Submit YOUR comments on GMO Labeling Rules NOW!

Rural Vermont just submitted our official comments to the USDA in response to their draft GMO labeling rules. There is still time to submit yours! They're due July 3rd.


Re: Docket No. AMS-TM-17-0050

Rural Vermont (aka Rural Education Action Project) is one of the core organizations in the Vermont Right to Know GMOs coalition that worked for four years to successfully pass Vermont’s first-in-the-nation, no strings attached, clear and concise GMO Food Labeling Law – Act 120 (2014). During the four-year grassroots campaign to pass Vermont’s law, we engaged over 10,000 citizens, many of whom testified before legislative committees and/or at the numerous public hearings that were held by the Vermont Legislature. These citizens unequivocally expressed their desire to know whether the food they purchase, consume, and feed to their families is genetically engineered. They also made it clear that they wanted Vermont’s labeling law to be clear and provide easily understandable and accessible information directly on food packages they could use to make their food purchasing choices. In representing many of these concerned citizens, Rural Vermont requests that the Agency adopt the following:

TOP PRIORITY:            It is crucial that the USDA reject “QR codes” and any other options for on-package labels that clearly discriminate against consumers and are not transparent. Labels of any kind that require the use of a “smartphone” and a functional connection to the Internet to be used are inherently discriminatory – according to the Pew Research Center, as much as one third of Americans do not have a smartphone and we know that this percentage is much higher in rural states like Vermont where many communities still don’t have broadband service. QR codes or other so-called “smart labels” would especially discriminate against low-income, minority, and elderly populations – known to disproportionally lack access to these technologies. The USDA’s own 2017 study demonstrated this.  Even for those who do have access to smartphones and Wi-Fi – it is an undue burden and barrier for consumers trying to get the grocery shopping done for their family to stop, scan a package, connect to the internet and spend time reading tiny text on their phone.

In addition, providing access to product information via on-package website URLs or text messaging should also be opposed, as it is equally discriminatory to the same groups of citizens. These methods are time-consuming, require access to technologies by consumers, and act as a disincentive for true transparency. This indirect form of food labeling would be unprecedented. Rural Vermont urges the USDA to require clear, easy to read, on-package labels using clear language and/or symbols that are easily understandable and unbiased.


1.         Do not prohibit or otherwise constrain the use of well-understood food labeling terms, such as GE or GMO. These terms have been in common usage in the public sphere for decades. USDA’s proposed restriction on the use of the terms “genetic engineering,” and “GMO,” despite their familiarity for consumers, food companies, and state and federal regulators will only serve to create confusion and a further lack of transparency. The proposed new term “bioengineered,” and its accompanying obscure acronym “BE,” does not meet the needs of consumers.  In addition, many companies have already invested time and resources in labeling their products using the well-understood terminology “GMO,” or “GE,” and USDA must not thwart these responsible efforts by restricting their use.

2.         Any proposed visual symbol to be used as disclosure labels on packages MUST BE NEUTRAL. We acknowledge that the federal disclosure law allows companies to choose to use symbols instead of text on their labels. However, two of three proposed symbols are objectively and unashamedly pro-GE / Biotech. Boldly biased symbols such as the “sun/smiley face” are an insult to consumers. The USDA should eliminate these clearly biased options for symbols, and again, require any visual symbol used to label packaging be neutral and utilize the broadly recognized acronyms “GE,” or “GMO.”

3.         It is essential, in providing meaningful information to consumers, that any labeling requirement include all processed foods produced with genetic engineering. It is widely understood that the overwhelming majority of GE foods are not whole foods, but processed foods, made with GE commodity crops such as corn, soy, canola, and sugar derived from GE beets, including cooking oils, sodas, and candies. These products must be required to be disclosed as GE. By potentially leaving these products out of the labeling requirements, it is likely that that hundreds of GE foods will not be labeled and the consumer’s right to know will be curtailed. Any labeling standard must include ALL GE products regardless of how highly refined they are so that consumers are not deceived or mis-informed.

4.         It is also critical that labeling disclosure rules include future food products made with forms of genetic engineering that are not yet in use or even considered.  Food & chemical corporations are vigorously experimenting with new forms of manipulating the genetics of food crops including gene-editing. The little understood, but increasingly used, so-called CRISPR technology is being used on such common food as oranges, cacao, potatoes, soy, and canola. USDA must ensure that foods made with any of these emerging forms of genetic engineering are included in the labeling disclosure requirement.

5.         In the proposed rules, USDA offers two options for GE content in food that arises from inadvertent contamination at some point in the supply chain.  Disclosure of this contamination would only be required if unintentional GE contamination exceeded 0.9% or 5% of the specific ingredient (by weight). We insist that the 0.9% threshold is the right one to use because it is high enough to cover contamination; has long been established in the European Union and so would facilitate trade with EU countries; and it further comports with the existing standards being used by many U.S. food companies.  A third potential option which would permit even intentional use of a GMO ingredient in a food product up to 5% of the entire item's weight, would effectively exempt the great majority of GE foods from mandatory labeling and is completely unacceptable.

6.         A large percentage of American consumers have been demanding that the presence of genetic engineering in their food be disclosed for more than a decade. A uniform federal requirement for disclosure is long overdue.  Please do not postpone the labeling requirement to 2022 as currently proposed. The labeling law requires regulations be finalized by July 29, 2018. However, USDA’s proposed rules would allow companies to further postpone GMO labeling until as late as 2022. This kind of delay is negligent and unfair to the many companies that have taken their responsibility to their customers seriously and are already labeling. The USDA must require companies to use GMO content disclosure labels by no later January 1, 2020.

We appreciate your consideration of these comments and look forward to receiving your response.

Rural Vermont
46 East State Street
Montpelier, VT 05602


Coco Moseley