products, as it is a complex endeavor. However, their intention of
production and use, often followed by a higher level of processing,
places them in this category.

Discussion

Systematizing the nomenclature of animal food alternatives refers to organizing and standardizing the currently used names to describe them. Our goal is to make the existing terminology consistent and clear across different disciplines, cultures, and sectors. The current ambiguity in nomenclature is best highlighted in the definition of meat alternative given by Wikipedia: "A meat alternative or meat substitute (also called plant-based meat or fake meat, sometimes pejoratively) is a food product made from vegetarian or vegan ingredients, eaten as a replacement for meat" (32). The scientific literature also abounds with such statements (5, 7, 8). To present a brief review of the recent works, Knaapila et al. (33) state that food products crafted from protein-rich, non-animal sources, designed to resemble meat and be used instead of meat are commonly known as meat analogs, meat substitutes, or meat alternatives. While these terms are often used interchangeably in the literature (34), there can be variations in their specific definitions among different authors. In recent studies focusing on the production of such products using extrusion technology, the term meat analog has frequently been employed (31, 35–40). Some define meat analogs as replacers of meat and meat products in their functionality while being similar in terms of sensory properties, particularly taste, aroma, and texture, as well as nutritional value (41–43). Kumar et al. (44) define meat analog as "a food product that approximates the esthetic qualities and/or chemical characteristics of certain types of meat." Fiorentini et al. (8) state that "plant-based products with meat-like sensory attributes are often referred to as meat analogs, plant-based, or imitation meat." Banerjee et al. (45) state meat analogs are also imitation meat, since they imitate the esthetic qualities of regular animal meat in terms of texture, flavor, and appearance. Meat substitutes have been defined by Elzerman et al. (46) as products specifically developed to be consumed "instead" of meat. On the other hand, they defined meat alternatives as other products that are commonly consumed as protein sources in vegetarian meals, such as pulses and nuts. However, Choudhury et al. (47) considered plant-based meat alternatives as sustainable protein sources that can replicate "the taste, texture, color, and nutritional profile of specific types of meat."

Based on these studies, it is evident that a consensus regarding the terminology for these products has not been universally established (33). Therefore, to promote clarity and efficient communication within the plant-based food industry and among scientists, nutritionists, health professionals, consumers, and social media, we found it timely and appropriate to offer clear definitions for the commonly used terminology. This will help reduce confusion and improve understanding of the various plant-based options.

Sha et al. (4) have suggested that adhering to terms such as “meat alternative” rather than “meat analog” “would better serve the purpose of delivering sustainable protein supply,” as plant-based protein products are unlikely to replace regular meat and poultry products. The authors argue that “by doing so, the industry would avoid many of the controversies and obstacles generated from the practice of mimicking animal meat and eliminate unnecessary consumer expectations. This approach would allow scientists and food

processors to focus on the development of the best possible
organoleptic and nutritious qualities of food from sustainable plant
proteins to feed the ever-increasing global population." However, as
"meat analog" is the most commonly used term, it would
be impractical to eliminate it from the existing terminology. Moreover,
despite the predicted increase in meat consumption (48), the rise in
the production of these plant-based products is projected to continue
as a response to their increasing demand (3). Additionally, the
proposed definition of analog here considers both "organoleptic" and
"nutritious" qualities, therefore, meeting the concern of the authors.

Moreover, we acknowledge the initiative by Plant Based Foods Association (PBFA) (49) to develop voluntary standards for labeling plant-based meats, milk, and yogurt in the United States. For meat, these labels include referencing the types of meat (e.g., meat, hamburger, sausage, chicken, pork) in terms of their flavor, texture, or style of preparation, the form or the type they take (e.g., nuggets, tenders, burger, patties), and qualifiers that indicate if the product is plant-based (i.e., consists mainly of ingredients derived from plants and does not contain animal ingredients of any kind), vegetarian (i.e., consists mainly of ingredients derived from plants but may contain small amounts of animal-derived ingredients, such as eggs or milk, but does not contain meat from any animal), or vegan (i.e., does not contain animal ingredients of any kind). While this information is necessary on a label, and we add that it should also contain the various additives, a systematic nomenclature is also needed at a higher level of classification that distinguishes between different terms.

In addition to our efforts, some plant-based food companies are working to standardize their product labeling to improve consumer comprehension and bolster marketing. Overall, systematizing the nomenclature for animal food alternatives is an ongoing process aimed at enhancing the precision and consistency of the terminology and facilitating greater understanding and transparency within different sectors.

Finally, the primary objective of this article is to enhance precision and consistency in the description of food components, fostering a shared understanding and transparency across various sectors. It is crucial to acknowledge that the dynamic nature of the food industry continually introduces new products to the market. As a result, our established terminology may not necessarily provide an unconditional fit for emerging and innovative food options. While this work serves as a valuable foundation, ongoing efforts are required to adapt and evolve the terminology to encompass these growing food products. By embracing the industry's dynamic nature and promoting continuing dialog and research, we can strive to ensure accurate and effective communication in the realm of food components.

Data availability statement

The original contributions presented in the study are included in the article/supplementary material, further inquiries can be directed to the corresponding author.

Author contributions

NA and RS-S developed the content, drafted and edited the
manuscript, and share the first authorship, JS developed the concept
and content and edited the manuscript. All authors contributed to the article and approved the submitted version.

## Conflict of interest

The authors declare that this work was conducted without any commercial or financial relationships that could be construed as a potential conflict of interest.

