to be the most preferred product attribute of
organic food. Animal welfare, food origin, and environmental issues were also found to play a
role in organic food purchasing decisions.
Hack (1993) identified the two primary motives for purchasing organic food products among
Dutch consumers to be health and beneficial impacts on the environment. Four major
impediments to the consumption of organic food were identified. Organic food was less familiar
to consumers, generally not as available as its conventional counterpart, much more expensive,
and perceived to be of lesser quality.
Bugge and Wandel (1995) investigated purchasing motives for organic food among Norwegians.
The main purchasing motive for all users was health concern. The primary constraints were
identified as insufficient information, availability, and price. Among consumers in the United
Kingdom, Latacz-Lohmann and Foster (1997) found health and food safety to be the two
primary motivators for consumption of organic food.
Hill and Lynchehaun (2002) found health to be the (overwhelming) reason consumers were
using organic milk. Taste and the perception organic production is better for the environment
were also important. Makatouni (2002) also found the perceived healthfulness of organic food to
be the main contributor to purchase, followed by the perception that organic food promotes a
higher degree of animal welfare. Consumers were also concerned about negative environmental
impacts when artificial fertilizers and chemicals were used in food production.
McEachern and McClean (2002) identified the top three purchase motivators for organic dairy
products in Scotland to be taste, food safety, and health benefits. Respondents also noted
environmental benefits and ethical considerations. As in other studies, price was identified as the
primary deterrent to organic food purchases.
Evidence from North America
3
A number of studies have considered organic food markets and how demographic characteristics
influence likelihood-of-purchase and willingness-to-pay for organic foods in the United States
(e.g., see Thompson & Kidwell, 1998; Huang, 1996; Byrne, Toensmeyer, German, & Muller,
1991; Misra, Huang, & Ott, 1991). Those reviewed here have also considered purchase
motivators.
Goldman and Clancy (1991) found that organic food purchasers frequenting an up-state New
York cooperative were concerned about pesticide residues and the effects those residues may
have on their health. Their primary reasons for purchasing organic food were food safety,
protection of the environment, and the promotion of sustainable agricultural practices.
Jolly (1991) found that California consumers buying organic food were concerned about health
and how it may be jeopardized by the presence of pesticides in their food. High prices and poor
availability were two stated obstacles. These same obstacles were also identified by Buzby and
Skees (1994) among Kentucky consumers.
Byrne, Bacon, and Toensmeyer (1994) and Groff, Kreidor, and Toensmeyer (1993) surveyed
Delaware residents. Byrne et al. concluded that consumers wanted organic produce because of its
perceived safety and higher nutritive value, because associated with it were fewer harmful effects
on the environment, and due to a desire for an increased level of societal control over the quality
of the food supply. Groff et al. found the most important factors affecting organic food
consumption were freshness, healthfulness, flavor, nutrition, and food safety.
Swanson and Lewis (1993) found organic food purchasers in Alaska to be primarily motivated
by environmental and personal safety concerns. Organic food purchasers were more concerned
about pesticide residues than non-purchasers. Overall, organic produce was perceived to be more
expensive and less visually attractive.
Sloan (2002) identified health and nutrition as the main drivers behind the purchase of organic
foods. Most organic users reported believing that organic products contribute to their overall
health, rather than associating them with any specific health effect. Consumers were found to be
very aware of chemical residues on their food, and a large number of consumers were found to
seek out organic products specifically to avoid GM ingredients. Another important driver of
organic food consumption was the perceived effect of production on the environment, with
organic users more concerned about the environment and pollution than the general population.
Organic food users felt that their food purchases would make a difference in helping sustain a
healthy environment. The Hartman Group (2002) identified health and nutrition, taste, food
safety, and environmental impact (in this order) as the most important motivators. Govindasamy
et al. (2005) identified health and safety as the most important purchase motivators for organic
produce.
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Overall, motivating factors for purchase of organic food products do not differ substantially
between US and European consumers. Dimitri and Oberholtzer (2005) note that, like their US
counterparts, European consumers have shifted to self-interest motivations such as food safety
and health, although they note that there sometimes seem to be important regional differences in
the importance of motivating factors. Price is noted as the primary deterrent in both the United
States and the EU.
The Market for (non) Genetically Modified Foods
Consumer attitudes about biotechnology have been assessed since its initial commercialization
(e.g., see Hoban, 1997). For reviews of the literature on consumer acceptance of GM food
products, see Wachenheim (2004) and Ganiere, Chern, and Hahn(2006). Although there is
considerably more recent literature on consumer attitudes and intentions regarding GM versus
organic food, less effort has been devoted to identifying specific purchase motivators. More
carefully investigated have been consumer attitudes about and willingness to pay for non-GM
foods, and the effect of various actions (e.g., media exposure) on such.
In general, we know that some Americans appear to have a basic understanding of biotechnology
and may recognize that it has been used in food production, but that most are unaware of its
prevalence in the US food supply (Hallman & Hebden, 2005; Thomson & Dininni, 2005). While
the specifics differ, in general the literature concurs that Americans have very little knowledge
about biotechnology. For example, Hallman et al. (2003) found that only one-fourth of US
residents believed that they had ever consumed food containing GM ingredients. The lack of
consumer awareness is not particularly surprising. Food product labels in the US do not indicate
either presence or a lack of GM content (Hallman & Aquino, 2005). Thus, unless it is an organic
product, consumers have no information about the product's GM content (Ganiere et al., 2006).
It is also very well accepted that biotechnology is supported among consumers to a much greater
extent for use in crops rather than animals (Ganiere et al., 2006). For example, Hallman et al.
(2003) reported that one-half of Americans approved of plant-based genetic modification, where
only one-quarter approved of it for use in animal agriculture. The literature also supports an age-
old marketing guideline: consumers want benefits not features. Americans have a much higher
acceptance level of GM products if certain benefits can be associated with its use, such as safer
or more nutritious food (Wachenheim & Lesch, 2004; Lesch, Wachenheim, & Stillerud, 2005).
And, there is some evidence that Americans believe genetic modification can and will make their
lives better (Hallman et al., 2003). However, in general there is also concern about the use of
biotechnology, and when queried, most support labeling of products containing GM ingredients
(e.g., see Hallman & Metcalfe, 2001; Onyango & Nayga, 2004; Wachenheim & Lesch, 2004).
5
In part because of the current lack of labeling, again, there is little literature specifically
assessing purchase motivations associated with GM foods. However, the potential motivators
that will arise as technologies develop and consumers become more informed will likely mirror
those of the organic industry. Acceptance will probably be related to perceptions of the benefits
and risks associated with human health and the environment (Larue et al., 2004; Moon &
Balasubramanian, 2001; Onyango & Nayga, 2004). And, while perceptions about risk generally
have not been considered with regards to organic production practices or food consumption, the
literature suggests that perceived risk and ethical considerations are important for acceptance of
biotechnology.
Consumer perceptions of organic processes and products and those involving biotechnology
warrant further investigation and especially comparison. The concept areas of interest identified
from the literature include health, environment, risk, and ethics. Past work has compared demand
for organic and GM products (e.g., Larue et al., 2004; West, Gendron, Larue, & Lambert, 2002),
and considered how demand for GM products is affected by organic food use classification
(Burton et al., 2001). To our knowledge, no study has directly elicited comparable attitudes about
organic and GM products and processes. That is the most important contribution of the current
study.
Methods
A written survey instrument was administered to students at two upper Midwestern universities
in the United States. The sample was drawn from undergraduate general business classes as well
as those in agribusiness. Students from one graduate course in organizational behavior were also
included. While we do not argue the sample population is representative of any group beyond its
definition, in a meta-analysis of findings of consumer acceptance of GM foods, Lusk et al.
(2005) found that student populations did not differ from more general populations in their
acceptance of GM products. However, the importance of market segments, particularly for
organic foods (e.g., Larue et al., 2004) requires we emphasize the limited population
participating in the current study.
Respondents were comprised of students in undergraduate classes in the subject matters of

general business (56% of respondents), introductory economics (31%), and statistics (8%), and
an MBA class on organizational behavior (5%). Fifty-five percent of participants were male.
Four percent were 18 years of age or younger, 51% were 19 to 21, 39% were 21 to 29, and 6%
were 30 and older. Ninety-two percent of respondents were undergraduates.
The instrument was built around the various constructs identified in the literature as related to
acceptance and purchase of GM and organic food products. These included health, environment,
risk, and ethical considerations. Participants were asked to indicate level of agreement with
6
statements using an 8-point Likert scale ranging from 1 (strongly agree) to 8 (strongly disagree).
Participants were prompted to use 9 for statements about which they had no opinion. To allow
for direct comparison of perceptions about organic and GM foods and processes, each instrument
contained identical statements except for the use of the words organic and genetically modified
(GM). Both positively- and negatively-worded statements were presented within each construct
to reduce the potential for agreement bias. The resulting questions were randomly ordered
throughout the forms, but question order for both instruments was identical.
The introduction of each survey instrument included a brief primer defining (as appropriate)
genetic modification or organic concepts as follows:
What is organic food production? Organic production is a system of farming that

uses production methods which minimize the use of off-farm inputs. Certified
organic means that agricultural products have been grown and processed according
to the United States Department of Agriculture's national organic standards, and
certified as such. The requirements apply to the production process rather than
measurable characteristics of the product itself. Certifying agents review
applications from farmers and processors for eligibility, and qualified inspectors
conduct annual on-site inspections of their operations. Inspectors talk with
operators and observe their production and processing practices to determine if
they are in compliance with organic standards. Organic standards for crops require,
for example, that no prohibited substance be applied to the land during the
previous three years and that crops not be genetically modified. Those for livestock
require animals not be given hormones or antibiotics and that they have access to
the outdoors.
What is genetic modification? Genetic modification refers to the process of

modifying plants or animals by adding genes to change the makeup of the original
organism. The traditional plant development process uses cross breeding which
requires plants to be sexually alike, transfers and sorts all genetic material, and it
takes time. The genetic modification process moves genetic material from one
organism to another such as from bacteria to plants, animals to plants, and
between dissimilar plants. It produces plants or animals with desired characteristics
faster than classical cross breeding methods. Sometimes the process of genetic
modification is called bio-engineering, biotechnology, or genetic engineering.
7
All respondents were urged to read the primer prior to completing the survey. Two separate
samples were used in this design, one for each food condition. Data collection was conducted in
the spring and early summer of 2004. A total of 340 completed questionnaires were collected:
167 organic and 173 GM. As a result of the data cleaning process, 42 organic and 40 GM survey
respondent forms were eliminated from the final sample. Most of the eliminated responses
answered all questions identically or provided responses outside the identified range. Finally,
some questionnaires were deleted because responses were not internally valid (e.g., respondents
strongly agreed with two opposing statements).
SPSS (v 9.0) was used to analyze the data. Means and frequencies of each organic and GM
question were compared and are discussed within the relevant construct area. Parametric F tests
were used to compare means.
Results
Empirical results are presented by construct area. Responses to the organic forms are presented
first, followed by responses to the GM instrument. Results within each construct area are
compared.
Health
Organic
The average participant slightly, but not strongly, agreed with the positively worded health
attributes (e.g., organic food is healthier), and disagreed with the negatively worded health
attributes (e.g., organic food is less healthy) (Table 1). A near majority agreed that consumption
of organic foods can improve one's healthy appearance and that scientists believe health can be
improved by organic foods. There were more neutral responses that organic foods are useful in
preventing disease and that eating organic foods will increase lifespan, although there was a high
level of agreement that if organic technologies could cure disease, that would be a good reason to
use them. A majority disagreed that there was a danger associated with consumption of organic
foods, ranging from lower nutrition to an undefined "grave danger."
Table 1. Health statements.

Percentage*
Statement AB N Mean C Agree Neutral Disagree
Organic
Consumption can improve your
P 0.004 118 3.81 7 52.5 23.7 23.7
overall healthy appearance.
8
Scientists believe that health can be
P 0.479 95 3.82 29 48.9 33.0 18.1
improved by Organic foods.
I will live longer if I eat Organic
P 0.009 107 4.36 18 26.2 53.3 20.6
foods.
Overall health will decline if I
N 0.009 117 5.99 8 7.7 24.8 67.5
consume Organic food.
Organic baby food is not as healthy as
N 0.007 105 5.26 20 20.0 29.5 50.5
traditional.
Organic ingredients in food pose
N 0.000 114 5.47 11 11.4 34.2 54.4
hidden dangers to my health.
Regularly eating Organic foods will
N 0.000 111 6.03 14 9.9 18.0 72.1
harm my health.
Organic foods present a grave danger
N 0.000 110 6.23 14 8.2 20.0 71.8
to my health.
Diseases such as Parkinson's might be
P 0.223 120 2.29 4 85.8 6.7 7.5
cured.
Organic foods are useful in preventing
P 0.429 86 4.28 39 31.4 43.0 25.6
disease.
Organic baby food ingredients can
have nutrients not found in traditional P 0.271 94 4.04 29 40.4 36.2 23.4
food.
Organic ingredients improve the
P 0.249 113 3.65 11 47.8 38.1 14.2
nutritional quality.
Organic foods may combat our
N 0.417 114 4.36 11 36.0 35.1 28.9
nation's problem with obesity.
Foods contain fewer carbs and more
protein if they contain Organic N 0.923 69 5.01 56 23.2 42.0 34.8
ingredients.
GM
Consumption can improve your
P 0.004 108 4.55 19 28.7 39.8 31.5
overall healthy appearance.
Scientists believe that health can be
P 0.479 91 4.01 32 41.8 38.5 19.8
improved by GM foods.
I will live longer if I eat GM foods. P 0.009 93 5.00 30 16.1 45.2 38.7
Overall health will decline if I
N 0.009 113 5.38 16 17.7 28.3 54.0
consume GM food.
9
GM baby food is not as healthy as
N 0.007 111 4.57 17 27.9 43.2 28.8
traditional.
GM ingredients in food pose hidden
N 0.000 120 4.49 9.1 28.3 42.5 29.2
dangers to my health.
Regularly eating GM foods will harm
N 0.000 102 4.92 24 23.5 38.2 38.2
my health.
GM foods present a grave danger to
N 0.000 107 5.30 20 15.0 35.5 49.5
my health.
Diseases such as Parkinson's might be
P 0.223 131 2.55 2.2 78.6 14.5 6.9
cured.
GM foods are useful in preventing
P 0.429 91 4.08 32 30.8 53.8 15.4
disease.
GM baby food ingredients can have
P 0.271 101 3.74 25 49.5 33.7 16.8
nutrients not found in traditional food.
GM ingredients improve the
P 0.249 110 3.90 17 44.5 36.4 19.1
nutritional quality.
GM foods may combat our nation's
N 0.417 110 4.15 18 40.0 35.5 24.5
problem with obesity.
Foods contain fewer carbs and more
N 0.923 64 5.05 52 14.1 53.1 32.8
protein if they contain GM.
Column A: P = positively worded statement and N = negatively worded statement.
Column B: Significance is based on parametric f-test (2 tailed).
Column C: Number answered "Don't Know" or "No Opinion."
* Agree is 1-3, Neutral is 4-5, and Disagree is 6-8 on the 8-point Likert scale.
Organic food was generally thought to have higher nutrient values than traditional food. Forty
percent agreed that organic baby food has nutrients not found in traditional baby food and 48%
agreed that organic food can improve the nutritional quality of convenience foods.
Genetically Modified
The average response about the healthfulness of GM foods was generally neutral. Respondents
did not agree that they would live longer if they ate GM foods, but most agreed with, or were
neutral to, the statement that GM foods are useful in preventing disease. And, most respondents
agreed that an appropriate use of GM technology would be curing diseases. Interestingly, 80%
agreed or were neutral that scientists believe that health can be improved with GM food, which
was nearly the same percentage as organic. Most respondents did not agree with statements
describing potential dangers associated with GM foods.
10
Forty-five percent of participants agreed that GM food improves the nutritional quality of foods,
while only 19% disagreed. Half of consumers agreed that GM baby food can have nutrients not
found in traditional baby food. However, 71% agreed or were neutral with respect to the
assertion that GM baby food is not as healthy as traditional baby food. There are some apparent
inconsistencies in respondent perceptions of the nutritional quality of GM foods, perhaps
associated with the polarity of the statements.
Potential benefits were reported for GM foods. However, in general, participants did not see GM
food to be as healthy as its traditional counterpart nor did they feel very strongly about the health
attributes associated with GM food. The more negatively worded questions elicited a higher level
of disagreement, suggesting that participants did not see GM as unhealthy, but rather as
somewhat less healthy than traditional food.
Comparison
Results of the present study do not contradict previous work identifying health-related concerns
associated with GM food products. However, there were smaller than expected associated
perceptual differences between GM and organic foods and processes. Both were thought to have
higher levels of nutrients than traditional food. They were seen as appropriate if they had
potential to help cure diseases, although the average levels of agreement that GM or organic
foods are in fact useful in preventing disease or combating obesity were neutral and were not
different from one another.
Participants perceived organic food products to be more closely linked to positive health
attributes than GM foods, with a relatively low range of unsure responses. As expected, organic
food was perceived as healthier than traditional food, and in general, the healthfulness of GM
foods was not perceived to be substantially different than that of traditional foods. Seven of the
eight statements directly associated with health had mean levels of agreement that were
statistically different. Participants generally more strongly agreed with the positive health
attributes and more strongly disagreed with the negative health attributes of organic food than
those of GM food.
Environment
Organic
The findings of this study concur with earlier findings that the organic process of producing food
is perceived as advantageous for the environment. For example, participants agreed that organic
production uses less pesticides and disagreed that more chemicals are used than with traditional
production methods (Table 2). Participants may have known or learned from reading the primer
11
that organic production does not allow the use of pesticides. It is interesting to note that
participants also agreed that production with biotechnology uses less pesticides. Respondents did
not agree that organic production reduces erosion.
Table 2. Environment statements.

