A Planetary Health Approach to the Labeling of Plant-Based Meat
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A Planetary Health Approach to the Labeling of
Plant-Based Meat
NICOLE E. NEGOWETTI*
ABSTRACT
In 2019, alternative proteins became mainstream. Bleeding plant-based burgers
are now available at fast-food restaurants and grocery stores across the country, and
the field of cellular agriculture-production of meat, dairy, and eggs from cells instead
of livestock-is advancing rapidly. The replacement of conventional animal products
with plant-based and cell-based alternatives signifies, for their producers and
advocates, a turning point toward a more sustainable, just, and healthy food system.
Yet, for the livestock industry, some consumer protection and environmental groups,
and natural food advocates, these Frankenfoods or fake foods represent a flawed
techno-fix. This paper explores these politicized narratives which have brought
regulatory and legal issues of naming and labeling to the forefront of FDA's and
USDA's agenda, have received congressional attention, and are also being addressed
by state legislatures proposing and passing laws to define foods, such as meat. The
health benefits and risks of both conventional and alternative meat products are focal
issues in the conflicting narratives reported in the media and communicated through
advertising campaigns. Focusing on FDA-regulated plant-based meat products that are
currently or soon-to-be on the market, this paper evaluates the appropriate role of
government in clarifying, and not further obfuscating, the issues. It does so by
analyzing the Dietary Guidelines for Americans and FDA's existing labeling guidance
and regulations regarding healthy implied nutrient content claims. The paper argues
for a broader approach to defining healthy that considers both human and planetary
health and allows consumers to compare the healthfulness of alternative products with
their conventional counterparts.
I. INTRODUCTION
In September 2019, RethinkX, an independent think tank, announced, We are on
the cusp of the deepest, fastest, most consequential disruption in food and agricultural
production since the first domestication of plants and animals ten thousand years
ago. Driving this dramatic shift are technological developments in the protein sector.
* Clinical Instructor and Lecturer on Law, Harvard Law School Animal Law and Policy Clinic, and
former Policy Director of the Good Food Institute. The author thanks FDLI for the opportunity to present
this paper at the 2019 Symposium, and in particular, Nigel Barrella for his very helpful comments. The
author also benefitted tremendously from feedback received at the Second Annual Academy of Food Law
and Policy Conference from Professors Timothy Lytton, Alexia Burnet Marks, Sarah Morath, Michael
Roberts, Joanna Sax, Susan Schneider, Steph Tai, and Diana Winters.
1 RETHINKX, RETHINKING FOOD AND AGRICULTURE 2020-2030 6 (2019),
https://www.rethinkx.com/food-and-agriculture#food-and-agriculture-download [https://perma.cc/AH3T-
XXJX].
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A Planetary Health Approach to the Labeling of Plant-Based Meat
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