FROM LAB TO FORK CRITICAL QUESTIONS ON LABORATORY-CREATED ANIMAL PRODUCT ALTERNATIVES Acknowledgements This report was written by Dana Perls, M.C.P., Senior Food and Technology Campaigner, Friends of the Earth U.S. Friends of the Earth would like to thank Michael Hansen, Ph.D., Senior Scientist, Consumers Union for review of this report. About Friends of the Earth: About Friends of the Earth: Friends of the Earth United States, founded by David Brower in 1969, is the U.S. voice of the world’s largest federation of grassroots environmental groups, with a presence in 75 countries. Friends of the Earth works to defend the environment and champion a more healthy and just world. We have provided crucial leadership in campaigns resulting in landmark environmental laws, precedent-setting legal victories and groundbreaking reforms of domestic and international regulatory, corporate and financial institution policies. Visit www.foe.org to learn more. Any errors or omissions in this report are the responsibility of Friends of the Earth U.S. ©Copyright July 2018 by Friends of the Earth U.S. 2 Background The meat, eggs and dairy at the center of many plates, and the ways in which we typically produce them, are at the heart of some of the world’s greatest threats to the environment, public health, workers’ rights and an- imal welfare. Industrial produced animal products are amongst the most resource-intensive foods in our diet. They require massive water and energy inputs and generate significant greenhouse gas emissions, soil, air and water pollution. Industrial factory farming is carbon and resource intensive1 and costs the public billions of dollars in diet-related diseases.2,3 There are two primary approaches to addressing these problems — one, through healthier and more sustain- able ways of producing animal products, such as organic and regenerative pasture-based methods, and two, reducing consumption of animal products by moving toward plant-based diets. These alternatives to factory farmed animal products have been steadily growing in popularity and are becoming more available to con- sumers. While this is great news for human health, animal welfare and the environment, an emerging wave of animal replacement products is raising new concerns. Significant investment has been made in the research and de- velopment of non-plant based products in an attempt to mimic animal-based products, ranging from animal tissue grown from animal cell cultures made with animal serum, to proteins produced by genetically engi- neered algae and yeast. These new animal replacement products are being marketed or promoted as “clean meat,” “plant-based” or “climate-friendly,” but these claims require credible substantiation. This departure from truly plant-based foods, including legumes, tempeh and tofu, includes a batch of biotech product proposals. Memphis Meats, for example, is developing “the world’s first cultured meatball” and “cul- tured poultry,”4 by using animal serum to grow animal cells into tissues. Other companies are using genetic engineering to manufacture ingredients that mimic animal proteins. For example, Impossible Foods has ge- netically engineered yeast to produce “plant blood” (leghemoglobin “heme” protein) for its “bleeding plant- based burger,” and Finless Foods has genetically engineered algae to produce protein for its “algae-based shrimp.” In addition, several other animal replacement proposals with ingredients derived from genetically engineered yeast include Geltor’s gelatin replacement, Perfect Day’s milk replacement and Clara Foods’ egg white replacement. Growing Investment Fortunately, the plant-based sector has been growing rapidly. According to a recent study, over a 52-week period ending in August 2017, U.S. retail sales of plant-based milk alternatives generated $1.5 billion in sales, with a growth rate of 3.1%. Plant-based meat substitutes generated $555 million and had a growth rate of 6.1%.5 Other studies suggest that this market could be worth close to $6 billion by 2022.6 This positive growth has also drawn attention and interest from companies that are focused on a new wave of lab-grown meat and genetically engineered proteins. Startups like Memphis Meat raised at least $22 mil- lion in investments from Bill Gates, Cargill, DFJ Venture Capital, Richard Branson and Tyson Foods.7 Silicon Valley start-up Impossible Foods, maker of the Impossible Burger, has raised upwards of $300 million since 2011 from investors including Bill Gates, Li Ka-shing, Temasek, and Khosla Ventures.8 These new investments are not directed at truly plant-based products, but are in response to the growing market demand for plant- based foods. Highly Processed Whether made from genetically engineered yeast or through in vitro processes, these next-generation animal replacement products are manufactured in resource-intensive factories. The lab-made animal replacement products are often made with multiple processed ingredients, including gums, flavors, colors and other ad- ditives. Some products also include novel, genetically engineered ingredients like the “heme” secreted from genetically engineered yeast, which gives the Impossible Burger its “blood.” 