Percentage*
Organic
The balance of organisms is better
P 0.009 111 4.54 14 28.8 41.4 29.7
managed by humans using Organic.
Organic will use lesser amounts of
P 0.091 113 3.19 12 63.7 19.5 16.8
pesticide.
Production of Organic crops reduces
P 0.914 90 4.67 34 25.6 41.1 33.3
unnecessary erosion of farmland.
Organic use will forever change our
N 0.000 112 4.51 13 25.0 48.2 26.8
natural environment.
Organic will introduce new organisms
N 0.000 97 5.46 28 12.4 40.2 47.4
that may harm our society.
I am worried about unknown effects. N 0.000 120 4.84 5 29.2 31.7 39.2
The balance of nature has been upset
N 0.000 112 5.60 13 12.5 35.7 51.8
by the use of Organic production.
It takes more chemicals to raise
N 0.006 102 5.85 23 13.7 26.5 59.8
Organic crops.
GM
The balance of organisms is better
P 0.009 117 5.19 16 20.5 36.8 42.7
managed by humans using GM.
GM will use lesser amounts of
P 0.091 99 3.65 35 51.5 33.3 15.2
pesticide.
Production of GM crops reduces
P 0.914 82 4.70 51 23.2 46.3 30.5
unnecessary erosion of farmland.
GM use will forever change our natural
N 0.000 113 3.41 20 48.7 45.1 6.2
environment.
GM will introduce new organisms that
N 0.000 95 4.17 39 35.8 41.1 23.2
may harm our society.
I am worried about unknown effects. N 0.000 129 3.64 4 51.2 31.8 17.1
The balance of nature has been upset N 0.000 109 4.68 25 26.6 39.4 33.9
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by the use of GM production.
It takes more chemicals to raise GM
N 0.006 90 5.11 44 20.0 41.1 38.9
crops.
In terms of the environment and genetic modification, there is a high level of public
disagreement amongst various stakeholders. Biotechnology companies and producers generally
hold that the use of GM in the production of food is advantageous to the environment, while
environmental and several consumer advocate groups often argue the contrary. However, the
literature confirms the notion that consumers are unaware of the potential benefits of GM to the
environment (e.g., Hoban, 1997; Wachenheim & Lesch, 2004).
In the present study, findings in general neither support nor refute GM production as having an
environmentally negative impact in the eyes of respondents. There seems to be some concern
about the unknown long-term effects of the use of GM varieties in production agriculture. Fifty-
one percent of respondents agreed that they are worried about the unknown effects that GM will
have on our ecosystem. Half agreed that GM will forever change our natural environment and
36% agreed that GM will introduce new organisms that may harm our society.
Comparison
Generally, consumers perceive organic food production as environmentally friendly, while

production involving GM varieties is perceived as less so than production of traditional food
(Sloan, 2002). The current findings do not refute this, but the perceptions among the participants
were more neutral than expected. With one exception for which there was no difference, for each
positive statement about the effect of organic production on the environment, level of agreement
was stronger than for GM (i.e., participants felt that organic food production is more
environmentally friendly than its GM counterpart). The same was true for each negative
statement, in that level of disagreement was stronger for organic than for GM. However, in this
study, agreement with benefits of GM was stronger than in most other work, and the perceived
concerns regarding GM were more moderate than expected.
Risk
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Risk is inherent in food consumption and today, more than ever, US consumers are exposed to
information about those risks. Although there is evidence that Americans trust regulators to
protect the safety of their food, consumers' risk perception of different food classes (e.g., organic
and GM) may affect their willingness to buy. Several different levels of risk are considered,
including general risk, consumption risk, long-term effects of the use of production practices on
society, and the risk to plants and animals.
Organic
Slightly more than half of respondents agreed that there is little risk in the consumption of
organic foods, organic foods are completely safe to eat, and that they would be willing to serve
organic food to their friends (Table 3). Sixty percent of participants disagreed that it is dangerous
to use organic production techniques to alter what we eat. Seventy-five percent of participants
disagreed that eating organic foods will subtract from their quality of life.
On average and in general, participants also did not have strong concerns about organic
production. Two-thirds disagreed that organic foods will harm society more than help it.
Seventy-five percent agreed or were neutral that organic foods hold no danger for future
generations. Although 42% agreed that animals such as organic sheep and cattle may change the
overall gene pool, only 10% agreed that raising organic species is dangerous to the gene pools. In
general, most perceived little risk associated with the consumption or production of organic
foods, although there were respondents who did perceive risk, especially longer-term risk.
Table 3. Risk statements.

Percentage*
Organic
I see no risks in the consumption of
P 0.000 115 3.44 10 52.2 34.8 13.0
Organic foods.
I would be willing to serve Organic
P 0.042 116 3.45 9 55.2 30.2 14.7
foods to my friends.
Organic foods are completely safe to
P 0.007 117 3.61 7 55.6 24.8 19.7
eat.
The risks to people associated with
N 0.001 97 5.90 28 10.3 25.8 63.9
Organic foods outweigh the benefits.
Consumption of regular foods is far
P 0.003 107 4.75 17 27.1 37.4 35.5
more risky.
Raising Organic animals holds no P 0.000 108 4.40 17 32.4 40.7 26.9
14
potential danger to other species.
Scientists cannot predict the future
N 0.007 112 3.96 13 47.3 31.3 21.4
outcomes of Organic.
Organic foods present no danger for
N 0.000 102 4.18 23 35.3 40.2 24.5
future generations.
Organic will harm society more than
N 0.001 123 6.01 2 10.6 22.8 66.7
help.
Eating Organic foods will subtract
N 0.011 120 6.23 5 11.7 13.3 75.0
from my quality of life.
It is dangerous to use Organic to alter
N 0.002 116 5.52 9 13.8 26.7 59.5
what we eat.
Production of Organic crops could
harm other species in ways we do not N 0.000 114 4.61 9 29.8 40.4 29.8
understand.
Animals such as Organic sheep and
cattle may change the overall gene N 0.000 105 4.12 19 41.9 31.4 26.7
pool.
Raising Organic species is dangerous
N 0.012 106 5.41 18 10.4 39.6 50.0
to the gene pools of those species.
GM
I see no risks in the consumption of
P 0.000 16 4.43 16 32.8 37.1 30.2
GM foods.
I would be willing to serve GM foods
P 0.042 13 3.95 13 40.0 40.0 20.0
to my friends.
GM foods are completely safe to eat. P 0.007 21 4.30 21 35.4 40.7 23.9
The risks to people associated with GM
N 0.001 35 5.03 35 22.2 36.4 41.4
foods outweigh the benefits.
Consumption of regular foods is far
P 0.003 27 5.50 27 13.2 33.0 53.8
more risky.
Raising GM animals holds no potential
P 0.000 30 5.04 30 19.2 37.5 43.3
danger to other species.
Scientists cannot predict future
N 0.007 17 3.29 17 56.4 30.8 12.8
outcomes of GM.
GM foods present no danger for future
N 0.000 30 5.08 30 17.5 40.8 41.7
generations.
GM will harm society more than help. N 0.001 10 5.15 10 21.0 33.9 45.2
15
Eating GM foods will subtract from my
N 0.011 10 5.62 10 16.1 28.2 55.6
quality of life.
It is dangerous to use GM to alter what
N 0.002 15 4.77 15 26.9 32.8 40.3
we eat.
Production of GM crops could harm
other species in ways we do not N 0.000 13 3.41 13 51.2 38.8 9.9
understand.
Animals such as GM sheep and cattle
N 0.000 12 3.29 12 55.7 38.5 5.7
may change the overall gene pool.
Raising GM species is dangerous to the
N 0.012 22 4.39 22 26.1 48.6 25.2
gene pools of those species.
Risks are a more prevalent concern with regard to GM foods and processes. This may be due to
the overall lack of knowledge of GM varieties and their products (Wachenheim & Lesch, 2004).
Average levels of agreement indicating a perceived risk associated with GM foods and their
production were higher than for organic food. However, the level of perceived risk was less than
may be expected given the findings from the literature and the content of popular press stories.
Level of consumption concern associated with GM foods was mixed. For example, one-third of
participants agreed that there is no risk in consumption of GM food, while 30% disagreed.
Thirty-five percent agreed that GM foods are completely safe to eat; 24% disagreed. Forty
percent agreed they would be willing to serve GM foods to their friends; 20% disagreed.
Participants were asked how GM will affect themselves and others. Only 21% agreed that GM
will harm society more than help it, but 42% disagreed that GM holds no danger for future
generations. Only 16% agreed that eating GM foods will subtract from their quality of life. Risks
in general appeared to be viewed on the aggregate versus individual level (e.g., a higher
percentage agreed that GM foods are dangerous, than agreed that eating GM foods will subtract
from the quality of their own life).
There is a perception that GM may change nature, but it depended on statement wording.
Responses to three statements indicate concern. More than half agreed that GM crops could harm
other species in ways we do not understand. Fifty-six percent agreed that genetic modification in
16
animals such as sheep and cattle will change the overall gene pool of those animals. And, 43%
disagreed that GM animals hold no potential danger to other species. Somewhat to the contrary,
only one-quarter agreed that the use of genetic modification is dangerous to the gene pool, albeit
nearly half were neutral.
Respondents perceived GM foods as possessing a higher level of risk than other classes of food.
As expected, most disagreed (54%) or were neutral (33%) that consumption of regular food is far
more risky. A certain level of uncertainty was apparent in the relatively higher percentage of
neutral and no opinion responses as compared to the organic survey. In terms of the risks to
society and the world surrounding them, participants, in general, saw a higher level of risk than
they saw for themselves. Participants did not appear to be frightened of GM foods, but rather
uncertain about their potential and more widespread effects.
Comparison
There has been a relatively small amount of work done with regard to perceptions about the risk
associated with organic food, but the conventional notion is that organic food is seen as a safer
alternative than traditional food. In contrast, research and popular understanding supports a
perceived risk associated with GM foods and production of those foods.
Indeed, organic foods and processes were perceived to be less risky than their GM counterparts.
Fewer participants felt that GM food is safe to eat and participants were less willing to serve GM
food than organic. However, respondents did not associate strong risks with GM food. Rather,
they saw GM as a process with uncertain effects. The means for every question within the risk
construct were statistically different for the GM and organic versions. Mean levels of agreement
were stronger for organic with positively worded statements, and mean levels of agreement were
weaker for organic with negatively worded statements.
Ethics
Organic
Social acceptability is one motive driving the purchase of organic food. This was examined using
the construct area of ethics. As expected, there was little ethical objection to organic food.
Eighty-seven percent of those questioned agreed or were neutral that organic crop production is
the right thing to do (Table 4). Few agreed that organic production was not morally acceptable or
that it was unethical to use organic methods to conduct research. The strongest level of
agreement with negatively worded statements are for the five that do not explicitly mention the
term organic.
17
Table 4. Ethics statements.
Percentage*
Organic
Animals have the basic right to exist
without the manipulation of their P 0.534 122 3.90 3 48.4 28.7 23.0
genes.+
Improving crop production by using
Organic methods is the right thing to P 0.148 113 3.76 12 41.6 45.1 13.3
do.
Introducing Organic into livestock
gene pools improves the quality of life P 0.079 113 4.34 12 34.5 38.9 26.5
of animals.
Scientists are fulfilling moral
obligations to society by improving P 0.002 114 4.15 11 39.5 37.7 22.8
food.
Organic is not morally acceptable. N 0.012 118 5.39 7 12.7 41.5 45.8
Changing the makeup of animals is not
N 0.202 120 4.95 5 25.8 34.2 40.0
morally acceptable.
It is inhumane to enhance livestock by
N 0.009 121 5.60 4 14.0 26.4 59.5
Organic means.
It is unethical for scientists to conduct
N 0.024 121 6.01 3 7.4 25.6 66.9
research.
Scientists are playing God when
N 0.751 123 4.85 2 33.3 26.8 39.8
altering the genes of plants.+
N 0.877 118 4.37 7 40.7 28.8 30.5
altering the genes of animals.+
Plants have the right to exist without
N 0.850 120 5.03 5 30.0 26.7 43.3
manipulation by humans.+
Crops should only be enhanced by
N 0.767 121 4.32 4 41.3 25.6 33.1
natural means.+
Organic foods threaten the natural
N 0.000 113 5.48 12 13.3 38.1 48.7
order of things.
Organic will harm future generations. N 0.001 108 5.57 16 13.0 30.6 56.5
Humans should not meddle with the
N 0.650 117 4.45 7 26.5 45.3 28.2
natural order of plants and animals.+
18
GM
Animals have the basic right to exist
without the manipulation of their P 0.534 123 3.74 11 48.8 34.1 17.1
genes.+
Improving crop production by using
P 0.148 119 4.08 14 37.8 42.9 19.3
GM methods is the right thing to do.
Introducing GM into livestock gene
pools improves quality of life of P 0.079 117 4.76 16 28.2 35.9 35.9
animals.
Scientists are fulfilling moral
obligations to society by improving P 0.002 121 4.85 12 21.5 40.5 38.0
food.
GM is not morally acceptable. N 0.012 118 4.75 15 27.1 37.3 35.6
Changing the makeup of animals is not
N 0.202 122 4.61 12 31.1 36.9 32.0
morally acceptable.
It is inhumane to enhance livestock by
N 0.009 126 4.95 8 23.0 33.3 43.7
GM means.
It is unethical for scientists to conduct
N 0.024 131 5.50 3 13.7 33.6 52.7
research.
N 0.751 130 4.77 4 29.2 30.8 40.0
altering the genes of plants.+
N 0.877 127 4.33 7 33.9 34.6 31.5
altering the genes of animals.+
Plants have the right to exist without
N 0.850 128 4.98 6 32.0 24.2 43.8
manipulation by humans.+
Crops should only be enhanced by
N 0.767 131 4.40 3 40.5 23.7 35.9
natural means.+
GM foods threaten the natural order of
N 0.000 118 4.29 16 29.7 44.9 25.4
things.
GM will harm future generations. N 0.001 109 4.77 25 22.9 42.2 34.9
Humans should not meddle with the
N 0.650 123 4.56 10 30.1 39.8 30.1
natural order of plants and animals.*
19
+ Statement did not indicate GM or organic.
Respondents also did not have major ethical objections to GM food. For example, 38% agreed
that improving crop production by using GM is the right thing to do, while only 19% disagreed.
As found in the literature, participants perceived the use of GM in plants as more acceptable than
use in animals.
Comparison
Although respondents had fewer ethical objections to organic processes, they seemed to not have
major ethical objections to either GM or organic food. Ethical objections were aroused when
discussing animals in both organic and GM food; GM food had higher levels of objection. Seven
of the 15 statements' means regarding ethics were found to be different. Higher levels of
agreement for the positively worded questions were present for organic than for GM. Also,
higher levels of disagreement for the negatively worded questions were present for organic than
for GM.
There was no difference in average level of agreement between the organic and GM survey
responses for any of the statements that did not explicitly mention organic or GM. Each dealt
with the rights of animals or plants.
Other Considerations
Some tested statements did not fit well into the above-referenced construct areas. Table 5
summarizes these responses. Half of participants agreed that plants can benefit from organic
processes while nearly the same amount (45%) agreed with regard to GM processes. When asked
if animals can benefit from these processes, a lower but similar level of agreement between
organic (33% agreed) and GM (31% agreed) was found.
Table 5. Other consideration statements.

Percentage*
Organic
The tools of Organic production may
prompt our breakthrough in the P 0.000 111 4.07 13 39.6 41.4 18.9
understanding of life.
Animals can benefit from Organic. P 0.344 107 4.10 15 32.7 48.6 18.7
20
Plants can benefit from Organic. P 0.524 111 3.69 14 49.5 37.8 12.6
Organic animals speed up the process
P 0.797 102 4.76 22 21.6 45.1 33.3
of change.
Quality of life can be improved by
P 0.134 113 3.73 12 49.6 35.4 15.0
using Organic.
Foods have the ability to enhance the
P 0.514 115 3.85 10 41.7 43.5 14.8
quality of our lives.
It is okay to use Organic if it improves
N 0.013 121 3.05 4 62.0 27.3 10.7
the lives of other people.
Organic lowers costs, therefore it is
N 0.714 122 4.23 2 39.3 36.1 24.6
okay.
GM
The tools of GM production may
prompt our breakthrough in the P 0.000 127 3.24 6 63.8 29.9 6.3
understanding of life.
Animals can benefit from GM. P 0.344 112 4.32 21 31.3 41.1 27.7
Plants can benefit from GM. P 0.524 122 3.84 12 45.1 36.9 18.0
GM animals speed up the process of
P 0.797 109 4.83 24 22.9 37.6 39.4
change.
Quality of life can be improved by
P 0.134 113 3.42 21 52.2 38.1 9.7
using GM.
Foods have the ability to enhance the
P 0.514 118 3.72 16 40.7 46.6 12.7
quality of our lives.
It is okay to use GM if it improves the
N 0.013 125 3.58 9 44.8 44.0 11.2
lives of other people.
GM lowers costs, therefore it is okay. N 0.714 129 4.32 4 31.8 38.0 30.2
Column A: P = positively-worded statement and N = negatively-worded statement.
When asked if the tools of production will prompt breakthroughs in the understanding of life
processes, 64% agreed for GM but only 40% agreed with regard to organic. Surprisingly, only
23% agreed that GM processes only speed up the process of change (nearly an equal percentage
for organic).
21
The use of GM or organic technologies to help people was found to be, on average, acceptable.
Forty-five percent of participants agreed that GM is okay to use if it improves the lives of other
people (62% for organic). Fifty-two percent agreed that GM can improve the quality of life (50%
for organic). When asked if it is okay to use the production process to lower the cost of foods,
32% agreed with GM and 39% agreed for organic.
Discussion and Implications
General Attitudes Towards GM and Organic Food Products
Organic food was perceived by respondents to be, in general, a healthier alternative to "regular
food," including its effect on appearance and resulting from higher nutrient levels. This supports
one of the primary marketing foci used by the organic industry, the purported health benefits
associated with organic food. Respondents were found to be less critical of GM food than was
expected. The sample population used in this study was generally neutral to the perception of
GM food with regard to its effect on health.
Environmental benefits to organic production were perceived. For example, organic food
production was perceived as reducing pesticide use. Alternatively, some respondents expressed
concern that GM food may have unknown effects on the environment. However, perceptions of
several of the proclaimed advantageous effects of biotechnology on the environment were also
found to hold (e.g., GM food uses less chemicals). Overall, organic food and its production were
perceived to be environmentally appropriate, as expected. An unexpectedly large percentage of
respondents believed there to be environmental benefits to using biotechnology in production
agriculture as well.
Organic food was seen as a safer alternative to traditional food by respondents. Although a
higher level of risk was associated with GM foods than traditional foods, this risk did not appear
to affect personal behavior. Specifically, respondents tended to agree that there were unknowns
involved in the GM process that elevate the risk associated with the food. However, given the
possibilities (some of which were altruistic) of GM's potential, respondents agreed it should be
used. Participants did exhibit more concern about the "big picture" in terms of GM food. They
identified risks associated with the aggregate (e.g., risks to society), but did not feel personally at
risk.
The role that ethics plays on consumers’ decision-making process was interesting. The literature
states that one of the reasons consumers choose organic food is that they believe it is the
responsible thing to do (Byrne et al., 1994; Goldman & Clancy, 1991). On the other side of the
spectrum is GM food. Few respondents had ethical objections to organic food. On the other
hand, possible unknown consequences had students concerned about GM food. The use of
22
biotechnology to enhance plants was much more favorable than its use in animals, consistent
with existing literature.
Implications to Stakeholders
Many members of the food industry marketing channel have an interest in the perceptions of
consumers with regard to GM and organic foods. This sample of college students helps provide a
look into the future.
For those supporting the use of biotechnology, the findings are favorable. It is sometimes argued
that consumers will not accept GM foods. This common notion was neither supported nor
refuted in the present case. However, college-age consumers did not possess the expected strong
negative feelings about GM foods or processes. In fact, they often saw beneficial possibilities.
The most notable concern of consumers with regard to GM foods was the unknown effects. They
are unsure of what will happen generations down the road, but do not appear concerned enough
to change their present behavior. More information is necessary about the long-term effects to
address these concerns; this will come from additional research. The management of this
information to influence consumer perceptions and behaviors will be important. Identifying and
developing powerful and targeted food attributes, then linking the same to specific benefits
sought by consumers should be undertaken. In short, one or more segments of consumers have
yet to decide. Those who are interested in the future of GM would benefit from giving
consumers favorable reasons to accept the technology.
Organic food stakeholders should also be encouraged with the findings. Credence attributes
associated with organic food are well-entrenched in the minds of consumers, even college-age
consumers. Organic food was thought to be more nutritious and healthier, to improve one's
appearance, and be more environmentally friendly. In general, organic food production had
virtually no negative perceived effects, although there was a small segment of students who held
beliefs contrary to the mainstream. It is not possible to identify why (e.g., uninformed,
misinformed, against organic production practices) from the current study. Further opportunities
should be explored in the distribution of organic food. The organic industry could capitalize on
the generally favorable perceptions, particularly in the area of health. For example, by "selling"
the benefits of organic food to institutions, such as school lunch programs and elderly care
facilities (in particular those that are concerned about the healthfulness of the food they are
providing) and to health care professionals who influence the attitudes and behaviors of others.
Environmental perceptions of GM food in this study are surprisingly unrevealing. There were no
strikingly adamant reactions towards the environment and GM food. However, much of the
relevant literature identifies chemical residues in food as a major issue to consumers. Therefore,
GM stakeholders would benefit from stressing the fact that GM food uses fewer chemicals than
23
more traditional production practices in their integrated marketing communication (if, in fact,
that is the case). Any other environmentally advantageous benefits should be prominently
communicated to consumers. The organic food industry also needs to do a better job of
addressing the issue of chemical residues. Thirty-six percent of participants were neutral or
disagreed that organic food production uses less pesticides. That is a rather substantial number
especially after they were asked and expected to read a primer stating that no artificial chemicals
were used in the production of organic foods. The absence of chemicals in the production of
organic food can be better highlighted and showcased. Still, many consumers do not know or
understand what organic food or GM food is comprised of, or how it may benefit them directly.
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In This Article
Table 1
Table 2
Table 3
Table 4
Table 5
References
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Oregon State University outreach in biotechnology
28
______________________________________
_______
Study Guide to the FOOD FOR THOUGHT lecture:
Public Perceptions of Genetically Modified Foods
Americans Know Not What They Eat
Presented by William Hallman at Oregon State University 12 October 2006
Slides and streaming video available at http://agsci.oregonstate.edu/orb/events
The production of this series of study guides by Megan McKenzie of Outreach in
Biotechnology was made possible
through funding by The American Society of Plant Biologists.
About the speaker
Bill Hallman is an Associate Professor in the Department of Human Ecology and an
Associate Director of
the Food Policy Institute at Rutgers University in New Brunswick, New Jersey. In a
project that involves
more than 30 investigators and graduate students from diverse disciplines across
multiple institutions,
Hallman is studying consumer perceptions of food biotechnology – especially GE
foods. Hallman’s focus
is the effects and impacts of human food choices on the environment and on
individuals and communities.
Terms
Biotechnology: the collection of industrial processes that involve the use of
biological systems – biotech
is commonly used to brew beer, produce antibiotics, and improve food crops and
livestock through
breeding. For some industries, these processes involve the use of genetically
engineered organisms.
Genes: molecules that carry inheritable instructions for making proteins in the cells
of living organisms.
The proteins coded for by genes determine an organism’s traits, or characteristics.
Interestingly, some
genes serve only to switch other genes on and off, and don’t make a protein
product at all.
DNA: The genes of all organisms consist of DNA. Even though organisms are very
different, they all use
similar proteins in their metabolic pathways, and they use similar genes to encode
these proteins.
29
Scientifically speaking, it’s what the DNA makes that matters, not where the DNA
comes from.
Genetic modification: a change in an organism’s genes made through selection,
hybrid breeding,
mutagenesis, or genetic engineering.
Hybrid breeding: producing a hybrid animal or plant by breeding two animals or two
plants of different
species or varieties to rearrange the genetic material between populations or races.
Hybrids are produced
because they have desirable characteristics not found or inconsistently present in
the parent individuals or
populations. Breeding companies sometimes use hybrids to protect intellectual
property.
Mutagenesis: a process by which the genetic information (DNA) of an organism is
changed in a stable
manner, either in nature or experimentally using chemicals or radiation.
Genetic engineering: a change in an organism’s genes made using recombinant
DNA technology. A
genetically modified/engineered organism is called a GMO. (More often than not, GE
crops are referred to
as GM crops, but this is a bit of a misnomer, since all GE crops are GM, but not all
GM crops are GE!)
Recombinant DNA technology: a series of procedures used to join (recombine) DNA
segments.
This technology makes it possible to take a gene from any species and place it into
almost any other
species.
Take-home messages
Hallman’s group performed a series of national surveys in 2004 to assess and
monitor American consumer
knowledge, awareness, and perceptions of food biotechnology. His goal was to aid
the agricultural
community in their understanding of factors driving consumer attitudes toward food
biotechnology; to
inform policy makers of the concerns and needs of consumers; and to help in the
design and delivery of
appropriate educational and outreach materials. His results indicate the following:
Americans remain unaware of and not very knowledgeable about GE foods.
o Most are still unsure about how they feel, but they are interested in the topic.
Because most Americans have not made up their minds, their opinions are:
o Often equivocal
o Highly malleable
o Sensitive to:
30
How questions are worded
What the technology is called (GM, GE, Biotechnology)
Which organisms are involved
The intended purpose of the product
Descriptions of potential benefits or risks.
The good news is:
o There is still an opportunity to have a dialogue.
The bad news is:

o If people hold uncrystallized opinions, they are open to manipulation.
o Most people lack the information they need to separate fact from fiction.
Throughout his talk, Hallman explained the survey questions people were asked and
explored their
answers. We’ll focus on a few segments, so that your total watching time is about
20 minutes – begin by
viewing part of the intro on streaming video (slide 11, video segment 9:40-10:40).
Read each question below before you watch the selected segment on streaming
video.
Questions
Short answer/fill in the blank
1. Hallman points out that most people don’t know which foods on the market are
GE and which are not.
Name two foods commonly misperceived to be GE, and name the two most
common GE foods. (slides
22-24, streaming video 21:50-24:50)
2. Hallman points out that it’s human nature not to let being uninformed “stand in
the way of having an
opinion.” He suggests, therefore, that public opinions about GE foods “actually
represent
___________.” (slides 28-29, streaming video 25:30-27:36)
3. Hallman jokes that even people who said they didn’t like the abstract idea of GE
plants, did like the
idea of GE grass that doesn’t need mowing. He uses this example to make the point
that “how you
present the question largely determines the _______ you get back”. (slides 37-38,
streaming video
31:00-34:45)
4. When people were asked if foods containing GE ingredients should have labels
indicating this, about
90% answered yes. However, when asked what information they’d like to see on
food labels, fewer
than 1% said that GE ingredients should be listed. Which website cited the former
result, and which
sighted the latter? (slide 42, streaming video 34:45-37:30)
31
Group activity
When consumers were given an 11-item true/false quiz about basic concepts
related to genetics and GE
food, the average person got fewer than half the questions right.
Working in groups of four, fill in the following table, and then discuss the answers as
a class. Consider
how an understanding of these concepts (or a lack thereof) might affect consumer
response to media
coverage. (slides 79-80, streaming video 57:30-1:00:10)
Question Correct answer (T/F) Why is that?

By eating a GE fruit, a person
person’s genes could also
become modified.
The mother’s genes
determine whether a child is
a girl.
GE animals are always bigger
than ordinary animals.
It is not possible to transfer
animal genes into plants.
Tomatoes modified with a
gene from catfish would
probably taste fishy.
Cloning produces genetically
identical copies.
More than half the human
genes are identical to
chimpanzees.
Scientists sometimes
genetically modify plants so
that they cannot reproduce.
Larger organisms have more
genes.
Most of the soybeans grown
in the US are of a genetically
modified variety.
GM corn is required to be
kept separate from non-GM
corn.
32
Genetically engineered crops and foods: back to the basics of technology
diffusion
,
C. Wagner Weick and S. B. Walchli
Eberhardt School of Business, University of the Pacific, Stockton, CA 95211, USA
Available online 6 September 2002.
Genetically engineered crops and foods have been accepted in the marketplace at an impressive
rate since their introduction in the mid-1990s. However, the future of these products, and the
many agricultural and food products still under development, has become cloudy. To understand
how the use of genetic engineering has arrived at this juncture and where the technology might
go in the future, this article returns to a time-tested model from the past. Everett Rogers’ five
factors of diffusion provide insight into the variety of influences—technical, ethical, political,
economic, cultural, health, and environmental—that have encouraged and discouraged the global
diffusion of genetically engineered crops and foods. The analysis sets the stage for a discussion
of how the barriers to diffusion might be overcome in the future through new product
development, increased study of health and environmental impacts, improved management of the
global marketplace, labeling, and making important distinctions between genetic modification
and genetic engineering.
Article Outline
1. Introduction
2. The five factors of technological diffusion
2.1. Factor one: relative economic or social advantage
2.1.1. The relative advantages of genetically engineered seed and food products
2.1.2. The relative disadvantages of genetically engineered seed and food products
2.2. Factor two: compatibility with existing values
2.3. Factor three: complexity of the idea
2.4. Factor four: divisibility
33
2.5. Factor five: observability
2.6. The effects of the five factors on the diffusion rate of genetically engineered
foods
3. Strategies to overcome barriers to diffusion
3.1. Directions in new product development
3.2. Actively study and monitor health and environmental impacts
3.3. Recognize and manage global markets
3.4. To label or not to label
3.5. What’s in a name?
Economic Impacts of Genetically Modified Crops on the Agri-Food Sector
4. Consumers, retailers: cascading effects
The demand can be analysed at the level of consumers, the retailing industry, and food processors. Of
these three actors, the retailing industry has a pivotal position by amplifying consumer preferences and
relaying them to the food industry. Whether retailers choose to label products containing GMOs, eliminate
GM ingredients from own-label food, or go GM-free, their approach has cascading effects on food
processors, grain companies, and ultimately on farmers. Today, the organisation of the world food market
more and more reflects the variable public opinion and power of civil society groups from one region to
another and their unequal influence on supermarket chains.
The main argument of this chapter is that the global food market is undergoing a reorganisation which
transcends the European context, where public awareness and debate of GMOs first emerged. European
retailers' restrictive stance on GMOs is giving birth to a bifurcated market leading food processors to
adapt their products to regional conditions, and US grain elevators to segregate commodities.
The chapter first surveys consumer preferences in different regions of the world through an overview of
available public opinion studies and mobilisation campaigns (section 4.1). The second section explores
the strategy of the retailing industry as evidenced by their degree of anticipation and the nature of their
reactions (section 4.2).
4.1. Consumers : moving fast
34
It has become customary to contrast North American consumers' perceptions of GMOs with those
of European consumers. While Americans and Canadians would hold benevolent views or simply
be indifferent, European consumers would display more scepticism for reasons which are said to
be: cultural (degree of faith in science, relation to food.), historical (recent food scares in Europe),
and political (degree of trust in public/private actors).
This dichotomy reflects clear regional cleavages, yet needs qualifying for at least three reasons.
First, civil society groups have early on organised global, transregional mobilisation campaigns
against GMOs. Second, some differences that once appeared readily between European and
North American public opinions have eroded with time. Finally, the two blocks overlap only
loosely with geographic boundaries. Not all European countries share the same concerns over
GMOs; conversely, some countries outside Europe-Australia, New Zealand-have joined in the
mobilisation against transgenic food.
4.1.1. Mobilisation campaigns
Public controversy over GMOs crystallised in the middle of the 1990s, as the first GM crops
were being harvested. Mobilisation emerged at the global level around the "Pure Food
Campaign," later known as the "Campaign for Food Safety." At the core of these campaigns,
international NGOs such as Greenpeace, Friends of the Earth, RAFI and others co-ordinated the
movements and set up discussion fora and comprehensive GMO databases on the internet
(Examples can be found in the internet database referred to in the bibliography). At the local
level, grassroots participated in the campaign: women's networks, environmental groups,
consumer associations, farmers, and youth.
The "Global Days of Action Against Gene-Foods" organised in the spring 1997 evidenced the
transnational, and multi-faceted character of mobilisation. Table 4.1 illustrates the regional and
political diversity of this campaign. According to the organisers, "activists from twenty-seven
nations organised actions and press events against gene-foods and genetic engineering" (Pure
Food Campain, 1997). In addition, the interests represented in this campaign ranged from the
promotion of sustainable development, to the protection of consumers, through the advancement
of ethical considerations with regard to genetic research.
35
Table 4.1 Global Days of Action Against Gene-Foods, April 13-27, 1997
(source: Pure Food Campain, 1997)
36
37
Global mobilisation against GMOs has continued ever since, sometimes with spectacular
actions. A second "Global Days of Action Against Genetic Engineering" took place in October
1997. In February 1998, the "Physicians and Scientists Against Genetically Engineered Food"
issued a declaration in which they demanded a "moratorium on the release of Genetically
Engineered organisms and the use of GE-food" (Physicians and Scientists Against GE Food
1998). In September 1999, activists from thirty countries (Latin America, North America, Asia and
Europe) launched a lawsuit against major biotech companies, claiming a multi-billion dollar
compensation for monopolistic practices (Financial Times, 13 September 1999). A month later,
Monsanto CEO Robert Shapiro announced the decision of his company "not to pursue
technologies that render seed sterile." The decision, a testimony to the power of organised
movements, was "based on input from you and a wide range of other experts and stakeholders,
including our very important grower constituency" (Open Letter from Robert Shapiro, 4 October
1999).
NGO mobilisation on issues raised by biotechnology was also strong in the context of the WTO
Ministerial meeting in Seattle in November/December 1999. Specific actions were organised in
Montreal in January 2000 in the event of the conference for the Protocol on Biosafety (see
chapter 5).
While protest against GMOs acquired a global dimension, interest groups and NGOs intensified
their pressure in three regions: in Europe, in Australasia, and in North America. The most notable
differences between these regions pertain to the timing of mobilisation-Europe was the first
mover-and the degree to which counter-mobilisation has organised (table 4.2). Counter-
mobilisation was stronger in North America where it centred around the agri-food business and
some scientist communities. On the other hand, there was little counter-mobilisation in Europe15.
This difference appeared clearly in the public hearings on GE foods organised by the FDA this
year, where participants described the European "scientific establishment.[as] less protective of
genetic engineering. [than] their US counterparts" (Congress Daily, 1/12/99).
38
Table 4.2. Sample of Recent GMO Actions in Europe, North America, and Australasia
4.1.2. Evolving Public Opinions

Mobilisation campaigns at the global and at the regional level display the salience of
biotechnological issues among interest groups and NGOs. Yet, the level of activism on GMOs is
an imperfect indicator of public perceptions as knowledge and concerns may not reach the larger
public. Public opinion polls and surveys show that the global mobilisation around GMOs masks
contrasting "moods" in North America and Europe. While consumers in Europe and Australasia
are unambiguously suspicious of genetic engineered food, North American consumers'
perceptions are much less clearly characterised. Until recently, the global mobilisation around
GMOs was thus anchored on more fragile bases in North America. There, the discourse against
transgenic food found only limited resonance with the public at large for reasons which have yet
39
to be researched. However, one must be cautious as the public debate is emerging in the US and
may be moving closer to the European debate.
In Europe, data can be found in the Eurobarometer studies on biotechnology, which provide
comparative data across countries; and in a series of surveys conducted by private polling
institutes for the retailing and food industry, NGOs, or the media. This corpus of studies
evidences some differences among European countries, with Italians, Spaniards, and Portuguese
displaying more positive perceptions of biotechnology in general than their fellow Europeans
(Eurobarometer 1997 and 2000; Menrad 1999).
Beyond these variations, clear regularities emerge:
o High level of concern: A large majority of Europeans is worried about transgenic food.
More than 60% of the 1997 Eurobarometer respondents are concerned about the risks
associated with GM food, compared with 40% in the case of the medical applications of
biotechnology. This result is consistent with those of private polling institutes16. The 2000
Eurobarometer has helped assessing the reasons for consumer concerns on GM food.
Items gaining the highest support are: "even if GM food has advantages, it is against
nature"; "if something went wrong, it would be a global disaster"; "GM food is simply not
necessary". The share of respondents thinking that food production is a useful application
of biotechnology decreased from 54% (1997) to 43% (2000).
o Knowledge and perception: Perceptions tend to "crystallize" with the degree of
knowledge. Both pessimism and optimism increase with the degree of knowledge of
respondents (Eurobarometer, 1997). This is consistent with a recent survey showing that
"the level of knowledge and familiarity with [biotechnology]. are not so decisive in shaping
general attitudes" (Menrad, 1999). According to the 2000 Eurobarometer, the use of
biotechnology in food production is the most commonly known application. However, only
11% of the respondents feel adequately informed on biotechnology. Factual knowledge
has hardly improved since 1997. Asked about the source of information they mainly trust,
respondents cite consumer organisation first (26%), just ahead of medical profession
(24%) and environmental protection organisations (14%). International organisations and
national public authorities record poor results (respectively 4 and 3%).
o If knowledge is not a key variable, "cultural factors seem to prevail in shaping personal
attributes towards modern biotechnology. the attachment of consumers to their national
food traditions is seen as an important factor in the process of acceptance of food
technology" (Menrad, 1999).
o Demand for labelling and non-GM: Only 18% of the respondents judge GM labelling
useless; 8% do not have an opinion; and 74% favour a clear labelling of GM food
(Eurobarometer 1997). 53% of the respondents say that they would pay more for non-GM
food, 36% would not (Eurobarometer, 2000).
For North America, the main surveys stem from the USDA, Novartis (1997), Time magazine
(1999), the International Food Information Council (1999) and some Canadian organisations. Two
broad tendencies emerge:
o Eroding trust in GM food: A 1995 USDA study of 604 New Jersey residents found that
60% would "consider buying fresh vegetables if they were labelled as having been
40
produced by genetic engineering" (Center for Food Safety, 1999). In 1997, Novartis found
that only 25% of Americans "would be likely to avoid labelled GE foods". Yet two years
later, the poll commissioned by Time magazine indicated that 58% of American
consumers "would avoid purchasing [labelled GE foods]" (Center for Food Safety, 1999).
These results show a certain erosion in the consumers' trust in GM food17.
o Demand for labelling: In the last four years, the demand for mandatory labelling of GE
foods has been high, and fairly stable: 84% of the respondents favored it in the 1995
USDA study; 93% in the 1997 Novartis survey; and 81% in the Time magazine poll. In
Canada, a 1994 survey showed that "83% to 94% of Canadians polled. want labelling on
foods that are produced using biotechnology" (Center for Food Safety 1999).
This cursory review is sufficient to stress the contrast between European and North American
perceptions of agricultural biotechnology. While Europeans are critical of GM foods and wish to
keep them at bay as long as detailed studies of the risks have not been conducted, North
American consumers have placed greater confidence in agricultural biotechnology. Recently
however, changes have been visible in US consumers' perceptions. North American consumers
have lent a more critical support of this research, and they have clearly mandated GE labelling.
The recent public hearings on GE labelling organised by the FDA have kick-started the public
debate. The turn-out was high (Financial Times, 18 November 1999), and debates have shown
"little middle ground" between the representatives of civil society, the industry, and scientists
(Detroit News, 19 November 1999). Protesters have staged media-oriented demonstrations
outside the conferences, and seized the coincidence of the second FDA hearing with WTO
ministerial meeting in Seattle (November, December 1999) to attract world media coverage.
These trends have put pressure on retailers and the food industry.
4.2. Retailing industry : following and shaping the demand
The retailing industry is the linchpin in the food market due to its proximity with consumers. Over
the last years, a global concentration process has increased the market power of retailers. The
first point of contact between consumers and the food industry, retailers do more than simply
transmitting consumer preferences to food processors and grain elevators. They amplify or
moderate market signals, contain or anticipate consumer expectations. Whatever their strategy, it
has cascading effects on the rest of the food industry at home and abroad.
The contrasts in regional mobilisation described above have had direct consequences on the
strategy of retailers. While European and Australasian retailers have early on been faced with
vehement protest against GM food, their North American counterparts have not been exposed to
direct consumer pressure. As a result, European retailers have moved to meet and shape the
demand for non-GM food, in contrast with the "wait-and-see" approach adopted by the bulk of
North American retailers.
4.2.1. Amplifying consumer preferences
Supermarket chains first moved in the UK, where Friends of the Earth organised in 1997 a
campaign against the introduction of GM foods in supermarket (see Friends of the Earth
Supermarket Letter). Given the absence of regulation of GM food, retailers were pressed to take
quick actions, probe consumer preferences, and anticipate the development of a non-GM food
market. Sainsbury's commissioned a consumer survey in the very early stages of grassroots
mobilisation. This move earned the retailer "congratulat[ions from Friends of the Earth] on
41
carrying out and publicising this timely and valuable research" (AgBiotechNet, 1997). Food and
Biotechnology Campaigner for Friends of the Earth Adrian Webb declared: "Sainsbury's promotes
itself on providing 'good food'. All the major retailers should now act on these findings" (Friends of
the Earth Press, Release 1997). This domino effect did take place and UK supermarket chains
unveiled their plans on GM food one after the other, starting with Sainsbury's and Iceland (May
1998), Tesco (September 1998), and other major food chains. In fact, a leaked Monsanto report
showed that the move towards adopting a restrictive stance on GMOs was well under way at the
end of 1998, retailers being determined to resist the introduction of GM foods18.
The movement spread to continental Europe in 1999. In March, Sainsbury's announced the
formation of a consortium with six European supermarket chains to organise the supply chain:
Carrefour (France); Delhaize (Belgium); Esselunga (Italy); Marks & Spencer (UK); Migros
(Switzerland) and Superquinn (Ireland) joined in. In May, Spain's biggest retailer, Pryca,
announced its policy, followed by Rewe in July; Edeka (under the pressure of Greenpeace) in
August; and Aldi in October 1999 (the list is not exhaustive).
In the Netherlands however, the biggest retailer, Albert Heijn, is a notable exception to this trend.
In 1997, the Dutch supermarket chain took a proactive stance to enhance consumers' acceptance
of GMOs. In one of its free monthly brochures, the chain advertised GM soya as having the same
quality as conventional soya. The Dutch Natural Law Party brought the case before the
Advertisement Code Commission for "false and misleading advertisement" (Campaign to ban
genetically engineered foods, Press Release 1997) and won it. On that occasion, the
environmental organisation noted that "In contrast with the food retailers in some other countries
the Dutch branch forms a closed front, which in fact is against the interests of its customers"
(Campaign to ban genetically engineered foods, Press Release 1997).
By the end of 1999, many European supermarket chains have thus adopted a restrictive policy on
GM food. Contrary to common views, they did not align on a single non-GM model. Rather, they
adopted various types of actions.
4.2.2. Types of supermarket actions
Faced with legal uncertainties on GM food labelling19 and growing popular pressure to phase out
GMOs, retailers have adopted different strategies. Table 4.3 illustrates the variations that
currently exist between chains' policies on GM food20. Some supermarket chains, like Sainsbury's
and Marks & Spencer, have adopted fairly comprehensive strategies whereby they commit
themselves to phase out GE ingredients from their own-label products and eventually to sell non-
GM fed meat. Other supermarkets, like Asda and Safeway, have chosen narrower policies to
eliminate GE ingredients in their own-brand products, but also label own-brand products for which
they have not been able to do so.
Table 4.3. Some Examples of Supermarket Actions on GMOs
42
This table combines three axes along which supermarket chains' actions can be differentiated:
o Group v. individual initiatives: Group initiatives, such as the Sainsbury consortium or