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<figure><img src="image_35.png" /></figure>

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EDITED BY

Fang Fang,
IEH Laboratories and Consulting Group,
United States

REVIEWED BY

Jinsha Li,
Archer Daniels Midland, United States
Ionica Oncioiu,
Titu Maiorescu University, Romania

*CORRESPONDENCE

Cother Hajat

chajat@doctors.org.uk

RECEIVED 29 March 2023

ACCEPTED 27 June 2023

PUBLISHED 12 July 2023

CITATION

Attwood S, Jameel S, Fuseini A, AlKhalawi E and Hajat C (2023) Halal cultivated meat: an untapped opportunity.
*Front. Nutr.* 10:1196475.

doi: 10.3389/fnut.2023.1196475

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# Halal cultivated meat: an untapped opportunity

Sophie Attwood<fnref n="1" />, Shahid Jameel², Awal Fuseini³, Eman AlKhalawi⁴ and Cother Hajat<fnref n="1" />,⁵*

The global Halal food market is forecast to reach US$1.67 trillion by 2025, growing to meet the dietary demands of a rapidly increasing Muslim population, set to comprise 30% of the global population by mid-century. Meat consumption levels are increasing in many Muslim countries, with important implications for health and environmental sustainability. Alt protein products are currently being manufactured and positioned as one possible solution to reduce the environmental impact of meat consumption, yet, little is currently known about the Halal status of these products, nor the extent to which they appeal to Muslim consumers in emerging markets in Asia and Africa. Here, we explore key considerations regarding the acceptability of alt protein products for Muslim consumers, explore Halal certification requirements in the context of cultivated meat, and examine some unique beliefs within the Islamic faith that may support, as well as impede, widespread adoption of alt protein among the 2.8 billion Muslims of the future.

KEYWORDS

alternative protein, plant-based, halal, sustainable diet, cultivated meat and dairy

Introduction

The role that alternative ('alt') proteins, particularly alt meat, will play in transitioning the world's population to more sustainable eating patterns is hotly debated. Some commentators suggest that investment in alt protein technologies can reduce greenhouse gas (GHG) emissions over 11 times more than other green technology investments (1). However, others are more skeptical about these numbers, and are concerned that the emissions reduction potential of alt protein will be limited by its inability to displace meat and dairy products in peoples' diets.

Fermented, hybrid or cultivated (i.e., cell-based or cell-cultured) proteins (see Table 1 for definitions and examples) are entirely new concepts to many consumers, and are viewed with hesitation, citing concerns about naturalness, healthiness, compliance with dietary requirements, and overall safety (3). As a result, to benefit climate and biodiversity in a meaningful way, companies that produce and market alt proteins must carefully consider how to address consumer reticence. The overriding goal here is to promote habitual purchasing, beyond initial hype, and encourage direct substitution of animal-based products (4). This will be a complex task given that our diets have otherwise been shaped over millennia by a huge range of factors, including local culture, climate, agricultural practices, the food industry, trade, social relations and belief systems.

Here, we explore religious belief as one highly influential, yet often overlooked factor that influences the food choices of billions worldwide. At present, around 85% of the global population identify with a particular religion (5), many of which issue clear guidance on the

<footnote n="1">¹Real World Health, Oxford, United Kingdom, ²Oxford Centre for Islamic Studies and Green Templeton College, Oxford, United Kingdom, ³Huddersfield Business School, University of Huddersfield, Huddersfield, United Kingdom, ⁴Department of Family and Community Medicine, King Abdulaziz University, Jeddah, Saudi Arabia, ⁵Public Health Institute, United Arab Emirates University, Abu Dhabi, United Arab Emirates</footnote>
<table><caption>TABLE 1 Definitions and examples of different types of alternative protein, reproduced from Hajat and Parkin (2).</caption><thead><tr><td>Name</td><td>Brief description</td><td>Example</td></tr></thead><tbody><tr><td>Plant-based</td><td>These products use plant-based ingredients, such as beans, peas, lentils, and soy to create meat substitute products.</td><td>One market leader is Beyond Meat, which produces burgers and sausages from pea, mung and fava beans and brown rice. Beetroot and apple extract are added to mimic the coloring of meat.</td></tr><tr><td>Cultivated meat</td><td>In vitro laboratory grown meat from cultured cells. Also known as cell-cultivated, cell-based or cell-cultured meat.</td><td>The first ever commercial sale of cultivated meat was by an American start-up, Eat Just, in 2013, served in a restaurant in Singapore. Whilst still not widely available in many regions, there are rapid developments in this industry. Companies producing these products include Memphis Meat and Mosa Meats Inc.</td></tr><tr><td>Fermentation-derived processes</td><td>Traditional fermentation uses microbial anaerobic digestion to improve the taste or functionality of plant-based ingredients. Biomass fermentation involve the rapid growth of microorganisms which form the basis of the product Precision fermentation uses microorganisms as hosts to produce specific ingredients used in alt-meat.</td><td>Soybeans are fermented into tempeh. Mycoprotien Quorn is made from fermenting fungal spores. The heme protein (soy leghemoglobin) added to the Impossible Food burger to improve its distinctive meaty flavor.</td></tr><tr><td>Hybrid products</td><td>Produced by combining reduced portions of animal-based meat, or cultivated ingredients (i.e., fat) with plant-based ingredients.</td><td>The Rebel Meat 'semi- vegetarian' burger contains 50% beef and 50% plant-based ingredients.</td></tr><tr><td>Insects</td><td>Processed edible insects, consumed either whole or ground, and used as ingredients to enhance the nutrient profile of existing products.</td><td>Fazer, a Finnish company that manufactures bread using cricket flour, and Eat Grub produce energy bars enriched with cricket powder.</td></tr><tr><td>Algae</td><td>Processed edible algae, mainly used as food ingredients or dietary supplements.</td><td>Examples include Spirulina or Chlorella.</td></tr></tbody></table>

types of food considered acceptable to eat. Examples include the vegetarian diet recommended for Hindus, Buddhists and Jains, Islam's guidance on Halal and Haram foods, and the Jewish Kosher diet, amongst others. Despite such ubiquity, the role that religious beliefs play in shaping food choices is often neglected by companies developing and manufacturing novel foods. This represents a considerable missed opportunity, especially in the context of the Islamic faith, as we explore below.

## The Muslim market for meat

The global Muslim population is predicted to grow to 2.8 billion people by mid-century, comprising around 30% of the world's population, with most of this expansion occurring in Asia and Africa (6). By then, it is estimated that India, a Hindu majority country, will be home to an estimated 310 million followers, the most of any nation in the world (6). By contrast, most investment and research into alt protein has so far occurred in the United States (US), which is a majority Christian country with a secular innovation ecosystem, followed by Israel, which is primarily Jewish (7).