3 Various “processing aids” are employed to make some of these genetically engineered products, including organisms (like genetically engineered bacteria, yeast and algae) that produce proteins and chemicals to ex- tract proteins. For example, chemicals like hexane are used to extract components of a food, like proteins or other compounds to make ingredients (like xanthan gum). Currently, however, disclosure of these processing aids is not required. Other processing aids (e.g. bacteria, yeast, algae), including those that are genetically engineered to produce proteins, are also not currently required to be disclosed on package labeling. The lack of transparency makes it difficult to assess the inputs and impact of their use. Key Concerns This report will examine important questions and concerns about products like “lab meat” and genetically en- gineered animal replacement products. While several methods are used to make these second-generation an- imal replacement products, there are distinctions to make among them concerning disclosure requirements, safety and environmental concerns, marketing claims, and resources required. These cost/benefit parameters are important to include in a true assessment of the health and sustainability of each production technique, each product and each product category overall. KEY QUESTIONS NEED TO BE ANSWERED BEFORE PRODUCTS ARE ALLOWED TO ENTER THE MARKET: • Are second-generation animal replacement products truly sustainable? • Are they a viable solution to the numerous problems surrounding industrial animal production? • How do these products’ environmental impacts compare to sustainably produced plant-based meat and dairy alternatives and products from animals raised in sustainable, high-welfare production systems? • Are marketing claims (such as sustainable and healthy) accurate? • Should the safety of these new products be left to individual companies to determine? • Is there adequate independent safety assessment, regulatory oversight and transparency? • Do these products and their claims meet consumer expectations? Lab-Grown Meat Genetically Engineered Proteins • Memphis Meats • Impossible Foods • Mosa Meats (Impossible Burger)9 • Just, Inc. (Formerly Hampton • Perfect Day Examples of Companies Creek) (Milk substitute)10,11, • Finless Foods • Clara Foods (Egg white substitute)12 Artificial muscle tissue is produced Yeast, bacteria and algae are in vitro by mass culturing stem cells engineered to produce proteins from animals in energy-intensive that mimic those derived from sterile conditions. plants and animals.15 The tissue is often cultured and Extraction and other processing Description of grown in solutions with bovine methods are often required to serum,13 mixes of hormones, growth isolate protein(s). Process factors, amino acids, vitamins and other food additives.14 At the time of writing, lab-grown meat has not been released onto the market. 4 • Fetal bovine serum16 Genetically engineered yeast, • Cell culture medium bacteria or algae that produce Processing Aids • Drugs and antibiotics proteins and other ingredients. (not required to be listed on in medium ingredient panel) Regulatory Requirements The company may determine the safety of the product. for Safety Assessment The FDA does not require The FDA does not require notification of new food notification of new food ingredients or processes. ingredients or processes. Manufacturing processes are GMO ingredients are currently not considered confidential business required to be labeled as such. Transparency information. Processing aids are currently Ingredients used in culture not listed on the ingredients mediums and other processing panel and can be considered aids are not required to be listed confidential. on the ingredients panel. Data on health and environmental The safety of genetically impact are often non-existent or engineered “heme” protein in Health Impacts hidden “confidential business Impossible Burger was questioned information.” by the FDA. • Use of energy, water, • Use of energy, water, feedstocks and other feedstocks and other chemical inputs. Incomplete chemical inputs. Incomplete understanding of impacts understanding of impacts throughout product life-cycle. throughout product life-cycle. • Greenhouse gas emissions, • Greenhouse gas emissions, Environmental Impacts plastics,