the GM-free working group, enable group members to share the burden of reorganisation
of the supply chain and give them additional weight with respect to the food processing
industry. On the other hand, individual initiatives are likely to diminish the negotiating
power of the chain with regard to food processing.
o GM labelling v. non-GM labelling: some chains have opted for labelling products
containing GMOs (Safeway; Asda), others for labelling non-GM products (Leclerc).
o Choice v. no choice: some supermarkets allow GM-labelled foods (Safeway; Asda);

others will not sell products labelled as containing GMOs (Adeg; BML; Hofer). Yet, other
like Aldi and other discount chains do not officially exclude GM labelled foods, but give
the consumer little choice as own-label products, from which they have eliminated GMOs,
represent 90% of their product range.
Given the current state of affairs, this review is necessarily incomplete. Yet, it displays the variety
of actions deployed by European supermarket chains. Options exist beyond the "choice", "no
choice"; however, the general tendency of chains is to phase out GM food. Given the
transnational character of supply chains, the restrictive stance of European supermarkets has
triggered a reorganisation that transcends Europe. Food processors and grain companies have
been hard pressed to segregate GM from non-GM products and regionalize their production.
Public reactions to information about genetically engineered

foods: effects of information formats and male/female
differences
43
Wei Qin
RM 213 Borland Lab, Food Science Department, Penn State University, University Park, PA 16802, USA, e-mail:
[email protected]
J. Lynne Brown
Food Science Department, the Pennsylvania State University
Developing effective communication strategies to inform the public about genetic engineering
applications in food production is critical for the successful commercialization and future
development of the technology. However, few existing studies in the United States have
examined how communication materials affect public understanding of new technologies. Our
survey study examined the effect of two information formats developed according to public issue
education principles on the public understanding of, interest in and attitude towards genetically
engineered salmon. In addition, we examined male/female differences in attitude. Our results
indicated that participants who read the "consequence" information learned more, expressed
more interest, and indicated higher level of actual confidence in judgment than those who read
the "perspective" information. Women were less approving of genetically engineered salmon
than men were both before and after reading the information. Reading information led to a
positive change in attitude although the effect size was not different between sexes. The
male/female difference was likely due to women's higher level of concern about effects on
humans and greater trust of environmental groups compared to men's. Suggestions for designing
an effective print communication about a specific genetic engineering application are presented.
Public Understanding of Science, Vol. 16, No. 4, 471-488 (2007)

DOI: 10.1177/0963662506065336
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Center for Food Safety comments to Environmental Protection Agency on

allergenicity of Cry34Ab1 (Bt)
Center for Food Safety
March 1-2, 2005
47
The Center for Food Safety
outlines its disagreement
with the EPA whether
Bacillus thuringiensis,
a popular component of
many genetically
engineered crops, causes allergies.
48
Comments to the Scientific Advisory Panel Evaluating
Cry34Ab1/35Ab1, March 1-2, 2005, Docket No. OPP-2004-
0395
- by Doug Gurian-Sherman, Ph.D.
Center for Food Safety (CFS)a appreciates the opportunity to comment on the
allergenicity assessment of Cry34Ab1, and more generally on allergenicity risk
assessment for genetically engineered (GE) crops at EPA.b CFS also commends EPA
for conducting this SAP as part of continuing efforts to better understand the risks of
GE crops, and thanks the panelists for taking time from their busy schedules to
provide this public service. Our comments are in three parts: 1) a general
introduction, 2) some background on food allergenicity assessment for GE foods,
and especially the gastric stability assay, and 3) our assessment of the potential
allergenicity of Cry34 and whether EPA should register this protein.
We disagree with EPA’s preliminary finding that Cry34Ab1 is unlikely to be an

allergen. We believe, as discussed in more detail below, that available data suggest
that EPA cannot conclude with a “reasonable certainty” (the legal standard) that no
harm will occur if Cry34/Cry35 corn is registered. In particular, Cry34 is as stable to
digestion as many important food allergens, and other data relied on by EPA are
insufficient to override the digestive stability data. For example, although EPA
bases its judgment in part on low levels of Cry34 in corn, the protein is found at
over 3,000 fold higher concentration than a previous SAP found unacceptable for
Cry9C from StarLink corn. EPA’s contention that Bacillus thuringiensis is non-
allergenic is unsupported, and contradicted by published studies that suggest
otherwise. The heat inactivation data is insufficient without showing that the
protein is not only inactivated, which may merely mean it is denatured, but also
degraded to peptides that are too small to cause sensitization.
In a situation such as exists with Cry34Ab1, where the level of hazard is not
precisely known, the regulatory decision will reflect whether EPA takes a cautious
approach, to ensure that the public is adequately protected, or puts the public at
some risk in order to allow commercialization. In making such a decision, the
potential benefits should be considered. Several products and approaches are
a
The Center for Food Safety is a not-for-profit public interest group located in Washington, DC, that works to
protect the safety of people and the environment on issues concerning genetic engineering and other new and
emerging technologies, and by the support of sustainable technologies. www.centerforfoodsafety.org
b
I will use Cry34 and Cry34Ab1 interchangeably in my comments
49
already on the market or available to farmers that adequately control rootworm,
and Cry34/Cry35 does not substantially improve the situation. Therefore, it would
be especially irresponsible to allow this corn rootworm product on the market under
the existing circumstances.
An alternative to rejecting Cry34Ab1 outright would be for the SAP to

recommend additional tests that could be dispositive concerning allergenicity. We
are not aware of currently available methods that could clearly resolve Cry34Ab1
allergenicity, and if the SAP could advance this issue, for Cry34Ab1 as well as future
GE proteins, they would perform a significant service. We feel that it is important to
point out that the issue of inadequate allergenicity testing has been present for as
long as GE foods have been commercially produced, almost 10 years, with little
progress. This is due in significant part to the limited resources devoted by the
agencies to solving this problem, notwithstanding this and other SAP, and it
therefore represents a significant failing of the current GE regulatory system. For
example, as far as we know, there has been relatively little research funding
devoted by either EPA or FDA to improving allergenicity testing.
There has also been little government effort to validate and adopt the
recommendations of respected international bodies such as the FAO/WHO. For
example, even though the digestive stability test has been widely accepted and
used since the mid 1990s, only recently has there been multiple-lab testing to
standardize and validate this assay.1 As a consequence, as noted in the table
provided by EPA at the end of its position paper, reaction conditions for the
digestive assay have varied widely. In particular, pepsin-to-test-protein ratios have
been up to several thousand fold higher than those recommended by the FAO/WHO,
despite data by TJ Fu of FDA and others that show that such high levels of pepsin
could make some allergens appear to be unstable, and therefore to wrongly look
like non-allergens.2 3 And although industry efforts to begin to standardize testing
procedures are commendable, regulatory agency direction is needed to ensure that
adequately protective methods that the public can trust are developed. In other
words, it is not enough that the tests simply work in the narrow sense and are
reproducible, but that the best tests are used – i.e. tests that are adequately
protective of the public. This requires the active participation of the regulatory
agencies charged with public protection.
Therefore, we believe that a crucial function of this SAP goes beyond the
immediate recommendations about the possible allergenicity of Cry34Ab1, and
includes recommendations for improving GE allergenicity assessments in general.
This is well within the purview of the SAP. And although the SAP cannot solve the
50
bigger problems concerning the inadequacies and lack of standards of current
allergenicity testing, it can point the way. Ultimately, unless EPA and its sister
agencies take more seriously the need to develop better procedures and improve
the rigor of allergenicity and other GE safety testing, the public cannot be expected
to have confidence in pronouncements about the safety of these crops. We hope
the SAP will appreciate, and not miss, this opportunity to assist EPA with the larger
issue of improving its risk assessment process, as well as advising EPA on the
potential allergenicity of Cry34.
Background
The immediate issue for the SAP is the potential allergenicity of Cry34, and
more specifically, the importance of gastric digestion assay data. The gastric
stability assay has been widely accepted as an important part of allergenicity
assessments of GE foods beginning around the mid 1990s. Several papers further
supported the assay beginning around 1996, and continuing through the FAO/WHO
consultation in 2001 that resulted in acceptance by the Codex Alimentarius.4 5
Although certainly imperfect, it should be kept in mind that for proteins

without significant previous human exposure, as is likely the case for Cry34, there
are no accepted tests that are more reliable for determining potential allergenicity.
For example, although sequence homology searches can be very useful when a
match is found, they typically say very little about allergenicity for proteins such as
Cry34 that have not been food constituents, and are not similar to food proteins or
known allergens. In other words, there is no reason to believe that known (and
sequenced) allergens represent the range of possible protein sequences that are
capable of producing an allergic reaction. In fact, unless we know that the currently
available sequences of allergens and IgE epitopes represent a substantial
proportion of the possible allergen sequences, negative results in a sequence
homology or similarity search tell us little about the likelihood that a novel protein
will become an allergen. Therefore, it would not be surprising for novel proteins
that have not been in the food supply to prove allergenic, even without a match to
the sequence of a known allergen.
51
Similarly, loss of function due to processing, such as by heating, does not
mean that a protein will necessarily be rendered non-allergenic. For example, some
milk allergens can have either conformational or linear epitopes, where the latter
may reflect sensitization to the denatured form of the protein. 6 7 For example, Vila
et al. found that: “Specific IgE antibodies against linear (denatured) as well as
conformational (native) milk proteins were determined by probing dot-blots with
patients’ sera.” 8 More generally, loss of function may simply mean that the
protein is denatured rather than degraded into short peptides, and could therefore
still be allergenic. Abundance of the protein in food has also been used in
predicting the likelihood of allergenicity, since most (but not all) food allergens are
typically plentiful proteins. But the recent SAP on StarLink concluded that even a
proposed tolerance of 20 PPB was not acceptable because a lower limit for
sensitization could not be determined.9 We note that the FAO/WHO consultation did
not rely upon either heat stability or protein abundance in its recommended
allergenicity determination. The FAO/WHO specifically noted that “…allergens can
sensitize susceptible individuals at less than milligram levels, possibly at less than
microgram levels,” and “Thus, level of expression cannot yet be incorporated into
the assessment of the allergenicity of genetically modified foods.” 10 Animal
models, another potentially useful approach, are not yet considered reliable
predictors of food allergenicity.
Finally, there have been several instances where food allergens have been
found to be unstable in the gastric assay, as well as some instances where
supposed non-allergenic proteins have been stable. This may demonstrate that the
correlation between gastric stability is imperfect, and makes interpretation more
difficult, but does not invalidate the assay. Food allergens also show a range of
digestion times, which also complicates the interpretation of results. In addition, it
is not clear that the proteins have always been adequately “classified” prior to the
assay. For example, if stability is correlated with allergenicity because the protein
must reach immune tissue in the intestines for sensitization to occur, then oral
allergy syndrome allergens may not fit the model because sensitization may occur
through the respiratory homologue of the food allergen.c Similarly, if the food is
always eaten in a cooked form, which degrades the GE protein or makes it more
susceptible to digestion, then using “raw” protein in the assay may not be expected
to fit the model. Considering these or other factors may lead to refinements of the
assay, and any guidance that the Panel can provide to EPA that could improve the
assay would be welcome.
Until a more reliable means of determining allergenicity is found, simulated

digestive stability should remain a fundamental part of allergenicity determinations.
c
The physiological meaning of stability has not been determined, but only hypothesized.
52
That said, how should this assay be applied? Although the kinetic approach
proposed by DowAgro may eventually have merit in some circumstances, the EPA
position paper points to several weaknesses of this approach. More basically,
although the work by DowAgro is a good start, this kinetic assay has not been
adequately validated. Such validation requires testing by several labs of the same
proteins and samples, and varying the assay conditions to determine how the assay
can be done in the most reproducible and accurate manner, as well as determining
how best to interpret the results. This has not been done with the kinetic approach.
There has been considerably more experience with the visible-endpoint
measurement approach that has always been previously used to determine
stability. In addition, there have been recent attempts to begin validating endpoint
measurement and reaction conditions.11 Therefore, regardless of what the panel
decides about the concept of using a kinetic approach in measuring stability, the
current results of the kinetic measurement of stability should not be accepted.
Instead, the endpoint data for Cry34 should be carefully considered. I briefly
considered those original data for the Cry34 Experimental Use Permit in April 2003,
and include that analysis as Appendix A.
Potential Allergenicity of Cry34
EPA, in its position paper, concludes on page 7 that “Cry34Ab1 is unlikely to

be a food allergen.” We disagree with EPA’s assessment for several reasons. It is
very difficult, due the limitations of currently available tests, to determine with any
precision how likely it is for Cry34Ab1 to become an allergen. None of the available
data can safely exclude the possibility of allergenicity, while some data support that
possibility. We therefore believe that the available data suggest that there is a
reasonable possibility that Cry34Ab1 could become an allergen. Unless additional
dispositive data can be produced, we believe that prudence and reasonable caution
demand that crops containing Cry34Ab1 in the edible portion are not approved.
First, Cry34 is as stable to simulated gastric digestion, or more stable, than

several known food allergens, and more stable than most non-allergen food
proteins. Recognizing that there is some variation in the visible endpoints for
various food allergens, probably due in part to variations in protein purification, gel
electrophoresis and protein staining,12 Cry34 survives digestion (visible at 15 min -
20 min, but not at 30 min) similar to several known food allergens. These allergens
include the major peanut allergen Ara h 2 (20-60 min), egg ovalbumin (20-60 min)
53
(Thomas, K. op. cit.), egg conalbumin (15 min), bovine milk casein (15 min), bovine
serum albumin (15), soybean lectin (15 min), soybean glycinin (15 min), soybean
Gly m Bd 30K (8 min), and peanut lectin (8 min) (Metcalfe et al., op. cit.). Alpha-
lactalbumin was stable for only 2 min (Metcalfe et al., op. cit). Similar results can
be found in Fu et al. (op. cit) and other references. Several major allergens are not
“highly” stable, so there does not appear to be a clear correlation between the
importance of the allergen and the magnitude of its stability. Put another way, it
does not seem valid to consider what EPA calls “moderate” stability of Cry34 as an
indicator of lower probability of allergenicity.
EPA considers several other parameters in arriving at its conclusion that

Cry34Ab1 will not become an allergen. In particular, EPA comments that because
Cry34Ab1 is inactivated by heat, is not glycosylated, has no sequence similarity or
homology with known allergens, and is present at relatively low levels in corn
kernels, and that Bacillus thuringiensis in not considered an allergenic source, it is
unlikely to be an allergen. We have addressed some of these issues generally in
the “Background” section above.
EPA claims that Bacillus thuringiensis is not an allergen, in contradiction to

available evidence. In particular, Bernstein et al. found preliminary evidence that B.
thuringiensis, and more specifically, spore preparations from B. thuringiensis, may
be allergenic.13 Although clinical symptoms were not present, important indicators
of allergy including B. thuringiensis spore-specific IgE and positive scratch tests
were demonstrated. In addition, other data suggest that Cry proteins may act as
potent adjuvents. While not proof that B. thuringiensis or Cry proteins are
allergens, these data are suggestive that they could be. Unfortunately, EPA has
done no follow-up studies to address the potential allergenicity of Cry proteins. In
addition, there are limited data on any significant previous exposure of the public to
Cry34, a necessary prerequisite to allergy. EPA is apparently therefore incorrect
when it claims on page 7 of its position paper that Cry34Ab1 “originates from a non-
allergenic source,” since the evidence to substantiate this claim is lacking.
As noted above, the amount of Cry34Ab1 in corn kernels cannot be relied

upon to eliminate the possibility of Cry34 allergenicity. The position paper states
that Cry34Ab1 is present at about 70 ng/mg in corn kernels. Although Cry34
concentration is lower than for most food allergens, it is over 3,000-fold higher than
the 20 PPB that the second StarLink SAP found unacceptably high for setting a
tolerance, because a minimal level for sensitization could not be established.14 It is
ironic that DowAgro used an ubiquitin promoter to produce the more stable
Cry34Ab1, which causes production in the kernel where the protein is not needed to
54
control corn rootworm, while using a wheat root-preferential promoter for the less
stable Cry35Ab1, which produces 70-fold less Cry35Ab1 in the kernels than
Cry34Ab1. Perhaps one recommendation of the SAP could be to produce new
Cry34/Cry35 corn with low or no expression of Cry34Ab1 in the kernel.
The second StarLink SAP determined that Cry9C had a moderate possibility of
being allergenic, and a low possibility of actually producing allergy due to limited
public exposure. Although Cry9C was stable to heat as well as digestion, while
Cry34 may be somewhat less stable to digestion and is inactivated on heating, on
the other hand StarLink was present only as a low-level contaminant (and the
proposed tolerance was only to allow for elimination from food supply through
dilution, rather than to allow continued planting) while Cry34 is being proposed as
an indefinite addition to the food supply, with ongoing exposure levels considerably
higher than were likely the case for Cry9C.
CFS believes that the possible consequences of a commercialized Cry34Ab1

allergen should be considered in the context of the food and the crop. Corn is
usually not an allergenic food. Therefore it can often be recommended as an
alternative source of protein for individuals, and especially children, who have
multiple food allergies, or who are more prone to develop food allergies. This is not
the case for several important sources of vegetable protein such as soybeans, nuts,
peanuts, and wheat, which are all prominent food allergens. Therefore, we should
take special care to avoid turning corn into a more common food allergen.
There is no pressing need for a corn rootworm product containing