The projected increase in the world's Muslim population in Asia and Africa will likely coincide with economic transitions in these regions. Rising income levels tend to lead to dietary changes as more people consume higher value foods, usually those rich in animal protein (8). This is demonstrated in Figure 1, which displays the countries that are estimated to be home to the largest Muslim populations by 2030, and projected changes in meat consumption (i.e., sheep, beef, veal and poultry, combined), from baseline year 2023 (9). Relative increases in meat intake range from 3 to 17%, are highest in India (noting the lower baseline meat consumption level in this

country), with only Nigeria registering a decrease from 2023 consumption levels.

## The halal market and dietary requirements

Adherents to Islam are asked to follow a 'Halal' diet, which refers to consumption of food and drink consistent with Islamic dietary laws. Box 1, below, outlines Halal requirements, with meat a major focus area. This guidance states that animals must be slaughtered in a prescribed way, and certain types of meat and by-products – including pork and blood products – eschewed. To support Muslims to follow a Halal diet, acceptable foods are certified by different Islamic bodies around the world. These organizations work to ensure that all aspects of production meet necessary requirements, additives and preservatives are Halal compliant, and that meat products have been derived from permissible animals that are slaughtered according to Islamic guidelines (10).

The global Halal food market was valued at US$ 1.27 trillion in 2021 and is forecast to grow, reaching US$ 1.67 trillion by 2025 (for context, global Kosher market revenue was under US$ 20 billion in 2021) (11, 12). In 2020, the trading bloc known as the Organization of Islamic Cooperation (OIC) reported a Halal food export deficit of around US$ 67 billion, indicating strong reliance on imports into major Muslim markets. The greatest volume of this trade comes from non-Muslim producer countries Brazil, India, the US and Russia. Here, technologies that ensure traceability of imported products are essential for consumer trust, and innovation in this area is growing. Most recently, this has included blockchain-enabled platforms to track the origin of Halal meat, and DNA testing kits to ensure
<figure><img src="image_36.png" /><figcaption>FIGURE 1</figcaption></figure>

Projected change in meat intake in the most populous Muslim countries by 2030. Data from the OECD FAO Agricultural Output 2022–2023 (9); estimated percentage (%) increase in kcal/capita/day of beef, veal, sheep and poultry meat for the entire population between 2023 and 2030. Non-halal pig meat excluded as default. Population estimates for different religious group in 2030 provide by Pew Research Centre (6). To note, no baseline data is currently available to estimate changes in meat intake in Bangladesh, Afghanistan, and Iraq – predicted to be home to the world's 4th, 9th, and 10th largest Muslim populations by 2030.

imported meat has not been tainted with forbidden animal-based products (13).

Trade imbalance represents a potential food security risk for many Halal markets. This is particularly true for Muslim-majority countries in the Gulf region which, due to climate and terrain, have limited

capacity for in-country livestock farming and agriculture to meet national demand, and currently import over 85% of their food and around 62% of their meat (14). As such, alt proteins are not only being considered as potential solutions to climate change, but, if locally produced, can also support national food security goals alongside

BOX 1: Halal Dietary Guidelines.

o Meat from animals that are permissible and slaughtered in the prescribed way by mentioning the name of Allah (and no other gods or persons)

o Free from any part (or substance) taken or extracted from animals forbidden to be consumed by Muslims.

o Free from any substance declared as unclean according to Islamic law (including products considered to be contaminated with filth*)

o Prepared, processed, produced, or manufactured using utensils, equipment, and/or machinery which are free from any substance declared as unclean according to Islamic law.

o Not contaminated by any food or materials during preparation, processing or storage that do not fulfil the above requirements.

o Plants – all types of plants and their products or derivatives are Halal and can be eaten except if poisonous, intoxicating, and harmful to human health.

o Drinks – all forms of water are Halal, except if poisonous, contain Haram materials, are intoxicating or are harmful to human health. Alcoholic and intoxicating drinks are forbidden. Water mixed with filthy liquids or food laced with wine and alcohol are also not permissible.

o Arising from the idea of 'clean' is the concept of 'tayyib', which refers to good, pleasant, wholesome, agreeable and delicious, as opposed to 'khabith', which refers to impure, harmful and disgusting. Upholding the requirement of 'tayyib' in the processing of food includes maximizing hygiene and minimizing contamination.

*Filth, according to Islamic law, includes substances such as pork, blood and carcasses (carrion) which are filth by themselves and cannot be accepted as clean. It also includes otherwise clean substances that are contaminated by filth Adapted from Amabli et al. (16).
other innovations like vertical, urban and seawater farming, genetically modified crops and precision agriculture (15).

## Addressing ethical and religious concerns

If alt protein companies are to succeed in attracting a substantial share of the global Muslim meat market, a fundamental question is whether different types of alt protein can even be certified as Halal. Whilst generally unproblematic from the perspective of 100% plant-based meat analogs, cultivated and hybrid products contain cells derived directly from animals. As yet, no clear guidance has been issued by any Halal certification body regarding the status of these products.

When attempting to address this point, scholars have considered various perspectives; for example, some have argued that cultivated meat contravenes Islam's 'Natural Law', as the production process can be seen as 'playing God' (17). Further complications arise from the fact that cultivated meat was originally intended to be made from cells harvested from live animals, rather than those slaughtered. This implies that the resulting cultivated product may not be Halal, unless cells were extracted from a permissible animal slaughtered according to Islamic guidance (17). Indeed, this is one of six key principles that a recent review on the topic suggests must be met in order that cultivated meat can be considered Halal, and is arguably one of the most important hurdles to overcome if cultivated meat products are deemed acceptable for Muslims to eat [see Kashim et al. (18) for an in-depth perspective on this issue]. In his book on animal welfare in Islam, Masri reported that extracting parts of live animals to eat was considered a delicacy in pre-Islamic Arabia, but the practice was subsequently outlawed by the Prophet Mohammed (PBUH) (19).

