Tell USDA: Don't "cultivate" consumer confusion on biotech meat

Research Shows the Term “Cultivated” Confuses Consumers

?The U.S. Department of Agriculture (USDA) is currently asking for comments on the question of how cell-cultured, or what I like to call biotech meat, should be labelled.

After creating the Plant Based Foods Association, I spent 5 years leading that industry on labeling matters, after a 20-year career calling out junk food industry deception. Combined with my policy experience and legal practice in helping food companies comply with labeling regulations, I have a unique perspective on this matter. It's important to strike the right balance between clarity / differentiation and market appeal to consumers.

Unfortunately, much of the biotech meat lobby is favoring marketing over clarity as evidenced by the term "cultivated"

The industry's self-proclaimed leader, the Good Food Institute (GFI), has put forth consumer data to support its position for the word cultivated as the best word to use. The term appears to first come on the scene with the results of a consumer survey that GFI commissioned, conducted by a food development and marketing agency called Mattson. The survey that Mattson conducted consisted of both quantitative and qualitative data.

GFI says that “cultivated” outperformed more common phrases such as “cultured” and “cell-based” “across consumer appeal metrics". They further cite focus groups where: “nearly every participant responded positively to 'cultivated', and the plurality selected it as their top choice." And to emphasize consumer friendliness: "Focus group associations for 'cultivated' included farming, naturalness, and caring.”

Similarly, GFI rejected other terms such as "cell-based" or "cell-cultured" over concerns those terms "evoked unnaturalness sentiments from focus group participants".

GFI further justifies the phrase cultivated: “it’s also the documented best term for consumer acceptance, which is critically important this early in the life of a new industry.”

?This may be important for the industry, but not what's best for consumer clarity.

What follows is several quotes from industry representative that clearly show how the emphasis is on consumer appeal and not clarity or differentiation. For example:

• "I support cultivated as a consumer-facing term."?– UPSIDE Foods.
• "Cultivated meat is a bit friendlier, foodier,?…. and signals a bit more of the caring / precarious process needed to keep cells happy." – Mosa Meat
• "Based on the research we’ve performed, cultivated will fulfill the requirements for differentiating the product and appealing to consumers." – Aleph Farms

GFI also cites investors as liking the phrase. Why should it matter what investors think?

Study results show GFI chose to emphasize consumer acceptance over clarity

A closer look at the actual survey results of the 2019 study are revealing. Under the heading of “appeal” to consumers, the name “cultivated meat” came out on top. In contrast, the term “cell-cultured” was the most “accurately descriptive”. Similarly, the phase “cell-cultured” rose to the top for the measures intended to differentiate the product from both animal meat and plant-based meat.

?On the three measures where clarity in the marketplace is paramount, the phrase “cell-cultured” performed best. Only when the measure is “appeal” does the phrase “cultivated” come out on top.

It’s clear that GFI placed consumer appeal above all other concerns in deciding that “cultivated” is the winning descriptor.

?Moreover, the need to help consumers differentiate from animal meat is paramount. Here, it’s quite clear that the phrase “cell-cultured” performed the best, while the word “cultivated” was the least likely to help the consumer differentiate from animal meat.?

Consumers think that the word “cultivated” means farming and naturalness

What should be critically important is clarity, not acceptance. And yet, GFI summarily rejects other terms that could provide consumers with more clarity out of concern they were too off-putting. Citing one focus group finding that “cell based” was “the most associated with science”. (“I don’t want to eat a science project,” said one participant.)

Then in explaining why the group dismissed the more popularly-used “cultured meat” they say admit the term does “almost as well with consumers as ‘cultivated’. But, they add that the term “does conjure up the image of a petri dish for some people”

Then they explain that this was “why Mattson Chief Innovation and Marketing Officer Barb Stuckey wanted to find a new name in the first place”. Furthermore, GFI explains: “In the Mattson focus group, her concerns were corroborated, with multiple participants noting that “cultured” conjured up labs and hospitals and others saying it sounds aged or old.”

GFI further cites Jess Krieger, a cultivated meat scientist at Kent State University, as favoring the word “cultivated” because “’Cultivated’ meat conjures images of agriculture and natural processes, is biologically correct, and isn’t used by any major food type—it’s a great name for us to stand behind as an industry.”

Just one problem: cell-cultured meats are not farmed and are not natural. It is deceptive to use terms that consumers mistakenly think means the meat is farmed or is from other natural sources.

Rutgers researchers reject "cultivated" for being too confusing

GFI also sites a published Rutgers study performed specifically regarding cell-cultured seafood, which GFI claims found that “cultivated seafood” outperformed “cultured,” “cell-based,” and “cell-cultured” "across positivity, nutrition, imagined taste, likelihood to purchase, and naturalness.”

?(Note that the Rutgers study was funded by cell-cultured seafood company so should also be viewed with caution. With that in mind, I agree with its conclusions to prioritize the ability to distinguish from natural sources meat / seafood over acceptance.)

The Rutgers researchers considered a variety of factors, and prioritized consumer ability to differentiate above that of consumer “acceptance”, explaining that they rejected the phrase “cultivated” because of how it caused confusion. “In fact, more than half of those viewing 'Cultivated' … mistakenly thought [it meant] 'Farm Raised'."

The Rutgers authors were especially concerned with this ability to differentiate given its importance in regulation. As they put it: “Because these terms [including cultivated] failed to meet the key regulatory criterion … to distinguish the product from its conventional counterparts, they were removed from further consideration.”

While the authors were referring to FDA regulations, the same concerns apply to USDA regulations: ensuring consumers are not being misled. For example, in the USDA call for comments, they ask: "What term(s), if used in the product name of a food comprised of or containing cultured animal cells, would be potentially false or misleading to consumers?"

GFI has failed to acknowledge that the Rutgers researchers did not recommend the word “cultivated”. Instead, the authors recommended “Cell-based seafood” to, as they put it, “distinguish products from those already known to consumers and to signal allergenicity”.

In a blog post summarizing the Rutgers results, the Environmental Defense Fund explains further the problem with the word “cultivated” and how any evidence of consumer acceptance is tainted by the confusion the term causes: "More than half of consumers thought the seafood was farm-raised. Given this confusion, not surprisingly, it scored well on consumer acceptance — consistently rating no different than farm-raised seafood."

From both research studies, not only is the word “cultivated” not ideal in describing the origins of cell-cultured meat, but it also runs a significant risk of confusing consumers into thinking the product is natural.

In the plant-based context, companies are always trying to differentiate from animal meat. But that's not so when it comes to biotech meat. Companies want to claim it's "real meat". See for example, the websites of Eat Just and Upside Foods both using the word "real". This positioning is being furthered by the deliberately confusing term, "cultivated".

Tell USDA not to allow this term. We have until December 2 to submit comments here.

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