Cry34/Cry35. Although the current available products have some drawbacks,
Cry34/Cry35 corn is unlikely to produce significant improvements over current
products. There are insufficient data to suggest substantially higher yield, and it
does not improve nutrition. For all of these reasons, EPA should not approve the
registration of Cry34Ab1.
Therefore, on balance, we believe that Cry34Ab1 has a similar possibility of

becoming a food allergen as did Cry9C. EPA correctly found that for StarLink, a
“low” possibility of becoming a food allergen was sufficient to deny a tolerance (or
exemption from tolerance), and it should do the same in the case of Cry34Ab1. As
noted above, it is impossible to accurately quantify the allergenic potential of
Cry34Ab1, or to put “too fine a point” on this analysis, which is precisely why EPA
should take a reasonably cautious approach in keeping Cry34Ab1 off the market
55
unless more definitive data can be produced dismissing the possibility of
allergenicity.
References
56
1
Thomas, K (2004) A multi-laboratory evaluation of a common in vitro pepsin digestion assay protocol used in assessing
the safety of novel proteins. Regulatory Toxicol. Pharmacol. 39: 87-98
2
Fu, T-J et al. (2002) Digestibility of food allergens and non-allergenic proteins in simulated gastric fluid and simulated
intestinal fluid – a comparative study. J. Agric. Food Chem.
3
Fu, TJ (2002) Digestion stability as a criterion for protein allergencity assessment. Ann. N Y Acad. Sci. 964:95-110
4
Metcalfe, DD et al. (1996) Assessment of the allergenic potential of foods from genetically engineered crop plants. Crit.
Rev. Food Sci. Nutr. 36 (S): 165-186
5
FAO/WHO (2001) Evaluation of allergenicity of genetically modified foods. Report of a Joint FAO/WHO Expert
Consultation on Allergenicity of Foods Derived from Biotechnology. January 22-25, Rome, Italy
6
Kohno, Y et al. (1994) Preferential recognition of primary protein structures of alpha-casein by IgG and IgE antibodies of
patients with milk allergies. Ann. Allergy 73: 419-422
7
Vila, L et al. (2001) Role of conformational and linear epitopes in the achievement of tolerance in cow’s milk allergy.
Clin. Exper. Allergy 31(10): 1599-1606
8
Vila, L et al., op. cit.
9
SAP Report No. 2001-09, Assessment of Additional Scientific Information Concerning StarLink Corn, July 2002,
Arlington, VA www.epa.gov/scipoly/sap/2001/july/julyfinal.pdf
10
FAO/WHO, op.cit.
11
Thomas, K et al., op. cit.
12
Thomas, K et al., op. cit
13
Bernstein, LI et al. (1999) Immune responses in farm workers after exposure to Bacillus thuringiensis pesticides.
Environ. Health Perspectives 107(7): 575-582
14
SAP Report No. 2001-09, op. cit.
Appendix A
1Public Information and Records Integrity Branch
Information Resources and Services Division, 7502C
Office of Pesticides Programs
Environmental Protection Agency
Room 119
Crystal Mall #2
1921 Jefferson Davis Highway
Arlington, VA
Attention: Docket ID Number OPP-2002-0350
April 7, 2003
Comments to EPA re: Dow Agro Request for a Tolerance for Corn Rootworm
Transgenic Corn Containing Cry34Ab1/Cry35Ab1
Center for Science in the Public Interest (CSPI) submits the following comments
recommending that EPA deny DowAgro Science’s request for a food tolerance or an
exemption from tolerance for its new rootworm-protected corn containing
Cry34Ab1/Cry35Ab1 (hereafter Cry34/35). This exemption would allow DowAgro to
incorporate Cry34/35 corn into the food supply when grown under an experimental use
permit (EUP). We make our recommendation based on simulated gastric digestion (SGD)
data submitted to EPA by DowAgro indicating that Cry34Ab1 may become a food allergen
if allowed into the food supply. Furthermore, due to the limitations of current allergencity
tests, we highly recommend that EPA present the allergencity data for Cry34/35 to
independent experts on allergenicity, such as the Scientific Advisory Panel, before
making a decision on the full registration of Cry34/35 in the future.
We find that SGD data for Cry34/35 presented in MRID 455845-02 and MRID
452422-12 indicate that Cry34Ab1 should be considered to be stable according to
accepted scientific literature, and therefore disagree with Dow Agro’s interpretation of
instability of Cry34Ab1. While digestive stability does not prove that a protein will
become a food allergen it has been accepted by international groups of experts on
allergencity as indicating a reasonable likelihood of allergenicity (Astwood et al., Metcalfe
et al., United Nations Food and Agriculture Organization/World Health Organization).
Therefore, EPA cannot determine with reasonable certainty that Cry34Ab1 will not cause
allergic reactions when consumed.
DowAgro presents two sets of data concerning SGD which found that intact
Cry34Ab1 could be detected for 20-30 minutes using sensitive detection methods
(Western blot), or that 90% of Cry34Ab1 was digested after 6.2 minutes using less
sensitive detection methods (Coomassie-stained SDS-PAGE gel). DowAgro discounts the
20-30 minute stability data by claiming that the detection method (Western blot) was
more sensitive than in SGD for previous Cry proteins registered by EPA. Based on their
calculation of 90% digestion of Cry34Ab1 after 6.2 minutes, DowAgro concludes that
Cry34Ab1 is not stable.
DowAgro’s interpretation of SGD data is not in accord with currently accepted

standards for several reasons. First, literature such as that cited by DowAgro on SGD
finds that several food allergens were digested in as few as two to eight minutes
(Astwood et al., Metcalfe et al.). By that criterion, detection of Cry34Ab1 after 6.2
minutes would indicate stability, not instability (see Astwood et al., Table 1).
Furthermore, the cited literature uses the longest time-point where SGD test
protein can be detected as a measure of stability, not the rate of digestion used by
DowAgro to determine 90% digestion. For example, Astwood et al. use the longest time-
point for which food allergens can be observed as their measure of stability. Like
DowAgro, they use Coomassie-stained SDS-PAGE gels to detect undigested allergens.
Cry34Ab1 is visible, even under the poorly reproduced gel pictures found in MRID
455845-02 and MRID 452422-12, for up to 20 minutes, and clearly visible at 7.5 to10
minutes in most of the gels.
In addition, DowAgro uses more than three-fold higher proportion of pepsin-to-test-

protein (Cry34Ab1) in its SGD assay compared to Astwood et al., which may make
Cry34Ab1 appear to be less stable than it would if carried out according to the literature.
Recent experiments clearly demonstrate that the proportion of pepsin to allergen can
change the apparent stability of the allergen (T.J. Fu and Fu et al.). More recent
protocols recommend even lower pepsin to test protein proportions (United Nations Food
and Agriculture Organization/World Health Organization). These more recent protocols
also recommend detecting SGD test protein using silver staining or colloidal gold which is
more sensitive than Coomassie staining and may approach the sensitivity of the Western
blots used by DowAgro that showed 20-30 minute stability of Cry34Ab1.
We recognize that the limited dietary exposure, both in amount and duration, that
would be caused by granting a temporary tolerance for Cry34/35 makes the likelihood of
allergic reaction low. However, it is a chance that should not be taken. DowAgro could
continue to grow Cry34/35 corn under an EUP on a crop-destruct basis if other safety
criteria are found to be acceptable. Therefore, it would be especially imprudent to
approve the requested tolerance.
Finally, the dilemma presented by the current lack of tests that would more clearly
determine the potential allergencity of a protein new to the food supply is obvious in the
example of Cry34/35. This example emphasizes the crucial need for the development of
more definitive tests and, in their absence, the delineation of acceptable standards for
performing and interpreting currently available tests such as SGD. Such standards are
provided by the FAO/WHO expert consultation on food allergy assessment for GE proteins
(United Nations Food and Agriculture Organization/World Health Organization), and EPA
should adopt those standards. Until such measures are taken, EPA will continue to face
situations that may challenge the credibility of its decisions, and hence public confidence
in GE technology.
Sincerely,
Doug Gurian-Sherman, Ph.D.

Science Director, Biotechnology Project
Center for Science in the Public Interest
1875 Connecticut Ave., NW
Suite 300
Washington, DC 20009
202-332-9110 ext. 377
References
Astwood JD, Leach JN, and Fuch RL (1996) Stability of food allergens to digestion in vitro.
Nature Biotech. 14:1269-1273
Fu, T-J (2002) Digestion stability as a criterion for protein allergenicity assessment.
Ann. N.Y. Acad. Sci. 964:99-110
Fu, T-J, Abbott, UR, Hatzos, C. (2002) Digestibility of food allergens and nonallergenic
proteins in simulated gastric fluid and simulated intestinal fluid – a comparative study. J.
Agric. Food Chem. 50:7154-7160
Metcalfe, D.D.,Fuchs, R.L., Townsend, R., Sampson, H.A., Taylor, S.L., and Fordham, J.R.
(1996) Assessment of the allergenic potential of foods derived from genetically
engineered crop plants. Crit. Rev. Food Sci. Nutr. 36(S):S165-S186
United Nations Food and Agriculture Organization/World Health Organization. (2001)

“Evaluation of Allergenicity of Genetically Modified Foods, Food and Agriculture
Organization.” Rome, Italy. January 22-25, 2001
Withering on the vine: Will agricultural biotech's promises bear fruit?
By Gregory Jaffe
Director, Biotechnology Project
Center for Science in the Public Interest
Februrary 2, 2005
Is agricultural biotechnology a growth industry with a steady stream of new products or
one limited to marketing a few hugevolume
commodity crops with narrow agronomic benefits? CSPI analyzed existing publicly
available regulatory information to determine whether development of new biotech
products has been increasing, decreasing or remaining constant.
i
Executive Summary
The biotechnology industry and its supporters have long proclaimed all the great things
that genetically engineered (GE) crops will do for agriculture, consumers, and the environment
in America and around the world. The first generation of products developed and
commercialized in the 1990s have, in fact, been commercially successful in the United States
and several other countries. Those GE crops – primarily insect-resistant corn and cotton and
herbicide-tolerant corn, cotton, soybeans, and canola – have been found safe to humans and the
environment. Indeed, they have benefitted the environment and farmers and have been widely
adopted by farmers. However, the promise of additional benefits has not been realized. The
“second generation” of crops, such as ones engineered to be salt-tolerant or to have enhanced
nutritional qualities have still not gotten beyond the laboratory. Is agricultural biotechnology a
growth industry with a steady stream of new products or one limited to marketing a few hugevolume
commodity crops with narrow agronomic benefits? CSPI analyzed existing publicly
available regulatory information to determine whether development of new biotech products has
been increasing, decreasing or remaining constant.
CSPI also assessed how long it takes two federal regulatory agencies to complete their
review of biotech crops so those products can be commercialized. The U.S. government often
touts its regulatory process for biotech crops as being a science-based process and a model for
other countries. Although three agencies – the Food and Drug Administration (FDA), the
Animal and Plant Health Inspection Service (APHIS) of the US Department of Agriculture
(USDA), and the Environmental Protection Agency (EPA) – regulate biotech crops through a
patchwork of legal authorities passed by Congress years before genetic engineering existed, the
government claims its regulatory process is efficient, effective, and does not hinder product
development. Is, in fact, that system efficient and effective? Have product reviews become
more routine and faster as the regulatory agencies have become more familiar and comfortable
with the technology?
This study analyzed FDA and APHIS information about GE crops that have passed the
mandatory or voluntary regulatory hurdles prior to commercialization. The study found that the
number of biotech crops going through the regulatory review process decreased sharply between
the last five years of the 1990s and the first five years of the 21st century. Furthermore, the
products that the government reviewed between 2000 and 2004 were not “novel” because they
involved engineering crops with the same or similar genes that were commercialized in the
1990s. Also, while the number of products to be reviewed by federal regulators declined by two-
ii
thirds between 2000 and 2004, the time it took to receive a regulatory clearance doubled. Those
unexplained trends should worry those who believe that agricultural biotechnology can be used
safely and can benefit farmers, consumers, and the environment in the United States, other
developed countries, and in developing countries. Public discourse is needed to understand what
factors account for the trends and whether and how they can be reversed.
Democratic Principles and Mandatory Labeling of Genetically Engineered