Another issue of concern for Muslim consumers is the use of cell culture media that are inconsistent with Halal laws. For instance, in many cases, the media in which extracted cells are developed contains fetal bovine serum, which is post-clotted blood fluid obtained from unborn cattle. Blood is considered unclean according to Islamic scriptures [Quran 5:3], and this point has been specifically highlighted by the Malaysian Halal standard (MS 1500/2019) (20). More recently, however, wholly plant-based media have been developed, helping allay the concerns of Halal consumers regarding fetal bovine serum, as well as addressing the requirements of other consumer segments, such as ethical vegans and vegetarians (21).

Similarly, some of the concerns around the acceptability of cultivated meat for Muslim consumers are shared by devotees of other religions. For Jewish consumers who follow Kosher guidance, the Chief Rabbi in Israel ruled for the first time in January 2023 that cultivated steak could be considered a Kosher product (22). This represents one of the first steps toward cultivated foods receiving widespread Kosher certification in the country, and is pivotal move for Israel, which is already home to 57 alt protein start-ups and has declared food technology a national research priority (7). The extent to which similar conclusions will be arrived at by Islamic religious leaders remains to be determined. In 2022, the Assembly of Muslim Jurists of America deemed cultivated meat provisionally permissible by default, provided that the above-mentioned Halal criteria are met. However, an ultimate ruling on the issue will

depend on how the technology develops in relation to the source of used stem-cells, additives and the broader health impacts of these products (23). We note that investment in these technologies is also a priority for Muslim competitive markets in the Middle East, particularly the United Arab Emirates (UAE) (24). Abu Dhabi launched their Xprize 'Feed the Next Billion' initiative to specifically fund research into development of alt proteins the country (25), and the Middle East's first plant-based meat factory recently opened in Dubai (26).

## Other factors influencing alt protein adoption in Muslim markets

If and when the issue of Halal certification is resolved, the question of how to boost the appeal of alt proteins to Muslim consumers still remains. Relatively little research exploring Muslim consumers' perceptions of alt protein is currently available, although the data that does exist suggests potentially greater willingness to try these products compared to non-Muslim consumers (27). For example, one recent study comparing the preferences of British Muslim and Non-Muslim consumers found significantly greater willingness to purchase cultivated meat amongst Muslim consumers, and greater willingness to pay extra for these novel products (28).

Muslim consumers otherwise share many of the same perceived barriers and facilitators to eating alt protein as are observed in other consumer groups across a wide range of countries (28). For example, where research has been conducted, acceptance of novel proteins, particularly cultivated meat, tends to be higher when consumers are more familiar with these products, have lower food neophobia scores, when they taste better, are more affordable, and when consumers are informed of their potential health and environmental benefits compared to traditional meat and dairy (3, 28).

Additionally, there is a range of more specific factors unique to Muslim consumers that are relevant to consider. For example, given that plant-based, hybrid and cultivated products can all be produced in highly controlled environments, this may limit the potential for contamination with non-Halal animal ingredients during production, thereby overcoming fears around product impurity. This is especially likely for cultivated products if the manufacturing process is reviewed and certified by a credible Halal authority that Muslim consumers already know and trust (29).

Availability of plant-based meat alternatives may also circumvent the issue of whether meat should be stunned prior to slaughter, which is generally considered more humane, but some believe is inconsistent with Halal rules (30, 31). Although Islam emphasizes the importance of animal welfare before and throughout the slaughter process, modern farming practices may fail to maintain these principles. As a result, consumers looking for Halal products that ensure animal welfare may be left with few options. More broadly, other qualitative research has revealed that some Muslim consumers recognize additional potential benefits of cultivated meat for the Halal economy, both in terms creating new jobs for halal meat scientists, as well as helping to grow Muslim-owned food businesses (29). Greater adoption of cultivated meat may also be viewed by some Islamic jurists and Halal consumers as a step toward Khilafa (guardianship of nature) [Quran 10:14], which is an important principle related to
environmental sustainability. Here, Islamic law states that any new rulings must align with the objective of attaining welfare and warding off harm. As such, the adoption of a diet with a lower environmental impact, *via* consumption of alt protein products, may be considered a way to uphold at least two of the five key principles: the preservation of life and linage.

We also note various other well-known Islamic teachings with implications for health and diet, which may also support movement away from excess meat consumption in Muslim populations. These include the recommendation to avoid wasting food (i.e., *"Eat and drink and do not waste, for God does not love the wasteful."* [Quran 7:31]), and the Hadeeth (Prophet's saying) to moderate intake (i.e., *"No child of Adam fills a container worse than his stomach. A few morsels that keep his back upright are sufficient for him. If he has to, then he should keep one-third for food, one-third for drink and one third for his breathing."* [Jami' at-Tirmidhi (2380), Volume 37, Hadith 77]). In addition, regular fasting is also encouraged, as is taking care of one's body, as per the saying of the Prophet in response to one of his companions fasting daily *"... your body has a right over you"* [Sahih Al-Bukhari (1977), Volume 30, Hadith 198].

Academic research has proven that religiosity can play a significant role in promoting behavior change, including pro-environmental actions. For example, a recent study by Hassan et al. found that Muslim diners were keen to avoid wasting food to adhere to teachings within the Quran (32). As such, influential Muslims, including Islamic religious leaders, have potential to play an extremely important role in encouraging sustainable and healthy behavioral change, and should be included as key stakeholders in the sustainable diets movement in any Muslim majority country where this is a priority national agenda item (33, 34).

## Conclusion

Muslim consumers' concerns regarding alt protein are currently poorly understood and rarely addressed by manufacturers of alt protein products. This is despite tremendous potential for market adoption, given the rapid growth and dietary transition occurring in many Muslim populations worldwide. In this piece, we outline key questions that require answering before widespread adoption of alt proteins is likely in Muslim countries. We also recommend further research to address religion-specific barriers to uptake. As decisions made by the Chief Rabbi in Israel attest, religious organizations and leaders can play a vital role in clarifying faith-related concerns about novel foods,

helping to encourage vast numbers of followers to adopt more sustainable diets while remaining adherent to the core tenets of their belief systems.

