Don’t Call It “Lab-Grown’: Upside Foods Responds to USDA’s Labeling Plans for Cultivated Meat

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Meat made via harvesting cells from animals should, in the future, be referred to as “cultivated” meat according to alt-protein company Upside Foods.

The comment is in response to the United States Department of Agriculture’s advance notice of proposed rulemaking (ANPR) around labeling cultured meat titled “Labeling of Meat and Poultry Products Comprised of or Containing Cultured Animal Cells.”

The point of the ANPR is to establish clarity around labeling cultivated meat when it reaches consumers on a more widespread basis and to avoid false or misleading claims on the labels of products. 

There are hurdles before those products arrive on store shelves or in restaurants. Currently, just one company in the world, Eat Just, has regulatory clearance to sell cultivated meat and only in Singapore.

In the US, the rulemaking process around labeling will be an important one for cultivated meat, and public comments, including those of companies in the cultivated meat industry, are a critical part of this process. That comment period ended last week.

“The labeling of cultivated meat and poultry products will be a crucial component of how our industry conveys the basic nature, essential characteristics, and value of these products to consumers,” Upside Foods said in its commentary to the USDA.

Image courtesy of Upside Foods.

A framework for labeling cultivated meat

In September, the USDA’s Food Safety and Inspection Service (FSIS) published its ANPR and called for public comments around the labeling of “meat and poultry products derived from animal cells.” The ANPR follows a formal agreement from 2019 between the USDA and the US Food and Drug Administration (FDA) to jointly oversee production of cultured meat in the US including cell collection, growth, and harvest as well as factors like packaging and labeling. 

Labeling of cultured meat products minus seafood falls under FSIS jurisdiction, hence the call for public comments published a few months ago from the USDA. 

FSIS is seeking comments on terms that should be in the name of cultivated meat products, whether the products should be labeled differently from traditional meat, what terms might be false or misleading, and whether companies should designate variations in appearance, color, and taste between cultivated meat and traditional.

Image courtesy of Upside Foods.

Upside’s take

Upside was formed back in 2015 (under the name Memphis Meats), which makes the company something of an old guard when it comes to cultivated meat.

The company claims a number of high-profile investors including Bill Gates and Kimball Musk. Upside was aiming for regulatory approval by the end of 2021 for its cultivated chicken, which is made by harvesting the cells of real chickens and “growing” the meat in reactors. That regulatory approval is still forthcoming, though the company did complete construction on a new production facility in Emeryville, California, that will be used for the manufacturing of cultivated meat. 

A few key highlights from the company’s 15-page commentary in response to the USDA/FSIS ANPR include:

  • Upside believes it is important to differentiate through labeling cultivated meat products from those made from slaughtered meat or poultry.
  • The company says the word “cultivated” is the most apt descriptor for these products versus other common terms (see below). According to Upside, consumer research supports the term “especially when provided alongside language noting that the product is derived from the ‘cells’ of a specific food animal.”
  • Product labeling should “clearly communicate” the source and production process for cultivated products.
Image courtesy of Upside Foods.

What not to call cultivated meat

Upside is also very clear about terminology it believes should not land on the labels of cultivated meat products. Those three main words or phrases are “lab-grown” or “lab-based,” “synthetic,” and “fake.”

“Lab-grown” and its derivatives indicate that cultivated meat would always be made in a lab, when in reality, once it scales it would most likely be made in a food production-like environment (though this point is still up for debate).

Synthetic anything denotes a chemical process by human agency, according to Upside. Since cultivated meat cells are harvested from the actual animals and undergo a similar biological process in a facility they would inside an animal’s body, the term “synthetic” would be inaccurate.

Meanwhile, Upside calls “fake” an “overtly disparaging term” since the cultivated meat involves actual animals to exist in the first place.

Upside’s entire commentary can be read here along with other public comments in response to the ANPR.

Lead image courtesy of Upside Foods.


  • Jenn Marston

    Jenn Marston is a writer and editor covering technology’s impact on food and agriculture systems and their surrounding communities. Prior to Green Queen, she was Senior Editor for food tech publication The Spoon and, before that, Managing Editor for Gigaom Research. She is devoted to helping educate and raise awareness about sustainable businesses, healthier and waste-free lifestyles, and other ways we can collectively build a better food system. She lives in Tennessee and has an enormous vegetable garden.

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