Food
Robert Streiffer and Alan Rubel, University of Wisconsin
2004, Public Affairs Quarterly
This paper gives two arguments about how the conflict between public
opinion
Page - 1 -
Democratic Principles and Mandatory Labeling
of Genetically Engineered Food1
Robert Streiffer and Alan Rubel
University of Wisconsin - Madison
Draft: Do not cite or distribute without written permission
Comments welcome: [email protected]; [email protected]
Forthcoming in Public Affairs Quarterly
1. Introduction
The Grocery Manufacturers of America estimates that over 70 percent of all processed
food products in grocery stores contain genetically engineered (GE) ingredients,
including such products as Kellogg’s Corn Flakes, Frito-Lay Corn Chips, Nestle
Carnation Alsoy Infant Formula, Heinz 2 Baby Food, Quaker Chewy Granola Bars, and
Gardenburgers. Nonetheless, almost 60 percent of consumers believe they have never
eaten GE food, and consumers are typically outraged “that such a change in the food
supply could happen without them knowing about it.” Thus, it’s not surprising that when
consumers learn about the prevalence of GE foods, they almost unanimously support
1 Theauthors very much appreciate the many helpful comments from Kristen Hessler, Russ Shafer-Landau,
Francis Schrag, Noël Carroll, Juan Comesaña, Carolina Sartorio, Norm Fost, Dan Hausman, an anonymous
reviewer for Public Affairs Quarterly, and the participants in the 2003 Agriculture, Food, and Human
Values Conference paper session. This material is based upon work supported by the University of
Wisconsin Graduate School and the Cooperative State Research, Education, and Extension Service, U.S.
Department of Agriculture, under Agreement No. 00-52100-9617. Any opinions, findings, conclusions, or
recommendations expressed in this publication are those of the authors and do not necessarily reflect the
view of the U.S. Department of Agriculture.
Page - 2 -
mandatory labeling. During one of the Food and Drug Administration’s public meetings
on biotechnology, Marion Nestle, professor of Nutrition and Food Studies at New York
University, testified “I think the surveys reveal an almost total agreement that bioengineered
food should be labeled as such.”2
Despite this overwhelming public support, the FDA recently reaffirmed its
original 1992 decision not to require labels, claiming that there is no scientific basis for
concluding that GE foods are less healthful than other foods.3 This claim has been widely
endorsed by independent scientific organizations, including the Royal Society, the
American Medical Association, the Food and Agricultural Organization of the World
Health Organization, and the National Academy of Sciences. However, concluding that
labels are not warranted on the grounds that GE foods are no less healthful than their
conventional counterparts assumes that such differences are the only ones relevant to the
labeling controversy. This paper argues that this assumption is mistaken.
2 Cited in Pew Initiative on Food and Biotechnology, “GM Food Safety: Are Government Regulations
Adequate?” (September 2003), http://pewagbiotech.org/buzz/display.php3?StoryID=42; Food and Drug
Administration, Center for Food Safety and Applied Nutrition, “Report on Consumer Focus Groups on
Biotechnology,” (October 20, 2000), http://www.cfsan.fda.gov/~comm/biorpt.html; “Biotechnology in the
Year 2000 and Beyond,” FDA Public Meeting on foods produced through modern biotechnology, Chicago,
Illinois (November 18, 1999), http://www.fda.gov/ohrms/dockets/dockets/99n4282/tr00001.rtf.
3 FDA, Statement of Policy, “Foods Derived from New Plant Varieties,” Federal Register: 57, no. 104 (29
May 1992): 22991; FDA, Draft Guidance for Industry, “Voluntary Labeling Indicating Whether Foods
Have or Have Not Been Developed Using Bioengineering,” Federal Register: 66, no. 12 (18 January
2001): 4839-40.
Page - 3 -
All governments must decide what to do when public opinion conflicts with the
decisions of a scientifically oriented agency. This question is particularly urgent, though,
for democratic forms of government in which such agencies ultimately derive their
authority from the consent of the people. This paper gives two arguments about how the
conflict between public opinion and the FDA ought to be resolved. The first is the
Consumer Autonomy Argument, which applies to the FDA and appeals to moral
principles about how public agencies within a democracy should exercise their discretion.
According to this argument, the Food, Drug, and Cosmetic Act (FDCA) gives the FDA
the discretion to require labels, and the FDA has a moral and democratic obligation to
exercise that discretion and require labeling. The second is the Democratic Equality
Argument, which applies to Congress and concerns its democratic responsibility to defer
to public opinion on certain kinds of issues. The argument concludes that if the FDA fails
to require labeling, Congress should.
Distinguishing between Decision-Makers
It is important at the outset to distinguish between the different decision-makers involved
in the labeling debate, and to recognize that different norms and constraints will apply to
different decision makers.4 The FDA is constrained by its authorizing statutes, most
importantly the FDCA, and any argument about what the FDA should do must take into
4 Another way to put this point is to say that role-relative reasons are central to this debate. A consideration
that may count as a reason for a decision-maker occupying one role may fail to be a reason for a decisionmaker
occupying another role. See Arthur Applbaum, “The Remains of the Role,” Governance 6 (1993):
545-57; David Luban, Lawyers and Justice: An Ethical Study, (Princeton, NJ: Princeton University Press,
1998), 104-127.
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account the constraints imposed by the FDCA as well as the moral norms applying to
federal agencies within a democracy. On the other hand, any argument about what
Congress should do need not take into account the constraints imposed by the FDCA, for
Congress can change the FDCA. But arguments about Congress do need to take into
account the moral norms that apply to legislative action. Thus, the sets of norms and
constraints will vary depending on who is making decisions.
This paper addresses the FDA and Congress because these are the two political
bodies with the clearest authority to require labeling. It is not addressed to the courts, for
courts will overrule the FDA’s interpretation of the FDCA only if the statute
unambiguously contradicts the agency’s interpretation or if the agency’s interpretation is
unreasonable, neither of which is plausible here.5 It also does not address state
legislatures. Arguments about what they ought to do will largely parallel arguments about
what Congress ought to do, but with additional Constitutional restrictions.6 Finally,
5 “[I]fthe statute is silent or ambiguous with respect to the specific issue, the question for the court is
whether the agency’s answer is based on a permissible construction of the statute.” Chevron v. Natural
Resources Defense Council, 467 U.S. 837, 843 (1984). Note, though, that the degree of deference will
depend upon what type of action the agency takes.
6 A state legislature may not, for example, unfairly protect its own industries or inordinately impact
interstate commerce. See, for example, Dean Milk Co. v. City of Madison, 340 U.S. 349 (1951); Southern
Pacific Co. v. Arizona, 325 U.S. 761 (1945). This seems to be the reasoning in the letter written by the
FDA to Oregon Governor Kitzhaber regarding that state’s referendum about labeling GE foods. The FDA
stated that “the proposed legislation would impermissibly interfere with manufacturers’ ability to market
their products on a nationwide basis….” http://www.mindfully.org/GE/GE4/FDA-Letter-Labeling-
Illegal4oct02.htm.
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because consumers cannot directly require labels, and because the arguments about what
the FDA and Congress ought to do are largely independent of whether consumers’
reasons for wanting labels are ultimately warranted, those reasons will be discussed only
insofar as they are relevant to what the FDA or Congress ought to do. Although there are
some grounds for thinking that consumers’ reasons for wanting labels are warranted, this
paper argues that they are relevant even if they turn out to be based on false beliefs about
food safety. Thus, the arguments are consistent with the received scientific view that GE
foods are no less healthful than conventional foods, but they do not accept the common
argument that labels are unwarranted because people’s reasons for wanting them are
unwarranted.
Unfortunately, much of the literature fails to distinguish between arguments
directed towards the FDA and arguments directed towards Congress. For example, Paul
Thompson explores whether labeling is supported by a democratic norm of toleration for
reasonable but different viewpoints about food.7 Such an argument applies to Congress,
but it is not at all clear that the FDA is licensed to act on such principles. Alan
McHughen argues against labeling on the grounds that it is likely to be implemented in
such a way that it will be useless to consumers.8 This is a perfectly appropriate
consideration for Congress to take into account, but McHughen’s argument ignores the
7 PaulThompson, Food Biotechnology in Ethical Perspective, (London: Blackie, Academic and
Professional, 1997), 57-80.
8 Alan McHughen, Pandora’s Picnic Basket: The Potential and Hazards of Genetically Modified Foods,
(Oxford: Oxford University Press, 2000), 201-29; Alan McHughen, “Uninformation and the Choice
Paradox,” Nature Biotechnology 18 (2000): 1018-19.
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possibility that the FDCA requires labels, even though they may not be justified
independently of the statute. For example, sodium benzoate is a food additive, and
therefore has to be labeled under the FDCA. The FDA would not be justified in ignoring
that requirement merely because such a label is useless to the majority of us who have no
idea what sodium benzoate is.9
The legal literature focuses on how the FDA has previously interpreted and
applied the FDCA. For example, Lara Beth Winn argues that because the FDA required
irradiated foods to be labeled on grounds of consumer demand, the FDA should require
GE foods to be labeled on the same grounds.10 Fred Degnan, on the other hand, argues
that the FDA broke with precedent in the irradiation case, and that precedent best
supports non-labeling of GE foods.11 Both of these ignore whether the earlier precedents
were rightly decided. Many who think that GE foods should not be labeled are also likely
to think that irradiated foods should not be labeled, and to think so for similar reasons.
Therefore, merely appealing to the FDA’s policy on irradiation is likely to beg many of
the important questions. The legal literature also frequently ignores the possibility of
legislative action that would render precedent moot. This paper avoids these mistakes
9 The example is from McHughen, Pandora’s Picnic Basket, 209-10.
10 Lara Beth Winn, “Special Labeling Requirements for Genetically Engineered Food: How Sound Are the
Analytical Frameworks Used by the FDA and Food Producers?” Food and Drug Law Journal 54 (1999):
667-88.
11 Fred H. Degnan, “Biotechnology and the Food Label: A Legal Perspective,” Food and Drug Law
Journal 55 (2000): 301-310
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because it is addressed to particular decision-makers and distinguishes between the norms
and constraints relevant to those decision-makers.
Defining “Foods Produced through Genetic Engineering”
It is important to clarify what foods count as produced through genetic engineering.
Foods produced through genetic engineering include both GE whole foods and processed
foods that include more than some threshold percentage of GE ingredients.12 These are
the clearest cases, and these are the ones on which this paper will focus. It leaves open
whether its conclusions also apply to food products derived from GE organisms, even
though the products themselves are not GE. Highly refined oils and sugars, for example,
can come from GE crops, but do not contain any DNA. Similarly, the paper leaves open
whether its conclusions extend to foods from animals that have been fed GE feed. It also
leaves open the question of exactly what information a label should contain. Discussion
of exactly what information labels should contain and exactly which foods should count
as GE will depend on the grounds for justifying labels in the first place, and so must
come after a discussion of those grounds.
With those clarifying remarks out of the way, consider the main questions of this
paper: should the FDA or Congress require labels on GE foods?
12 It
is not necessary at this point to specify exactly what the threshold should be; one can argue that doctors
ought to inform patients about the risks of treatment without specifying exactly how likely a risk must be to
require disclosure.
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2. The Consumer Autonomy Argument
The Consumer Autonomy Argument can be summarized as follows. The decision as to
whether GE foods should be labeled is within the discretion of the FDA. In order to
decide how to exercise its discretion on this matter, the FDA should ask what the best
justification is for the existing labeling provisions, and then determine whether or not that
justification also supports a labeling requirement for GE foods. The best justification for
the existing labeling statutes gives a primary place to consumer autonomy, and
considerations of consumer autonomy support a labeling requirement for GE foods. Thus,
the FDA should require labels on GE foods.
Why the FDA Has Discretion to Label GE Foods
The FDA has the discretion to label GE foods for two reasons. First, the FDCA requires
that all “material” facts be present on the label, but the FDCA leaves the standards for
when physical differences between GE foods and their conventional counterparts are
material within the FDA’s discretion.13 There are a variety of physical differences,
including the presence of marker genes, promoter genes, stop sequences, the transgenes
themselves, the biochemical products of the transgenes, and the phenotypic changes
13 FDA, Draft Guidance for Industry (January 2001), 4840. Note that “material” does not mean the same as
“physical.” It would be absurd to interpret the FDCA as requiring that all physical facts be on the label, as
there are infinitely many physical facts about any given food. Within the FDCA, “material” just means
“required to be on the label.” It is therefore circular to argue (as, unfortunately, much public discussion
does) that a food’s GE status should not be on the label because GE status is not material; for a fact to be
material just is for it to be required on the label. One purpose of this paper is to articulate and defend a
substantive, non-circular standard for materiality that includes considerations of consumer autonomy.
Page - 9 -
induced by the presence of the transgenes. As Millstone et al. point out regarding
glyphosate-tolerant soybeans (GTSBs):
The chemical composition of GTSBs is, of course, different from all
antecedent varieties, otherwise they would not be patentable, and would
not withstand the application of the herbicide glyphosate. It is quite
straightforward to distinguish, in a laboratory, the particular biochemical
characteristics that make them different.14
Given that there are such differences, it follows that it is within the FDA’s discretion to
decide that those differences are material.
The second reason why mandatory labeling is within the discretion of the FDA is
that current labels are misleading to the average consumer, and the FDCA prohibits labels
that are misleading “in any particular.”15 As noted in the introduction, the Grocery
Manufacturers of America estimates that over 70 percent of all processed foods in
grocery stores contain genetically engineered ingredients, yet almost 60 percent of
consumers said that they had never, so far as they knew, eaten such foods.16 A 2002 poll
by the Rutger’s Food Policy Institute found that 32 percent of Americans “do not believe
[genetically engineered] products are in food stores.”17 Thus, consumers believe that they
are not purchasing GE foods when in fact they are. Note that the FDCA explicitly says
14 Erik Millstone, Eric Brunner, and Sue Mayer, “Beyond ‘substantial equivalence,’” Nature 401 (7
October 1999): 526.
15 Food, Drug, and Cosmetic Act, U.S. Code, vol. 21 sec. 343(a) (2003).
16 Pew Initiative on Food and Biotechnology, “GM Food Safety.”
17 William Hallman, Adesoji Adelaja, Brian Schilling, and John Lang, “Public Perceptions of Genetically
Modified Foods: Americans Know Not What They Eat,” (Food Policy Institute, Rutgers University, RR-
0302-001, March 15, 2002), 12.
Page - 10 -
that omitting information can render a label misleading.18 Thus, even though current
labels do not assert that the food is free of GE ingredients, the labels can still be
misleading under the FDCA. Of course, under such a broad understanding of
misleadingness, any label will mislead some consumers in some respects, but the fact that
a lack a GE food label is misleading to the average consumer means that it is within the
FDA’s discretion to determine that the misleadingness is sufficiently problematic so as to
require labeling.19
Autonomy and the Labeling Provisions
Given that it is within the FDA’s discretion to require labeling, what democratic norms
govern how the FDA ought to exercise that discretion? Because the FDA derives its
authority from Congress, the FDA should exercise its discretion in the way that best
comports not only with the letter of the FDCA but also with its underlying spirit (absent
serious reservations about the justice or legitimacy of the FDCA, a point addressed
18 FDCA, sec. 343(n). See also U.S. v. 36 Bottles of London Dry Gin 210 F. 271 (3rd Circuit 1914), holding
that a label can be misleading even in the absence of any intent to deceive.
19 Notice that the first argument, which relies on the presence of physical differences, only applies to foods
that are themselves genetically engineered or that contain genetically engineered ingredients. It does not
necessarily apply to highly refined products derived from genetically engineered crops or to foods from
animals that have been fed GE feed, as there may be no physical differences between these products and
products derived from conventionally bred crops. The second argument, however, applies to all four
groups. In the absence of a label indicating that a product is derived from a genetically engineered crop or
from an animal fed with GE feed, consumers are misled into thinking that it is derived from or fed with
conventionally bred crops. In this regard, then, the requirement that labels not be misleading is much
stronger than the requirement that labels reveal all material facts.
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below).20 Thus, the FDA ought to look to the underlying justification for the labeling
provisions and determine what policy best fits with that justification. This section begins
by arguing that several common interpretations of the FDCA labeling provisions are
mistaken because they fail to account for the breadth of those provisions. Those
interpretations therefore offer no guidance as to what the underlying justification really
is. This section concludes by arguing that only consumer autonomy can account for the
breadth of the labeling provisions, and that consumer autonomy is therefore the
underlying justification for those provisions.
One popular interpretation is that the FDCA requires information on a food label
when, but only when, that information is relevant to the product’s safety. But because GE
foods are no more or less safe than their conventional counterparts, they do not have to
have special labels. This interpretation is clearly mistaken. According to this view,
adding tea-seed oil as a harmless filler to olive oil would not require a label change, but
in the absence of a label change, this is a clear case of adulteration and, hence,
misbranding.21
Another popular interpretation is that the FDCA requires information on a food
label when, but only when, that information is relevant to the healthfulness of the
product. For example, at a public meeting in Chicago, Ralph Hardy, president of the
20 One might argue that the FDA ought not do anything that isn’t explicitly authorized by the FDCA, but
this would ignore the fact that Congress delegates decision-making to the FDA precisely because Congress
cannot legislate all aspects of food and drug regulation.
21 Peter Hutt and Richard Merrill, Food and Drug Law: Cases and Materials, 2nd ed. (Westbury, New
York: Foundation Press, 1991), 75.
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National Agricultural Biotechnology Council, asked the FDA “Does it serve the
consumer to label something where there is no demonstrated nutritional negative health
or positive health benefit?”22 This interpretation would account for why the FDCA
requires labeling for both safety and nutrition. However, it is still too narrow to explain
all the labeling requirements, for the FDCA requires that artificial flavorings and
colorings be labeled regardless of their impact on foods’ healthfulness.23 Similarly, the
FDCA requires that imitations be labeled even when they are no less healthful than the
originals.24
One might interpret the FDCA more broadly to require labeling of information
relevant to healthfulness or quality. On the assumption that imitations and artificial
flavorings and colorings negatively affect quality, this would account for some labeling
provisions. However, this is still too narrow, for the FDCA requires that ingredients be
listed whether or not they affect the safety, healthfulness, or quality of the product.25
Surely though, one might argue, the FDCA only requires facts about the product
itself to be on the label. Facts about the process by which a food has been produced are
only relevant when they affect facts about the product. In some statements, the FDA
seems to endorse this view:
While legislative history … provides little discussion of the word
“material,” there is precedent to guide the agency in its decision regarding
22 “Biotechnology in the Year 2000 and Beyond,” FDA Public Meeting on foods produced through modern
biotechnology.
23 FDCA, sec. 343(k).
24 Ibid. sec. 343(c).
25 Ibid. sec. 343(i).
Page - 13 -
whether information on a food is in fact material. Historically, the agency
has interpreted the scope of the materiality concept to mean information
about the attributes of the food itself. 26
But, first, it has already been noted that there are physical differences between GE
foods and foods containing GE ingredients and their conventional counterparts. So this
would not rule out labels on those products. More importantly, this interpretation is
inconsistent with the FDCA’s labeling provisions. For example, the FDCA requires that
labels on packaged foods disclose “the name and place of business of the manufacturer,
packer, or distributor” even though these are not “attributes of the food itself.”27
Moreover, a label that is misleading about its country of origin is clearly misbranded,
even though country of origin is not a fact about the product itself. Indeed, restricting
information on a label to facts about the food itself would be inconsistent with labeling
on the basis of safety, nutritional properties, or quality. None of these are, strictly
speaking, attributes of the food itself, but are rather relational properties that hold
between the food and those who consume it.
In other statements the FDA seems to adopt a different interpretation of the
FDCA, according to which a label is misleading only if “it fails to reveal facts that are
material in light of representations made or suggested in the labeling, or material with
respect to consequences that may result from the use of the food to which the labeling
26 FDA, Draft Guidance for Industry, “Voluntary Labeling Indicating Whether Foods Have or Have Not
Been Developed Using Bioengineering,” retrieved from http://www.cfsan.fda.gov/~dms/biolabgu.html.
This version differs slightly from the version located at Federal Register: 66, no. 12 (18 January 2001):
4839-42.
27 FDCA, sec. 343(e).
Page - 14 -
relates under the conditions of use prescribed in the labeling, or under such conditions of
use as are customary or usual.”28 But the FDCA explicitly says that the FDA is supposed
to consider those facts “among other things.”29 Thus, reading that language as restrictive
is inconsistent with the FDCA’s clear instructions.
If interpreting the labeling provisions as being solely about safety, healthfulness,
quality, and so forth, does not adequately account for the labeling provisions of the
FDCA, what does? There are several reasons for thinking that only considerations of
consumer autonomy can adequately do so. First, several provisions make sense only by
appealing to autonomy. Second, the general FDCA requirement that labels be truthful and
non-misleading is best explained as respecting autonomy.30 Finally, while it is undisputed
that health considerations are relevant for labeling, even those are best explained by
considerations of autonomy.
Before turning to the provisions of the FDCA, however, it is worth considering
what autonomy means. Dan Brock helpfully points out that autonomy, or selfdetermination,
requires that one make “important decisions about one’s life for oneself
and according to one’s own values or conception of a good life. It is through the exercise
of self-determination, and through the respect of it by others, that people take control
over and responsibility for their lives.” Further, those choices should be voluntary, which
Brock takes to mean that “they will be based on [the person’s] own values, not coerced or
manipulated to serve someone else’s interests or someone else’s view of what would be
28 FDA, Draft Guidance for Industry, “Voluntary Labeling.”
29 FDCA, sec. 343(n).
30 Ibid., sec. 343(a).
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best for the [person].”31 Thus, autonomy involves not only making one’s own choices,
but being able to make choices that comport with one’s values and to make choices based
on beliefs that ultimately prove unwarranted or false. Moreover, it is inconsistent with
autonomy for others to manipulate someone into choosing what they (perhaps rightly)
believe comports with that person’s values. As Seana Shiffrin observes, autonomy is
insulted by “efforts to supplant or maneuver around an agent’s agency when motivated
by distrust of that person’s agency,” even when the effort will achieve the outcome that
corresponds to the agent’s own values.32 Otherwise, lying to someone when doing so
results in a choice that comports with her values would be more respectful of her
autonomy than telling her the truth.
Now consider some specific provisions of the FDCA. One requirement is that
food labels carry the name and place of business of the food’s manufacturer, packager, or
distributor.33 What is the best justification for this requirement? Although it’s true that
this information could facilitate safety in cases of suspected food-borne illness, this can’t
be the only consideration motivating it, for there are more efficient ways to track suspect
foods than by requiring that information (e.g., requiring a phone number and lot number
would suffice). Rather, the best justification is that place of manufacturer matters to
people in making purchasing decisions; their values either support making food choices
31 Dan W. Brock, “A Critique of Three Objections to Physician-Assisted Suicide,” Ethics 109, no. 3.
(Symposium on Physician-Assisted Suicide Ethics) (April 1999): 523-24.
32 Seana Shiffrin, “Paternalism, Unconscionability Doctrine, and Accommodation,” Philosophy and Public
Affairs 3 (Summer 2000): 215.
33 FDCA, sec. 343(e)(1).
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based upon the information, or they wish to make their decisions with that information
readily available, regardless of whether the information directly influences any particular
choice.
The FDCA also requires a statement of food quantity “in terms of weight,
measure, or numerical count.”34 One might argue that the FDCA requires an accurate
statement of quantity only to ensure that customers are not fraudulently misled by, for
example, large cereal boxes or heavy packaging. This is of course true, but only
reinforces the point about autonomy. It is necessary that an autonomous choice be made
free of deception; thus, rules requiring full disclosure of quantity and thereby preventing
(or mitigating) deceptive packaging serve precisely to promote autonomy. One might also
argue that the justification for such a provision is that it protects the economic interests of
consumers. Presumably it does, but nonetheless it is still best explained as a mechanism
for protecting consumer autonomy. Clearly consumers wish to incorporate information
about quantity into their purchasing decisions, and so providing that information ipso
facto respects their autonomy. More importantly, requiring information about quantity
would be justified even if producers did not induce consumers to make economically
detrimental decisions by deceptive packaging. Thus, the best justification for requiring
accurate quantity labels is that it respects consumer autonomy.
This parallels a second reason why consumer autonomy is the best explanation of
the labeling provisions. Consider the FDCA’s general requirement that labels be truthful
and non-misleading. As noted above, autonomy requires that one be able to incorporate
one’s values into choices as one sees fit. Where a label is deceptive by being untruthful or
34 Ibid., sec. 343(e)(2)
Page - 17 -
misleading, there is a sense in which the choice is not one’s own at all. Deception allows
another person to manipulate one’s decisions and thereby fails to respect autonomy.
Requirements for truthfulness and non-misleadingness therefore serve to respect
autonomy.
Note, too, that one must appeal to autonomy to justify even safety and nutrition
labeling requirements. It might strike some as odd to say that considerations of
autonomy, as opposed to considerations of health, justify labeling on the basis of safety
or nutrition, but what explains the importance of health? It makes sense to accommodate
health-based food decisions not because health concerns are intrinsically more important
than other sorts of concerns. Rather, the desire for health-related information is widely
shared, both because people value health itself and because health is instrumentally
necessary for whatever sort of life one wishes to lead. Thus, even safety and nutrition
labeling is ultimately justified because it promotes autonomy by providing consumers
information important to them.35
Autonomy and GE Labels
So, the justification for the labeling provisions also supports GE labeling if the GE status
of food products is in fact important to many consumers. This section shows that this is
indeed the case. If it is true that autonomy justifies labeling, then it ought to for GE foods
just as much as it should for any other kind of labeling. Thus, while people tend to
35 One might argue that the FDCA labeling provisions are based upon a group of values that includes health
and safety as well as autonomy. Although this interpretation arguably underestimates the role of autonomy,
it would still support the conclusion that the FDCA requires autonomy-based labeling.
Page - 18 -
juxtapose safety and nutrition labeling with GE labeling on the grounds that safety and
nutrition labeling promotes health and GE labeling does not, it is more accurate to say
that they are analogous in that they both promote autonomy.
As illustrated in Table 1, there is substantial data showing that many consumers
want to take into account whether foods are genetically engineered in their food
purchasing decisions.36
Table 1: Consumer Preferences about GE Foods
Year Source Result
2003 ABC News 55% would “avoid foods carrying a biotech label”
2001 ABC News 57% would be less likely to buy labeled foods
36 Poll results compiled from The Center for Food Safety, “Compilation and Analysis of Public Opinion
Polls on Genetically Engineered Foods,” http://centerforfoodsafety.org/facts&issues/polls.html (September
30, 2003); Label This, “North American Public Opinion on GE Food and Labeling,”
http://www.labelthis.org/polls.htm, (accessed July 28, 2003; site now discontinued); and the Campaign to
Label Genetically Engineered Foods, “ABC News Poll: 92 Percent of Americans Want Labeling,” The
Campaign Reporter (August 2003) http://www.thecampaign.org/reporter0803.php#new, September 30,
2003. One might object that polls ask people to predict their market behavior, but those predictions may be
inaccurate. However, Huffman et al. have used controlled bidding studies to observe subjects’ willingness
to pay for labels and their comparative willingness to spend money on GE and conventional foods. They
found that consumers’ behavior matches those polling results in that “consumers’ willingness to pay for
GM-labeled foods is significantly lower than their willingness to pay for the plain-labeled counterpart,” just
as the opinion polls predict. Wallace Huffman, Jason Shogren, Matthew Rousu, and Abebayehu Tegene,
“Consumer Willingness to Pay for Genetically Modified Food Labels in a Market with Diverse
Information: Evidence from Experimental Auctions,” September 30, 2003,
http://www.biotech.iastate.edu/publications/IFAFS/GMJARE093003a.pdf.
Page - 19 -
2001 Rutgers University 48% wouldn’t buy labeled fresh vegetables
2000 Oxygen/Markle-Pulse Only 50% of women would eat GE food; only 37% would
give GE food to their children; 47% would pay more for
non-GE food
2000 Economist/Angus Reed
Group
4% would be more likely to buy foods because they are
GE; 57% would be less likely to buy foods because they
are GE
1999 Time Magazine 58% would avoid purchasing labeled foods
There are any number of reasons why people would be interested in knowing
information about what foods are genetically engineered so that they can better
incorporate their values into their food choices (i.e., exercise their autonomy). First, many
people who observe religious or cultural prohibitions against eating foods from certain
sources may be concerned about whether genes from those sources are in other foods.37
Similarly, vegetarians may be concerned about the presence of animal-derived genes in
non-animal food products. Others may wish to avoid food from the genetically
engineered animals that will enter the food supply soon on the ground that genetic
engineering will likely have a negative impact on animal well-being.38 Paul Thompson
describes “latent purificationists” who think that food safety and quality are determined
by the absence of impurities and additives, some of whom think that novel genes and
37 Thompson, Food Biotechnology in Ethical Perspective, 72-75.
38 JoyceD’Silva, “Campaigning Against Transgenic Technology,” in Animal Biotechnology and Ethics,
eds. Alan Hollan and Andrew Johnson (London: Chapman & Hall, 1998), 92-102. See also Donald M.
Broom, “The Effects of Biotechnology on Animal Welfare,” in Animal Biotechnology and Ethics, 69-82.
Page - 20 -
their products therefore make a food less safe or good.39 People whose values make them
more averse to risks posed by novel technologies than to risks posed by traditional
methods may also be interested in avoiding GE food, even if they agree that GE food is
no more risky than conventional food. Some people may think that genetic engineering
renders food unnatural in a way that older methods of genetic modification do not, and
may wish to avoid foods that are unnatural in that way. Additionally there are people who
distrust the ag-biotech industry and who are concerned about the adequacy of the United
States’ regulatory apparatus.40 Finally there are people with no concerns about consuming
GE foods per se, but who may avoid them either to show solidarity with others or to
support small farms or the organic farming community.41
It is not just people who wish to avoid GE foods who are interested in knowing
whether their food is the product of genetic engineering. There are technophiles who may
wish to embrace the latest advances in food engineering, and others who are impressed
39 Thompson, Food Biotechnology in Ethical Perspective, 73.
40 With some warrant. Consider, for example, that according to Phil Angell, director of Monsanto’s
corporate communications, “Monsanto should not have to vouchsafe the safety of biotech food. Our
interest is in selling as much of it as possible. Assuring its safety is the FDA’s job.” Quoted in Michael
Pollan, “Playing God in the Garden,” New York Times Sunday Magazine, 25 October 1998. And yet
according to the FDA, there is “a legal duty on those who introduce food into the market place, including
food derived from new crop varieties, to ensure that the food satisfies the applicable safety standard,” and it
is developers who initially decide whether alterations introduced through genetic engineering “raise
questions of safety sufficient to warrant formal premarket review and approval by FDA.” FDA, “Foods
Derived from New Plant Varieties,” 22988, 22985.
41 Thompson, Food Biotechnology in Ethical Perspective, 74-5.
Page - 21 -
with what they believe are specific benefits of particular GE foods. Others simply value
autonomy for its own sake, and may therefore be interested in having labels that would
allow them to incorporate information into their purchasing decisions. A related group
may not be concerned with GE foods per se, but would resent being denied the
opportunity to refuse to consume GE foods, similar to patients who would be willing to
be used for training medical students if asked, but are outraged to learn only after the fact
that they have been used.
Note that most of these reasons are compatible with the received scientific view
that GE foods are no less healthful than other foods. More importantly, even those views
that conflict with the received scientific view are relevant even if they are mistaken. As
discussed above, protecting autonomy requires respecting decisions based on views that
are false.
Objections
One might object that the interest consumers have in knowing whether their food is GE
could be better satisfied either by providing information in a non-label format or by
voluntary negative (i.e., “GE free”) labeling. However, neither of those options would
protect consumer autonomy nearly as well as mandatory positive labeling. After all, there
is already a voluntary negative labeling schema; foods labeled organic are not produced
through genetic engineering. But because people do not know that non-organic food is
usually genetically engineered, this does nothing to protect the autonomy of the large
number of consumers who buy non-organic food but who still want GE food to be
