Language:

The Labeling system of food products derived from genome editing technology
~The Consumer Affairs Agency (CAA) acknowledged the difficulty of making it a mandatory labeling.~

On June 20, 2019, at the Food Labeling Section Meeting of the Cabinet Office Food Safety Commission, CAA acknowledged the difficulty of mandatory labeling for genome edited foods. I would like to summarize the outline based on CAA’s materials “The Labeling system of the food products derived from genome editing technology “presented in the meeting.

Background

The Ministry of Health, Labour and Welfare (MHLW) is planning to provide a specific guideline for genome edited foods from the perspective of food hygiene and to carry it out by the summer of 2019. Once this operation starts, the distribution of genome edited foods by business operators is expected to launch; Therefore, it is necessary to discuss and organize the ideal labeling methods for those food products at the same time.

While thinking of the labeling system, the following points must be considered

  1. Consumers' need for labeling;
  2. Feasibility of labeling genome edited foods;
  3. Possibility of verification to check false labeling; and,
  4. International harmonization

These points were discussed during the Food labeling Section meeting, where it was acknowledged that a mandatory labeling for genome edited foods will be difficult.

What is genome editing technology?

In general, genome editing technology allows to alter a particular part of the genome intentionally using a DNA cleaving enzyme; not only to insert external genes but also to suppress an existing gene and to substitute the base sequence. Then I would like to summarize "genome editing" technology here. The following table summarizes the "Conventional breeding technology", "Genome editing technology" and "Recombinant DNA technology" based on the MHLW's materials: "Genome editing technology and how to handle genome edited foods".

      How to handle foods derived from genome editing technology
Conventional breeding technology (mutagenesis techniques) To obtain a mutation generated through the process of natural repair, after randomly cleaving the DNA using artificial methods like irradiation or chemicals. Safety insurance by business operators (No specific regulations)
Genome editing technology [Type 1] The target DNA is cleaved to obtain a mutation generated through the process of natural repair.   Notification
[Type 2] After cleaving the target DNA, let the introduced DNA repair as a template in order to obtain a mutation.   Notification/Safety review
[Type 3] In order to obtain a mutation, the target DNA is cleaved then the introduced gene is incorporated.   Safety review
Recombinant DNA technology (so-called "genetically modified") Obtain a mutation by producing recombinant DNA molecules extracellularly and then transferring and incorporating them into living cells (to proliferate). Mandatory safety review

Source: "genome editing technology and how to handle genome edited foods (MHLW)

*Note that this conceptual diagram represents various types of cases and their handling methods.

About the labeling method

According to the results of public comments and requests to CAA, some concerns about genome edited foods and demands for labeling on those foods allowing consumers to choose have been raised among people. There are various opinions such as "We demand a rational and complete labeling so that consumers can voluntarily choose". However, when planning and operating a labelling system, it is necessary to make a handling system for the food related business operators which actually create food labels.

Examples of points to be considered:

  1. The possibility to grasp information whether the used materials are genome edited or not.
  2. Whether the required administrative burden for the maintenance of equipment and human resources for raw materials management is excessive.

The big challenge that led to the acknowledgement of the difficulty of labeling of foods derived from genome editing technology is "the verifiability of violations of the food labeling system". As for foods derived from genome editing technology which does not fall under the category of genetically modified food; currently it is difficult to establish an effective testing method in order to detect and distinguish the differences between mutations obtained by genome editing technology and a conventional breeding technology. (In the case of foods derived from genome editing technology falling under the category of genetically modified foods, it is scientifically possible to detect the foreign gene).
Also, the fact that no countries nor regions set specific rules for foods derived from genome editing technology at present might be supporting such issues.

Future schedules

In the CAA's materials on "The Labeling system of food products derived from genome editing technology", a summary as "The risk communication for foods derived from genome editing technology" is as follows.

  • Since foods derived from genome editing technology are based on new technologies which are worrying consumers, it is then necessary to accurately inform them about the contents of this technology and the differences between it and recombinant DNA technologies which have been applied for conventional selective breeding processes.
  • As described in the report of the Newly Developed Food Research Division of the Pharmaceutical Affairs and Food Sanitation Council as well, CAA will collaborate with MHLW and the Ministry of Agriculture, Forestry and Fisheries in order to implement a risk communication starting from July.

Although the difficulty of mandatory labeling for genome edited foods was acknowledged but based on the opinions by the committee during the Section Meeting, discussions will be held in various places starting from July. To whom it may interest, I recommend going through the materials of the Section Meeting.

References:
The labeling system of food products derived from genome editing technology
Genome editing technology and how to handle genome edited foods

August 2019