## Data availability statement

The original contributions presented in the study are included in the article/supplementary material, further inquiries can be directed to the corresponding author.

## Author contributions

SA and CH conceived of the article idea. SA contributed as lead authorship. SJ, EA, AF, and CH contributed to writing the final perspective piece. SA edited and formatted the manuscript for submission. All authors contributed to the article and approved the submitted version.

## Conflict of interest

AF works as Halal Sector Senior Manager at the Agriculture and Horticulture Development Board (AHDB) (UK).

The remaining authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

## Publisher's note

All claims expressed in this article are solely those of the authors and do not necessarily represent those of their affiliated organizations, or those of the publisher, the editors and the reviewers. Any product that may be evaluated in this article, or claim that may be made by its manufacturer, is not guaranteed or endorsed by the publisher.

## Author disclaimer

The views expressed in this article are the author's own and do not reflect the views of AHDB.

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CITATION

Kuosmanen S, Niva M, Pajari A-M, Korhonen K, Muilu T and Konttinen H (2023) Barriers associated with pulse and plant-based meat alternative consumption across sociodemographic groups: a Capability, Opportunity, Motivation, Behaviour model approach.
*Front. Nutr.* 10:1186165.
doi: 10.3389/fnut.2023.1186165

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# Barriers associated with pulse and plant-based meat alternative consumption across sociodemographic groups: a Capability, Opportunity, Motivation, Behaviour model approach

Sini Kuosmanen¹,²*, Mari Niva², Anne-Maria Pajari¹, Kirsi Korhonen³, Toivo Muilu³ and Hanna Konttinen¹,⁴

¹Department of Food and Nutrition, University of Helsinki, Helsinki, Finland, ²Department of Economics and Management, University of Helsinki, Helsinki, Finland, ³Natural Resources Institute Finland, Oulu, Finland, ⁴Social Psychology, Faculty of Social Sciences, University of Helsinki, Helsinki, Finland

**Introduction:** To enhance environmental sustainability and food security, there should be a change in dietary protein consumption. It is suggested that meat consumption should be reduced and that the currently low consumption of pulses and other plant-based proteins should increase. We aimed to examine (1) how sociodemographic factors and perceived barriers are associated with self-reported current and perceived future pulse and other plant-based meat alternative (PBMA) consumption and (2) how sociodemographic factors relate to perceived barriers.

**Methods:** Participants were 18–75 year-old Finnish adults (n = 1,000). Multivariable logistic regression was used as the main analysis technique. The results were interpreted by employing the Capability, Opportunity, Motivation, Behaviour (COM-B) model.

**Results:** Pulses were consumed more often than PBMA and lower education level and financial strain were associated with more infrequent pulse and PBMA use. The most common perceived barriers for pulse consumption were unfamiliarity, expensive price, and unpleasant taste, which can be interpreted to represent the capability, opportunity and motivation components of the COM-B model, respectively. Women, the young, and financially strained perceived more barriers limiting their pulse consumption than others.

**Discussion:** To increase plant-based food consumption, it is important that tasty, easy to use and affordable plant-based foods are available for all. Additionally, we suggest that food services should be encouraged to increase the use of pulses in their dishes and that capabilities, opportunities and motivations are taken into account in intervention measures advancing plant protein consumption.

KEYWORDS

plant-based diet, alternative protein, legume, socioeconomic differences, COM-B
# 1. Introduction

As the world faces new and recurring challenges, such as the climate change and the ever-growing global population, it is more important than ever to rethink the sustainability of our dietary and food production practices. Current high level of meat production is regarded as environmentally unsustainable (1), and plant-based proteins have generally smaller environmental footprint than animal proteins (2, 3). Despite this, meat consumption has increased significantly globally in the last decades (4). Cultivating more sustainable protein sources, such as pulses, can contribute to mitigating climate change (5), but it is also noteworthy to recognize that pulse cultivation is not unproblematic either [e.g., (6)]. Despite the shortcomings of pulse cultivation, it is widely acknowledged that there should be a transformation in dietary protein sources: for instance, in 2019 the EAT-Lancet Commission proposed a substantial increase in pulse consumption while reducing meat consumption to ensure global food production and healthy diets within planetary boundaries (7).

Meat has been regarded as a central ingredient in main meals especially in Western diets (8), while the consumption of pulses is generally low: for example, in Finland about 140 grams weekly (9), which is well below the recommended 525 grams weekly as suggested by the EAT-Lancet Commission (7). One reason behind this is that different sociodemographic groups often experience different kinds of barriers related to eating pulses – a relationship that needs to be better understood to increase the environmental sustainability of food consumption. Furthermore, a recent review on meat alternatives by Onwezen et al. (10) suggests that more research on pulse and plant-based meat alternative (PBMA) consumption is needed, as only 18 of the 91 articles reviewed concerned pulses or PBMAs.

In this paper, we examine how the barriers and sociodemographic factors are associated with current and future pulse and PBMA consumption, as well as how sociodemographic factors relate to these barriers. The conceptualization of the Capability, Opportunity, Motivation, Behaviour (COM-B) model (11) is applied in examining the barriers affecting plant-based food consumption. In addition, sociodemographic characteristics such as gender, age, education and income level are taken into account in the analysis, as they may be reflected on an individual's capabilities, opportunities and motivations to consume plant-based foods.

# 2. Applying the COM-B model in the context of plant-based eating across sociodemographic groups

## 2.1. Sociodemographics and barriers: selecting plant-based foods

In everyday life, food selection is often a routinized process. However, many economic, environmental, social, psychological and cultural factors are involved in why people eat the way they do (12). If one is accustomed to consuming meat at most meals, it may be difficult to alter such routinized ways of eating. Furthermore, a variety of societal and cultural practices maintain a meat-eating culture. For instance, meat is readily available at grocery stores, and restaurants are usually assumed to offer meat dishes, unless they are profiled as vegetarian or vegan. Furthermore, liking the taste of meat, the price of

meat alternatives and the routinized nature of meat eating are significant barriers for reducing meat consumption (13). Skórska et al. (14) discovered that as a large part of Western cooking recipes center around meat, consumers are steered towards meat instead of plant-based protein sources.