labeled. Further, there is already a surfeit of easily accessible information regarding the
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GE status of foods,42 yet consumers are still are not incorporating that information into
their purchasing decisions, even though they want to. Finally, as noted above, a lack of
positive labeling is demonstrably misleading about an aspect of the food that many
consumers care deeply about. Requiring consumers to independently learn about the
extent to which the foods they eat are genetically engineered and to avoid them by buying
organic or voluntarily labeled food does not suffice to protect consumer autonomy;
positive labeling is the only way to avoid misleading labels. Return to the example
mentioned earlier of patients who are outraged to learn only after the fact that they have
been used for training medical students. One could require patients to independently learn
whether they are being used for training medical students, but that possibility does not
eliminate the requirement, grounded in autonomy, to inform unsuspecting patients when
their care is being provided by a medical student.
There are two objections to the claim that GE labels protect autonomy that are
worth discussing here. First, one might object that a labeling requirement would cause
conventional food producers to simply put a “may contain GE ingredients” label on all
their food products, thereby undermining consumer autonomy by precluding distinctions
between GE and non-GE foods. Second, one might argue that autonomy really involves
making choices that best comport with one’s own values, that labels will cause people to
make choices that do not best comport with their values, and that labeling would
therefore undermine rather than protect consumer autonomy. Ultimately these are both
unpersuasive; consider them in turn.
42 See, for example, http://vm.cfsan.fda.gov/~lrd/biotechm.html.
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Because of the difficulties segregating and tracking GE and non-GE foods, it may
be that the easiest labeling strategy for conventional producers will be to simply label all
foods as possibly containing GE ingredients. Thompson and McHughen predict that this
will happen and argue that it would defeat the purpose of labeling.43 Without means to
distinguish GE foods from non-GE foods, they argue, there would be no way for
consumers to exercise autonomy in food purchasing decisions. This is unpersuasive for
three reasons. First, it ignores the possibility that consumers will be willing to pay enough
more for non-GE food to make segregation by producers financially worthwhile. Second,
since organic foods are not GE, they will not bear the “may contain” labels, and thus,
consumers will have a meaningful choice foods. Finally, even in situations where there is
no meaningful choice among alternatives, information still respects autonomy. Consider a
patient whose only options are a relatively minor operation or death. Her autonomy is
respected by getting her consent and informing her of the relevant risks, benefits, and
procedures involved in the operation, even though she has no real choice.
The second objection is that if an autonomous choice is simply a choice that best
comports with one’s values, there could be cases where labels make some persons’
choices less autonomous. A person who wishes to make his food choices in the most
environmentally innocuous way, for example, might choose conventional rather than
Roundup Ready soybeans on the mistaken belief that conventional soybeans are less
harmful to the environment. If a label leads him to make that choice, then on this view of
autonomy, it actually diminishes his autonomy. But this understanding of autonomy is
mistaken, for it implies that lying to someone actually promotes his autonomy as long as
43 Ibid., 79; McHughen, “Uninformation and the Choice Paradox,” 1019.
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it causes the outcome he wants. In fact manipulation by lying bypasses his decisionmaking
capacity – and thereby his autonomy – altogether.
The FDA and Trusteeship
Those who think that GE foods are no worse than their conventional counterparts are
likely to also think that labels will be detrimental to many people’s interests by inducing
consumers to pay more for non-GE food while providing no compensating benefit. On
such a view, the FDA faces the choice of whether it should set aside its obligation to
comply with the underlying spirit of the FDCA and instead act as a trustee of consumers’
interests. An agency may be justified in exercising its discretion in that way, but only
where (a) the discretionary policy that best fits with the underlying spirit of an agency’s
enabling legislation would cause serious injustice and (b) the agency’s enabling
legislation suffers from serious defects in its democratic legitimacy (either in its content
or in the circumstances of its enactment).44 So, a policy that violates the underlying spirit
of an agency’s enabling legislation will be difficult to justify if adhering to the underlying
spirit would not result in significant injustice, or if the enabling legislation is rich with
democratic legitimacy. This is because an agency’s authority is derived solely from its
enabling statute. To use the authority granted by the enabling statute in ways that
undermine the very purpose of the statute is prima facie illegitimate. It is wrong in the
absence of compelling justification, such as would be available when conditions (a) and
(b) are met.
44 Fora more detailed defense of this view, see Arthur Applbaum “Democratic Legitimacy and Official
Discretion,” Philosophy and Public Affairs 21 (1992), 240-74.
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Consider, for example, a somewhat altered account of the case known as the
Tacoma Neon Wars.45 Suppose that a city had passed an ordinance requiring that one
percent of money spent on new public buildings be spent on public art, and suppose that
the intent of the ordinance was clearly to provide art that the public would enjoy.
However, the final decisions as to what art to buy were to be made by an arts council.
Would the arts council be justified in exercising its discretion to purchase art that the
public clearly disliked, on the grounds that it would improve the public’s sense of art
appreciation, and therefore be in their long-term best interests? Clearly not. This is an
obvious case in which an official ought to act in accordance with the public’s preferences
even though she thinks those preferences are mistaken. As Arthur Applbaum says, “If
democratic authority is ever a dispositive … reason, it is so here.”46
The situation with respect to the FDA and labeling is analogous to the Tacoma
Neon Wars. No one alleges that the FDCA was enacted undemocratically or is
undemocratic in its content. In fact, it is the current policy of not requiring labels that is
vulnerable to charges of illegitimacy. Not only does the policy’s content deny people the
liberty to incorporate their values into their food purchasing decisions, the policy was
enacted under substantial pressure from the Council on Competitiveness, whose
democratic legitimacy has been widely criticized.47 Further, even if labeling will result in
consumers not making optimal food purchasing decisions, this hardly amounts to an
45 “Tacoma Neon Wars,” Kennedy School of Government case C15-87-764, -765, -766
46 Applbaum, “Democratic Legitimacy and Official Discretion,” 267.
47 Michael Arndt, “Democrats Target Quayle’s Regulations Panel,” Chicago Tribune, 6 September 1992, p.
6.
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injustice. Because there is no injustice, and because there is no claim of illegitimacy, the
case for arguing that the FDA should ignore the intent of the labeling statutes of the
FDCA is very weak.
3. The Democratic Equality Argument
The Democratic Equality Argument is directed to Congress, which, as noted above,
differs from the FDA in that Congress is not constrained by the FDCA, and Congress has
a direct obligation to act as a representative body. The argument can be outlined as
follows. The decision as to whether GE foods should be labeled is a collective decision
within the purview of the citizenry. And although Congress is frequently justified in
delegating a decision within the purview of the citizenry to a scientific agency with the
authority to overrule citizens’ preferences, this is not the case with labeling. So, if the
public wants labeling (and if the FDA does not provide it), then Congress should require
it. Further, when consumers are informed about the prevalence of GE food products and
ingredients, a vast majority say that there should be labeling. It follows that Congress
should require labeling. The following sections examine each of these premises, starting
with the evidence from opinion polls.
Public Support for Labeling
Public opinion clearly supports labeling, as evidenced by the polls cited in Table 2: 48
48Pollresults compiled from Center for Food Safety, “Compilation and Analysis of Public Opinion Polls on
Genetically Engineered Foods,” Label This, “North American Public Opinion on GE Food and Labeling,”
and the Campaign to Label Genetically Engineered Foods, “ABC News Poll,” The Campaign Reporter
(August 2003).
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Table 2: Public Support for Labeling
Year Source Result
2003 ABC News 92% said “the federal government should require labels”
2001 ABC News 93% think the government should require labels
2001 Rutgers University 98% think GE foods should have special labels
2000 FDA “Virtually all participants said that bioengineered foods should
be labeled as such”
2001 Pew Initiative on Food
and Biotechnology
75% think it is “important to know if food is made with GE
ingredients”
2001 International Food
Information Council
37% support current FDA labeling policy; 58% support critics
of the FDA who call for mandatory labeling
2000 Oxygen/Markle-Pulse 85% support labeling
2000 Harris Poll 86% think the government should require labeling
2000 Texas A & M 86% want labels
2000 USA Today 79% said “it should not be legal to sell GE fruits and
vegetables without special labels”
2000 MSNBC 81% think the government should require labeling
1999 Gallup Poll 68% “want labels …, even if it means higher food costs”
1999 Grocery Manufacturers of
America
92% support labeling requirements
1999 Time Magazine 81% believe GE foods should be labeled
1998 National Federation of
Women’s Institutes
93% of women say they want labels
1997 Novartis 93% agree that GE foods should be labeled; 73% “feel
strongly” about labeling
There are, of course, well known difficulties in assessing how accurately polls
reflect public opinion and in interpreting polling results. For example, if the only polls
Page - 28 -
showing overwhelming support for labeling were done by non-governmental
organizations with clear agendas to promote, one could reasonably be skeptical of their
findings. However, overwhelming public support for labeling is consistent across polls
done by diverse groups, including news organizations, industry, academics, and the FDA
itself.49
Labeling Is Within the Purview of the Citizenry
The reason that the decision as to whether GE food should be labeled falls within the
purview of the citizenry is simply that in a democracy, this is the default for any
collective decision that does not impinge upon people’s fundamental rights or undermine
the institutions and procedures necessary for democracy. According to John Rawls, for
example, the fact that citizens are political equals implies that there is a pro tanto reason
for collective decisions to be made in accordance with the majority’s will.50 In the U.S.,
the Constitution provides the mechanism to delimit collective decisions that impinge
upon fundamental rights. Clearly, though, following the majority’s will to require
labeling would neither impinge upon people’s fundamental rights nor undermine
institutions and procedures necessary for democracy.
49 A poll conducted by Wirthlin Worldwide for the International Food Information Council (an industry
group) in May 2000 found that 69% of consumers support the FDA’s current labeling policy (down from
78% in February 1999). However, independent researchers have pointed out that several of the survey
questions gave the FDA’s current policy a “clear and positive presentation” while no explanation of an
opposing view was given. (Program on International Policy Attitudes, “U.S. Public Opinion on
Biotechnology,” http://www.americans-world.org/digest/global_issues/biotechnology/ biotech3.cfm).
50 John Rawls, A Theory of Justice rev. ed. (Cambridge: Belknap Press, 1999) 196-7, 200-1.
Page - 29 -
Justifiable Delegation Within a Democracy
Of course, even decisions that fall under the purview of the citizenry are often delegated
to scientifically-oriented administrative agencies that may overrule citizens’ preferences.
Such delegation can be justified for the reasons discussed below. However, it is important
to note at the outset that such delegation requires some sort of justification, and, as the
literature on political paternalism makes clear, a marginal increase in overall utility is not
a sufficient justification.51 Reasons that would justify such delegation include: the public
has consented to the delegation (for example, the public might consent to delegation
because it realizes that a politically insulated, scientifically oriented agency will be more
expedient or effective when making decisions about technical issues that require
scientific expertise); the agency is paternalistically justified in overruling citizen’s
preferences; and delegation is necessary to prevent the fundamentally unfair treatment of
some stakeholders. However, these reasons do not apply in the case of labeling. Consider
each in turn.
First, has the public consented to delegating the GE labeling decision, and even if
it has, would that justify ignoring the public’s preferences? To adequately address the
issue, it’s important to consider the difference between general and specific consent. A
person can give general consent to a broad range of actions, or to a single action and
whatever actions are necessary to perform the action to which one has consented.
However, the person might be more specific in giving her consent. She might consent to
very narrow actions, or she might consent to a single action and certain courses of action
necessary to perform it, but not others. So, for example, a patient might give consent to a
51 See infra notes 52 and 56 and the accompanying discussion of paternalism.
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physician to do whatever it is that will be good for her, or to whatever will cure her
cancer, both of which would be general consent. On the other hand, a patient might
consent to only a particular procedure, or she might consent to whatever will cure her
cancer except chemotherapy, both of which would be (more) specific consent. Further,
she might revoke some part of her consent, thereby making it more specific.
It is fine to operate on general consent absent more specific consent so long as
there is no reason think that there has been or would be more specific revocation. For
example, the fact that a patient has given general consent to a physician’s care does not
give the physician the right to override the patient’s clear objections to specific aspects of
her care. This is especially true when the specific revocation comes later and when the
consenter is presently contemplating the particular facts of the situation but was not doing
so at the time of general consent.
The public has given general consent to the FDA to make labeling decisions in
virtue of the facts that (1) the public elected Congress, (2) creating the FDA was within
Congress’s legitimate authority, and (3) labeling is within the FDA’s legitimate authority.
Creating an administrative agency to make certain decisions is a common example of
people “voluntarily [putting] ‘themselves under the protection of rules’ that deprive them
and others of liberties, when those liberties are unrewarding and burdensome.”52
However, the public has not given specific consent to the current policy of not requiring
GE labels. First, the original decision to not label was made primarily by the Council on
52 Joel
Feinberg, “Legal Paternalism,” in Paternalism, ed. Rolf Sartorius (Minneapolis: University of
Minnesota Press, 1983), 16.
Page - 31 -
Competitiveness without any public input.53 Second, the near-unanimous support for such
labels shown in Table 2 indicates that the public has specifically refused to give consent,
in effect revoking general consent to the FDA with regards to labels on GE foods.
One might argue that what is relevant here is not whether the public has in fact
consented to the delegation, but whether they would do so if they were well-informed.
After all, one common view is that the public’s preference for labels is based on mistaken
beliefs about the safety of GE foods, and that were people better informed, they would
change their preference, thereby giving hypothetical consent to the delegation.
However, there are good reasons to think that the specific refusal is not based on
false beliefs about safety and that it would be stable with increased information. First, the
FDA has concluded from its focus groups that most consumers “accepted as a matter of
course that the short-term safety of bioengineered foods can be determined by science,
and therefore it was not in question,” and that the “the level of knowledge about food
biotechnology was not obviously correlated with how people saw the risk/benefit
tradeoff.”54 Second, two studies commissioned by the UK conclude that providing people
with more information is unlikely to alleviate their concerns about GE food, and in many
cases, actually reinforces those concerns.55
53 Arndt, “Democrats Target Quayle’s Regulations Panel,” 6. Marlene Cimons and Donna K. H. Walters,
“U.S. Policy To Be Unveiled Today Regulates Foods Created by Genetic Engineering Like Other
Varieties,” Los Angeles Times, 26 May 1992 Home Edition, p. A1.
54 FDA, “Report on Consumer Focus Groups on Biotechnology.”
55 Barrie Gunter, Deryck Beyleveld, and Julian Kinderlerer, “Development of a Strategy to Promote the
Public’s Understanding of Biotechnology,” (United Kingdom Ministry of Agriculture, Fisheries, and Food,
Page - 32 -
If, as suggested by those two studies, the public’s preference would be stable with
greater information, this makes their specific refusal especially weighty. To see why,
consider a patient who refuses a simple, relatively risk-free medical procedure that would
likely be very beneficial. A doctor might point out the comparative risks and rewards of
the options, hoping that she would reconsider in light of better information. However, if
the patient persists even after being presented with better information, one should treat
her specific refusal as extremely weighty.
In sum, the overwhelming public support for labeling is a specific judgment at the
present time, where the public is specifically contemplating GE foods, and where that
judgment is likely to persist in the face of more information. This specific judgment takes
precedence over the earlier, more general delegation of labeling decisions. Congress
therefore cannot justify letting the FDA’s decision stand on the ground that the public has
consented to the delegation.
Paternalism is the second potential justification for ignoring the public’s desire for
labeling and the public’s specific refusal of consent. While the details of what counts as
justified paternalism are contentious, there is broad agreement about the kinds of
considerations that are relevant. First, is the public’s preference the result of impaired
decision-making capacity or ignorance of relevant facts? If it is, would that preference
persist if the public were more rational or better informed? Second, how serious is the
harm to be avoided, and is the harm reversible? Third, how significant is the proposed
constraint on liberty, and are there other, less restrictive alternatives that would also avoid
1998), 69. GM Public Debate Steering Board, “GM Nation: The Finding of the Public Debate,” (September
2003), 39-41, http://www.gmnation.org.uk/ut_09/.
Page - 33 -
the harm in question?56 Finally, is the recipient of the decision-making authority likely to
act in the best interests of the trustees? Consider how these considerations apply to
labeling.
The first question to ask in determining whether paternalism is justified is whether
consumers’ decision-making is impaired. Certainly, there are some consumers who
would avoid GE food because they are ignorant of the facts about GE food and have
mistaken beliefs about its safety. As mentioned earlier, however, there is reason to
believe that education results in a greater dislike of GE foods. For many consumers, the
preference against GE foods does not indicate ignorance of the safety of GE food, but
rather indicates that consumers make purchasing decisions based on values that include
more than mere safety. These include the value of nature and its relationship to scientific
and technological advances, values in risk perception that go beyond mere magnitude and
likelihood of harm, the value of using one’s purchasing decisions to express one’s moral
beliefs about how the country’s agricultural system should be structured, and the
considerations mentioned in the discussion of autonomy and labels above. That is, “for
the most part, it is the great range of economic, regulatory, environmental, and ethical
issues, rather than food safety or human health issues of the type science can eventually
resolve, that biotechnology’s critics are raising.”57 Thus, there is no reason to think that
most consumers’ decision-making is impaired with regard to GE foods. It is also
56 See generally Dennis Thompson, “Paternalistic Power,” chap. 6 in Legislative Ethics (Cambridge:
Harvard University Press, 1987), esp. 154-55.
57 Susanna Hornig Priest, A Grain of Truth: The Media, the Public, and Biotechnology, (Lanham, MD:
Rowman Littlefield, 2001), 8 (emphasis in original).
Page - 34 -
important to note that even if consumers’ decision-making were impaired with regard to
GE foods, that alone is not enough to justify paternalism. One must also take into account
the other considerations discussed below.
Second, are the alleged harms of labeling serious enough to justify paternalism?
These alleged harms include, first, higher prices due to the loss of certain agricultural
efficiencies (either through increased yields or easier crop management), and the cost of
labeling itself. Second, because Bt corn (a particular kind of GE corn) generally has
lower levels of mycotoxins due to the absence of the European corn borer, consumers
who choose non-Bt over Bt corn products would lose a small health benefit.58 Similarly,
those who only purchase conventionally grown soybean products rather than Roundup
Ready soybean products are likely eating food that has more harmful herbicide residues.
Note, though, that given the current products on the market, there are no other benefits
that consumers would be giving up because of labels.59
58 Eugene Nester et al., “100 Years of Bacillus Thuringiensis: A Critical Scientific Assessment,” A Report
from the American Academy of Microbiology (2002), 12, http://www.asmusa.org.
59 It is often asserted that Bt corn has less harmful pesticide residues than conventional corn, but this is
mistaken. The pests against which Bt corn is effective are not pests against which farmers normally apply
other pesticides, which are still applied to Bt corn. Gerald Nelson and Alessandro De Pinto, “GMO
Adoption and Nonmarket Effects,” in Genetically Modified Organisms in Agriculture: Economics and
Politics, ed. Gerald Nelson (San Diego: Academic Press, 2001), 74. Many of the advertised consumer
benefits of GE foods (increased nutrients, longer shelf-life, etc.) are really projected benefits from “secondgeneration”
products that are not yet on the market. See, for example, Gene Gabrowski “Food Industry
Perspective on Safety and Labeling of Biotechnology,” Ibid., 225-32. At any rate, these benefits will not be
threatened by mandatory labeling because the genetic modifications would be advertised anyway.
Page - 35 -
The loss of these benefits does not qualify as a substantial and irreversible harm;
indeed, if it did, the FDA would be well-advised to remove conventional soybeans and
corn from the market, as their consumption would be causing substantial and irreversible
harm. Clearly that is untenable. Moreover, the loss of these benefits could be avoided by
other, less restrictive means than by paternalistically depriving people of labeling
information they want (by public education, for example). The above arguments apply
regardless of whether or not the FDA is likely to make decisions that are in consumers’
best interests. However, paternalism is especially problematic where a decision-maker
may not make decisions that are in the best interests of the trustee. In fact some people
reasonably worry that the FDA will not act in the interests of consumers. It is welldocumented
that the FDA has strong ties to industry, as pointed out in the New York
Times:
Even longtime Washington hands said that the control this nascent
[agricultural biotechnology] industry exerted over its own regulatory
destiny — through the Environmental Protection Agency, the Agriculture
Department and ultimately the Food and Drug Administration — was
astonishing.60
The FDA relies almost entirely on information provided by industry in their product
evaluations. Yet industry itself shows little direct concern for consumers’ well being. As
Marion Nestle has extensively documented, “food companies – just like companies that
60 KurtEichenwald, Gina Kolata, and Melody Petersen, “Biotechnology Food: From the Lab to a Debacle,”
New York Times 25 January 2001 A1. See also Marion Nestle, “Influencing Government: Food Lobbies
and Lobbyists,” chap. 4 in Food Politics: How the Food Industry Influences Nutrition and Health
(Berkeley: University of California Press, 2002).
Page - 36 -
sell cigarettes, pharmaceuticals, or any other commodity – routinely place the needs of
stockholders over considerations of public health.” 61
One could argue that industry’s willingness to submit new GE foods to voluntary
pre-market consultations with the FDA shows that it can be trusted to act in the interests
of consumers. However, there are reasons other than consumer protection that motivate
such behavior. Specifically, industry believes that approval by a public entity is needed to
ensure consumer acceptance of its products.62 Further, by establishing a precedent for
costly pre-market review, larger firms with greater resources have been able to establish a
competitive advantage over smaller firms.63
Others argue that industry is likely to act in consumers’ interests because failure
to do so may expose them to post-market product liability. However, post-market
surveillance is unlikely to pinpoint any harms were they to occur, especially in the
absence of positive labeling.64 Thus, the likelihood of a plaintiff showing the causal
connection typically necessary for liability is small, and thus industry is unlikely to be
motivated by concerns about post-market liability.
So three important considerations for justifying paternalism fail to obtain in the
case of labeling: aversion to GE foods need not reflect significantly impaired decision-
61 Nestle, Food Politics, viii.
62 Daniel Charles, Lords of the Harvest: Biotech, Big Money, and the Future of Food (Cambridge: Perseus
Publishing 2001), 310.
63 Ibid., 134.
64 Harry A. Kuiper, et al., “Assessment of the Food Safety Issues Related to Genetically Modified Foods,”
The Plant Journal 27 no. 6 (June 2001): 505, 520.
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making capacity; the risk of harm from labeling is minimal; and there are alternative nonpaternalistic
means of avoiding what risks there are. Clearly, then, depriving people of
the information on a GE food label is not justified on paternalistic grounds.
The last question to ask in determining whether Congress should let the FDA’s
decision stand is whether following public opinion would treat the interests of some
stakeholders unfairly, and if so, is the unfairness serious enough to justify overruling
public opinion. There are three groups of stakeholders that might be treated unfairly: the
producers of GE foods, consumers who are not interested in the information provided by
labels, and those who would suffer in the future from food inadequacies absent
development of GE foods today.
Labeling would, in all likelihood, deprive some producers of GE foods of some of
their profits.65 Thompson takes this as grounds for objecting to mandatory labels, saying
that they would “groundlessly reduce the commercial viability of genetically engineered
foods and this could plausibly be interpreted as interference in the rights of the food
industry….”66 However, producers are not entitled to profits resulting from consumer
ignorance of facts about their products. Hence, the loss of those profits resulting from
informing consumers is not unfair.
It seems that consumers have a legitimate concern, namely not to pay for
information they are not interested in. However, there is the possibility that labeled GE
foods will become cheaper, thereby benefiting consumers uninterested in avoiding GE
65 Huffman, et al., “Consumer Willingness to Pay for Genetically Modified Food Labels in a Market with
Diverse Information.”
66 Thompson, Food Biotechnology in Ethical Perspective, 78.
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foods.67 Given the current prevalence of GE foods, most conventional producers would
probably opt for a label stating that their foods “may contain GE ingredients,” thus
avoiding the costs of segregation and tracking.68 Further, if the costs of labeled GE foods
were to increase too much, growers would still have the option of not planting GE crops.
Because GE crops have not significantly lowered food prices, it is unlikely that a return
to conventional crops would result in significant price increases.69 At any rate, concerns
about price increases arise in every case of mandatory labeling. Many consumers are not
interested in receiving information on various nutritional qualities of food, or on its
ingredients, yet these are required to be on the label nonetheless. Given the large
percentage of consumers who want labeling even if it means increased costs, those costs
would be an unfortunate, but not unjustified, consequence.
People suffering from food shortages have the most important interest of all the
stakeholders in this debate. While the current causes of malnutrition do not include a lack
of global agricultural capacity, it may be that in the future there will not be enough
67 Dhar and Foltz conclude that consumers of milk produced through genetic engineering actually save
$100 million annually because of the competitive effects of voluntary organic and “non-rBST” labeling.
Tirtha Dhar and Jeremy Foltz, “Market Structure and Consumer Variation in the rBST-free and Organic
Milk Markets,” Food System Research Group, Working Paper Series, FWSP2003-2, 17. Mandatory
labeling for GE foods could have a similar competitive effect.
68 Foltz, e-mail to authors, September 23, 2003.
69 Mark W. Rosegrant, for example, has found that even with full adoption of GE crops until 2010
“consumers would see little change in prices” compared to prices with complete rejection of GE crops.
“Simulation of World Market Effects: The 2010 World Market With and Without Bt Corn and GR
Soybeans,” in Nelson, ed. Genetically Modified Organisms in Agriculture, 39-45, 45.
Page - 39 -
capacity to accommodate the entire world with conventional crops. GE foods may allow
people to cultivate otherwise inhospitable land, increase productivity of current land, and
make staple crops more nutritious.70 This is certainly a powerful reason for developing
GE foods. However, it is an unpersuasive argument against labeling.
Even if GE foods will play an important role in alleviating malnutrition, public
pressure that would come from labeling is likely necessary to encourage research and
development of products designed to alleviate malnutrition. For-profit companies fund
much of the research on GE foods, but there is little prospect of direct profits from the
most clearly socially useful applications of genetic engineering. Thus, the attempt to
garner favorable publicity for and (thereby) public acceptance of GE foods may be the
only reason that socially useful developments happen at all. Daniel Charles puts the point
well:
The public welfare does not depend, to any significant extent, on the
commercial success of Roundup Ready soybeans and corn. Nor is
opposition to biotechnology depriving poverty-stricken parts of the world
of crucial tools for solving urgent problems. If anything, the opponents
have forced companies purely for the sake of public relations to share
more tools and knowledge with researchers in the developing world who
otherwise could not afford them…In short, the chaos of public argument
might actually yield an outcome that is both reasonable and wise.71
Ingo Potrykus, the lead developer of vitamin A enhanced Golden Rice (to date the
primary example of a GE food with a potential humanitarian benefit), points out that
public pressure motivated biotechnology companies to give access to their intellectual
property and allow Golden Rice seeds to be distributed for free in countries that need it.
70 Maarten Chrispeels, “Biotechnology and the Poor,” Plant Physiology 124 (September 2000): 3-6.
71 Charles, Lords of the Harvest, 312.
Page - 40 -
Thanks to the interest of the agbiotech companies to use “golden rice” for
better acceptance of the GMO technology, and thanks to the pressure
against GMOs built up by the opposition, the [intellectual property rights]
situation was easier to solve than expected.72
Thus, insofar as labeling may increase public awareness of GE foods, it may well provide
an increase rather than a decline in GE foods available for humanitarian use.
In sum, the decision to label is within the purview of the citizenry and there does
not seem to be any good reason for Congress to override the majority’s overwhelming
preference for GE labels.
A Possible Counterexample
It is important to pause here to consider the broader consequences of the view developed
here. Administrative agencies make any number of unpopular scientifically-based
decisions, and one might argue that the view presented here would require Congress to
frequently review those decisions and modify the law to circumvent them. One example
might be controversial listings of endangered species. However, the view presented in
this paper has the resources for acknowledging the legitimacy of a wide range of even
unpopular decisions, and accordingly it can distinguish between GE food labeling and
endangered species listings. First, listings enjoy much greater support than the decision
not to label GE foods, and the controversy surrounding listings does not clearly revoke
consent. Second, the perils of de-listing species are probably of greater magnitude and
more likely to be irreversible than the perils (if indeed there are any) of labeling GE
foods; thus, one could argue that listings are justified paternalistically. Third, one might
argue extinguishing species unfairly compromises the interests of future generations.
72 Ingo Potrykus, “Golden Rice and Beyond,” Plant Physiology 125 (March 2001): 1159.
Page - 41 -
Thus, the arguments presented here do not imply that Congress should circumvent
controversial listings of endangered species.73
4. Conclusion
This paper has provided two arguments for a mandatory labeling requirement for GE
foods, one concerning the FDA and one concerning Congress, the decision makers with
the clearest authority and responsibility to require labeling. The Consumer Autonomy
Argument appeals to a general democratic norm, that an administrative agency within a
democracy ought to exercise its discretion in a manner consistent with the underlying
spirit of the relevant parts of its enabling legislation. This norm can be overridden when
required by considerations of justice or legitimacy, but these considerations are absent in
the case of labeling GE foods. The Democratic Equality Argument appeals to another
general democratic norm, that the people’s representatives ought to defer to
overwhelming public opinion on collective decisions that neither impinge people’s
fundamental rights nor undermine the institutions and procedures necessary for a
democracy – considerations which are absent in the case of labeling GE foods. Moreover,
legislators frequently delegate decision-making authority to administrative agencies
whose decision-making is insulated from the vagaries of public opinion. Indeed, it is hard
to imagine how a modern state could effectively govern itself without such agencies. This
is perfectly legitimate under certain circumstances: when the public has consented to the
delegation, when the delegation meets the criteria for justified paternalism, or when the
73 The authors owe this point and the endangered species example to the
comments of an anonymous reviewer for Public Affairs Quarterly.
Page - 42 -
delegation is necessary to avoid fundamental unfairness. But this paper has argued that
none of these circumstances obtain in the case of GE labeling.
Any framework for adjudicating the labeling dispute should be sensitive to facts
about safety and health, prices, future benefits, and public opinion. Most obviously, if
public opinion were to change about labeling, that ought to be relevant to whether
Congress or the FDA should require it. On the general framework articulated here, it
clearly is relevant. Similarly, if GE foods turned out to be substantially safer or more
nutritious than their conventional counterparts, and if labeling would nonetheless deter
consumers from purchasing those products, then this should weaken the argument for
labeling. And on this general framework, it does: these facts are relevant to how the FDA
should exercise its discretion and to whether Congress is justified in paternalistically
overriding public opinion. Finally, if labels would cause prices to rise dramatically, or if
they would preclude research and development that would alleviate future malnutrition,
then the case for labeling should be weaker. Again, this is reflected in the paper’s general
framework, which acknowledges that death and disease from malnutrition are
fundamentally unfair, and economic costs to consumers are one element in determining
whether Congress is justified in overriding public opinion. Thus, it is important to note
that the paper’s conclusions are limited by the empirical facts surrounding GE foods.
This, however, is an advantage of its general framework, as it is sensitive to the moral
complexities of the actual situation.