Before and in the beginning of the 20th century, meat consumption in Finland was quite scarce, and pulses together with grains were an important source of protein (15, 16). After World War II, meat has had an important role in the Finnish food culture with most people consuming it regularly [e.g., (17)], and a significant amount of the Finnish population consume red and processed meat more than the national nutrition guidelines recommend (9). However, in recent years the consumption of all types of meat (beef, pork, poultry, game) has been decreasing slowly (18). The recently published Nordic Nutrition Recommendations 2023 advocate more plant-based diets by decreasing the amount of meat and increasing the consumption of pulses (19).

As meat consumption has already been decreasing and more plant-based diets are called for, it is an opportune time to try to quench the cultural appeal of meat by replacing it with pulse and other plant-based alternatives. Soy protein granules and tofu may be the most traditional and well-known meat alternatives, but in recent years different plant-based patties, sausages as well as various other forms of meat-like products have fast gained shelf-space in supermarkets (20). Such new products often imitate meat in sensory properties, like mouthfeel and taste (21), which often helps consumers to accept them as they provide a familiar alternative. In this paper we use the abbreviation “PBMA” to refer to all (processed) plant-based meat alternatives. The concepts of “plant protein food” and “plant-based food” include the aforementioned PBMAs as well as all other kinds of plant protein sources, such as fresh, dried and canned beans and peas.

Earlier studies have found typical pulse consumers to be young and women with a higher education, interested in healthy eating and living in large or medium-sized cities (14, 22, 23), and more sustainable eaters to be women, young, and highly educated (24). Furthermore, current consumers of pulses and pulse-based meat alternatives are also interested in consuming them more in the future (25, 26). Men, people with higher income, lower education level and disinterest in healthy eating gravitate more towards animal protein source consumption (13, 22, 23, 27, 28).

Major reasons for not consuming pulses are not being used to eating them, not knowing recipes for preparing them and not being interested in them (29). Additional barriers to pulse consumption found are, i.e., unpleasant gut symptoms (29), inconvenience and long preparation times (28, 30), inability to cook pulses and scarce number of traditional meals containing them (14) and the unpleasant taste of beans (25, 29, 31). Mäkiniemi and Vainio (32) found that price was the most decisive barrier to climate-friendly food selection, including increasing plant protein food consumption. However, there is as of yet little research on the association between sociodemographic factors and pulse consumption barriers [see (33)]. Our paper examines this relationship.

## 2.2. The COM-B model and plant-based eating

The COM-B model, developed by Michie, van Stralen, and West (11), provides a fruitful theoretic background for examining different
habits, such as exercising, smoking and, as in this paper, eating. Furthermore, the COM-B model forms the center of the Behaviour Change Wheel (BCW) (11), which enables the planning of effective behavior change interventions. The COM-B model is a rather simple yet comprehensive system to analyze the different capabilities (C), opportunities (O) and motivations (M) people have for acting the way they do, and how these three components in turn may influence (and be influenced by) actual behavior (B). The COM-B model and BCW are effective in identifying how and which components should be transformed in order to achieve the desired behavior change. All three COM factors are required to be present for a behavior to occur, and for a behavior to change, as the factors interact with each other (11). As an example, if one enjoys plant-based foods and is thus motivated to consume them, but lacks the skills to cook such dishes and at the same time the selection of products is narrow or non-existent meaning that capability and opportunity are absent, one is not very likely to commit to a plant-based diet and motivation to do so may decrease as well [see (34)].

Michie et al. (11) define all three COM-B factors as comprising of two dimensions. Capability is divided into *physical and psychological capability*. In the context of eating, physical capability may refer to the bodily ability to cook, and psychological capability being able to understand recipes and how to modify them. Opportunity consists of *social opportunity*, which can be defined as the surrounding social environment, and the *physical opportunity* concerning which food items are on offer and their affordability. Motivation includes *reflective motivation* such as planning what will be eaten and for what reasons (e.g., health, environment), and *automatic motivation* that takes into account emotions and impulses, like smelling something good and suddenly wanting to eat that even though something else was previously planned – thus overriding the reflective motivation.

The BCW, and the COM-B model in its center, offers a suitable framework for planning (eating) behavior change interventions, since it takes into account both the inner and outer behavior cues. The intervention measures presented in the BCW are closely linked with the three elements of the COM-B, and thus with the BCW it is possible to target the COM-B factors appropriately when mapping out interventions. Atkins and Michie (35) note that behavior is contextual and materializes within a system of behaviors, which occurs at different levels. Eating is often habitual behavior, which is heavily influenced by the environment (36), i.e., the social and physical opportunities. West and Michie (34) point out that capability and opportunity affect motivation, which then may influence the actual behavior, but that behavioral motivation also competes with alternate behaviors. This means that sometimes it is necessary to decrease another behavioral motivation in order to achieve the targeted behavior (34). Hence, in the context of more plant-based eating, it might be worthwhile to try to decrease the motivation to eat meat, while strengthening the motivation to switch to a more plant-based diets, as well as to try to modify the environment which facilitates habitual (meat) eating behavior.

Graça et al. (37) employed the COM-B in their analysis of consumption orientations and the willingness to transition towards more plant-based diets. They noted that all three components needed improving in order to increase plant-based eating, as did van den Berg et al. (13). Social opportunity was lacking, as social image was seen as a barrier to eat more plant-based meals, and led to abandoning capability and motivation needed for this (37). Consumers who

expected eating-related pleasure needed motivation enhancing in relation to better taste and expectations towards plant-based meals (37). Van den Berg et al. (13) found that concerning meat consumption decrease, motivation and opportunity were lacking the most, as the taste of meat and perceived high prices of meat alternatives were seen as barriers.