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Volume 9 // Number 3 // Article 5

Back Issues | Index

Perceptions of Genetically Modified and Organic Foods and Processes

Consumers in industrialized countries enjoy a plethora of food choices, with increasing

Organic Food Market

Evidence from Europe

Evidence from North America

The Market for (non) Genetically Modified Foods

Respondents were comprised of students in undergraduate classes in the subject matters of

What is organic food production? Organic production is a system of farming that

What is genetic modification? Genetic modification refers to the process of

Table 1. Health statements.

Table 2. Environment statements.

Generally, consumers perceive organic food production as environmentally friendly, while

Table 3. Risk statements.

Table 5. Other consideration statements.

Discussion and Implications

General Attitudes Towards GM and Organic Food Products

Bugge, A., & Wandel, M. (1995). Forbrukerholdninger til moderne matvareproduksjon.

Latacz-Lohmann, U., & Foster, C. (1997). From ‘niche’ to ‘mainstream’—Strategies for

Wachenheim, C.J. (2004). Consumer acceptance of genetically modified food products.

© 2006 AgBioForum | Design and support provided by Express Academic Services |

The bad news is:

Question Correct answer (T/F) Why is that?

Eberhardt School of Business, University of the Pacific, Stockton, CA 95211, USA

Available online 6 September 2002.

2. The five factors of technological diffusion

2.1. Factor one: relative economic or social advantage

2.2. Factor two: compatibility with existing values

2.3. Factor three: complexity of the idea

2.4. Factor four: divisibility

3. Strategies to overcome barriers to diffusion

3.1. Directions in new product development

3.2. Actively study and monitor health and environmental impacts

3.3. Recognize and manage global markets

3.4. To label or not to label

3.5. What’s in a name?

Economic Impacts of Genetically Modified Crops on the Agri-Food Sector

4. Consumers, retailers: cascading effects

4.1. Consumers : moving fast

4.1.1. Mobilisation campaigns

4.1.2. Evolving Public Opinions

Beyond these variations, clear regularities emerge:

4.2.1. Amplifying consumer preferences

4.2.2. Types of supermarket actions

Table 4.3. Some Examples of Supermarket Actions on GMOs

o Group v. individual initiatives: Group initiatives, such as the Sainsbury consortium or

o Choice v. no choice: some supermarkets allow GM-labelled foods (Safeway; Asda);

Public reactions to information about genetically engineered

Food Science Department, the Pennsylvania State University

Public Understanding of Science, Vol. 16, No. 4, 471-488 (2007)

Couchman, P.K., Fink-Jensen, K. (1990), "Public attitudes to genetic engineering in New

Hallman, W.K., Metcalfe, J. (1993), "Public perceptions of agricultural biotechnology: a survey

Kelley, J. (1994), "Public perceptions of genetic engineering", Department of Industry, Science

Macer, D.R.J. (1992), Attitudes to Genetic Engineering: Japanese and International

Zaichowsky, J.L. (1985), "Measuring the involvement construct", Journal of Consumer

[Manual Request] [Infotrieve] [Crossref]

Center for Food Safety comments to Environmental Protection Agency on

We disagree with EPA’s preliminary finding that Cry34Ab1 is unlikely to be an