In a systematic review comprising over one hundred studies, Graça et al. (38) examined reducing meat consumption and following plant-based diets by employing the COM-B model. They noted that while the volume of research on motivational factors regarding more plant-based eating is ample and increasing, studies including opportunity and capability variables are lacking. Our paper focuses on each aspect of the COM-B, and thus allows a broader insight into the factors affecting the consumption of pulses and other plant-based foods. In addition, we analyze the capabilities, opportunities and motivations related to plant protein consumption barriers by taking into account the different sociodemographic factors as well. This helps to identify whether different sociodemographic groups would benefit from varying kinds of actions when advancing more plant-based food consumption.

# 3. Materials and methods

## 3.1. Participants and data collection

The consumer survey was part of the Leg4Life (Legumes for sustainable food system and healthy life) research project funded by the Strategic Research Council at the Academy of Finland. The survey was conducted in Finnish and the aim was to collect data on how consumers perceive pulses and PBMA, their current and future use as well as barriers and enablers related to pulse consumption. The survey data was collected online in September–October 2020 by a consumer and market research company Makery Oy via their existing consumer panel in Finland. The sample (n = 1,000) consisted of 18–75 year-old women and men, and was stratified by gender, age group, education level and residential area. Comparison of the participants’ sociodemographic characteristics with the Finnish national statistics indicated that the sample represented the Finnish adult population well (for details, see Table 1). The participants did not receive monetary compensation for their contribution, but earned points which can be used to buy goods from the panel’s web shop or be donated to charity.

### 3.1.1. Ethical issues

Prior to data collection, the survey and its protocol were reviewed by the University of Helsinki Ethical Review Board in Humanities and Social and Behavioral Sciences (Statement 40/2020). The respondents were provided detailed information on the study beforehand and they gave their informed consent electronically.

## 3.2. Measures

The sociodemographic factors examined included gender, age, residential region, urban-rural residency, education, and perceived financial situation. The response options for gender were woman, man and other, but none of the participants chose the last option. Age was
recoded into three age groups (18–34, 35–54, and 55–75 years). Participants’ place of residence was recoded into four geographical regional categories: Helsinki and Uusimaa region, Southern Finland, Western Finland, and Eastern and Northern Finland. Despite being geographically part of Southern Finland, Helsinki and Uusimaa region was separated into its own category, as Helsinki is the capital of Finland and around 30% of the Finnish population resides in Helsinki and Uusimaa region. Participants’ place of residence was also categorized into urban or rural region as defined by Statistic Finland (39). Education was recoded into three classes: elementary, secondary and tertiary education, in which all higher education levels (bachelor, master and post-graduate) were combined into tertiary education. The participants were asked to estimate their own financial situation on a 5-point scale: I get by excellently, I get by quite well, I get by when I shop frugally, I sometimes need to compromise and I need to compromise almost all the time. The first two response options were recoded into a combined category “no financial strain” and the last two options into “financial strain” category, thus resulting in a three-category perceived financial situation variable.

Current pulse and PBMA consumption were studied with the question “How often do you consume the following foods?” with choices for (a) beans, lentils and peas and (b) PBMAs (examples with familiar Finnish product names given in brackets). The response options were never, less than once a month, 1–3 times a month, once a week, 2–4 times a week, 5–6 times a week and daily. These response options were recoded into a dichotomous scale as follows: 1 = never or less than once a month and 0 = more often than once a month for pulse consumption and 1 = never and 0 = at least sometimes for PBMA consumption. This difference in recoding was due to the different share of non-consumers: 46% of the participants reported never consuming PBMAs, while the respective proportion was 8% for pulses.

Future pulse and PBMA consumption were investigated with the question “How do you believe your consumption of the following foods will change in the near future?” (in this paper, we refer to this as future consumption) with choices for (a) beans, lentils and peas and (b) PBMAs (examples with familiar product names given in brackets). The response options (decreases, stays the same, increases and do not know) were recoded into the following dichotomous scale: 1 = increases and 0 = other.

The participants were also asked to evaluate to which extent ten different factors limit their use of pulses and pulse-based products (the two food item types were combined in the same original variable). These factors (later: barriers, see Table 1) were measured on a 5-point Likert scale (1 = does not limit at all – 5 = limits significantly) with “do not know” as an additional response option. The measured barriers were recoded into dichotomous variables as well. Responses with values 1–3 and “do not know” were recoded into “0 = not a barrier” and responses with values 4–5 were recoded into “1 = barrier.”

### 3.3. Statistical analyses

The relationships between current and future consumption of pulses and PBMAs, sociodemographic factors and perceived barriers were analyzed with logistic regression using IBM SPSS Statistics version 26 (IBM Corp., Armonk, NY, United States). The results are reported as odds ratios (ORs) and 95% confidence intervals (CIs). The threshold for statistical significance was set at $p < 0.05$.

<table><caption>TABLE 1 Descriptive characteristics of the participants, n = 1,000.</caption><thead><tr><th></th><th>N</th><th>%</th><th>Comparison with Finnish population, %*</th></tr></thead><tbody><tr><td><strong>Gender</strong></td><td></td><td></td><td></td></tr><tr><td>Men</td><td>500</td><td>50</td><td>50.2</td></tr><tr><td>Women</td><td>500</td><td>50</td><td>49.8</td></tr><tr><td><strong>Age group</strong></td><td></td><td></td><td></td></tr><tr><td>18–34 years</td><td>293</td><td>29.3</td><td>28.3</td></tr><tr><td>35–54 years</td><td>352</td><td>35.2</td><td>34.4</td></tr><tr><td>55–75 years</td><td>355</td><td>35.5</td><td>37.3</td></tr><tr><td><strong>Residential region</strong></td><td></td><td></td><td>(Continental Finland)</td></tr><tr><td>Helsinki and Uusimaa region</td><td>311</td><td>31.1</td><td>31.5</td></tr><tr><td>Southern Finland (excluding Helsinki and Uusimaa)</td><td>200</td><td>20.0</td><td>20.9</td></tr><tr><td>Western Finland</td><td>259</td><td>25.9</td><td>24.8</td></tr><tr><td>Eastern and Northern Finland</td><td>230</td><td>23.0</td><td>22.8</td></tr><tr><td><strong>Urban–rural residence</strong></td><td></td><td></td><td></td></tr><tr><td>Rural area</td><td>214</td><td>21.4</td><td></td></tr><tr><td>Urban area</td><td>786</td><td>78.6</td><td></td></tr><tr><td><strong>Education level</strong></td><td></td><td></td><td>(20-74-year-olds)</td></tr><tr><td>Tertiary</td><td>358</td><td>35.8</td><td>36.7</td></tr><tr><td>Secondary</td><td>509</td><td>50.9</td><td>46.1</td></tr><tr><td>Elementary</td><td>133</td><td>13.3</td><td>17.2</td></tr><tr><td><strong>Perceived financial situation</strong></td><td></td><td></td><td></td></tr><tr><td>No financial strain</td><td>442</td><td>44.2</td><td></td></tr><tr><td>Ok when frugal</td><td>375</td><td>37.5</td><td></td></tr><tr><td>Financial strain</td><td>183</td><td>18.3</td><td></td></tr><tr><td><strong>Current consumption of pulses</strong></td><td></td><td></td><td></td></tr><tr><td>Never</td><td>78</td><td>7.8</td><td></td></tr><tr><td>Less than once a month</td><td>215</td><td>21.5</td><td></td></tr><tr><td>1–3 times a month</td><td>284</td><td>28.4</td><td></td></tr><tr><td>Once a week</td><td>192</td><td>19.2</td><td></td></tr><tr><td>2–4 times a week</td><td>182</td><td>18.2</td><td></td></tr><tr><td>5–6 times a week</td><td>34</td><td>3.4</td><td></td></tr><tr><td>Daily</td><td>15</td><td>1.5</td><td></td></tr><tr><td><strong>Current consumption of PBMAs**</strong></td><td></td><td></td><td></td></tr><tr><td>Never</td><td>455</td><td>45.5</td><td></td></tr><tr><td>Less than once a month</td><td>255</td><td>25.5</td><td></td></tr><tr><td>1–3 times a month</td><td>130</td><td>13.0</td><td></td></tr><tr><td>Once a week</td><td>75</td><td>7.5</td><td></td></tr><tr><td>2–4 times a week</td><td>66</td><td>6.6</td><td></td></tr><tr><td>5–6 times a week</td><td>12</td><td>1.2</td><td></td></tr><tr><td>Daily</td><td>7</td><td>0.7</td><td></td></tr><tr><td><strong>Future consumption of pulses</strong></td><td></td><td></td><td></td></tr><tr><td>Increases</td><td>260</td><td>26.0</td><td></td></tr></tbody></table>

(Continued)
<table><caption>TABLE 1 (Continued)</caption><thead><tr><th></th><th>N</th><th>%</th><th>Comparison with Finnish population, %*</th></tr></thead><tbody><tr><td>Stays the same/decreases/do not know</td><td>740</td><td>74.0</td><td></td></tr><tr><td><strong>Future consumption of PBMA</strong></td><td></td><td></td><td></td></tr><tr><td>Increases</td><td>195</td><td>19.5</td><td></td></tr><tr><td>Stays the same/decreases/do not know</td><td>805</td><td>80.5</td><td></td></tr><tr><td><strong>Perceived barriers</strong></td><td></td><td></td><td></td></tr><tr><td>Products are not familiar</td><td>440</td><td>44.0</td><td></td></tr><tr><td>Expensive price</td><td>437</td><td>43.7</td><td></td></tr><tr><td>Do not like the taste</td><td>411</td><td>41.1</td><td></td></tr><tr><td>Unpleasant mouthfeel</td><td>337</td><td>33.7</td><td></td></tr><tr><td>Do not know how to prepare [pulses]</td><td>311</td><td>31.1</td><td></td></tr><tr><td>Family does not want to eat [pulses]</td><td>304</td><td>30.4</td><td></td></tr><tr><td>Narrow product selection</td><td>237</td><td>23.7</td><td></td></tr><tr><td>Do not suit me (e.g., cause stomach problems)</td><td>224</td><td>22.4</td><td></td></tr><tr><td>Preparing [pulses] is tedious</td><td>218</td><td>21.8</td><td></td></tr><tr><td>Hard to find in a store</td><td>202</td><td>20.2</td><td></td></tr></tbody></table>

Four binary logistic regression models were conducted with sociodemographic and dichotomous barrier variables predicting the odds of (1) using pulses less than once a month or never (29% of participants), (2) never using PBMA (46%), (3) increased future pulse use (26%), and (4) increased future PBMA use (20%). All predictors were entered simultaneously into the models (see Appendix Table A.1 for logistic regressions testing bivariate associations between each predictor and outcome).

The reference category for each sociodemographic predictor was chosen based on prior studies' results on who are the most likely users of pulses and/or (other) plant proteins. The chosen reference categories were: female, youngest age group of 18–34 years, Helsinki and Uusimaa region (large and medium-sized, urban cities), tertiary education and no financial strain. Reference category for the perceived barriers was “no barrier.”

To ensure the suitability of including all sociodemographic and barrier variables as predictors into the same model, Spearman correlation tests were carried out beforehand. All correlations were below 0.5 suggesting no substantial multicollinearity between the predictors.

Ten binary logistic regression models were then performed with sociodemographic factors predicting the odds of each barrier. Again, all predictors were entered simultaneously into the models (see Appendix Tables B.2A,B for logistic regressions testing bivariate associations between each predictor and outcome).

Finally, the number of reported barriers and their association with sociodemographic factors was tested with multinomial logistic

regression. The odds of reporting “zero barriers” or “six or more barriers” (with “one to five barriers” as a reference category) was predicted by gender, age group, education level, perceived income and residential region.

# 4. Results

## 4.1. Current pulse and PBMA consumption in relation to sociodemographic factors and perceived barriers

We examined 10 perceived barriers often associated with consuming plant-based foods (Table 1). All barriers had prominence at some level, but the most common barriers related to eating pulses were unfamiliarity (44%), expensive price (44%), and not liking their taste (41%). Barriers limiting pulse consumption the least were finding cooking them tedious (22%) and experiencing them hard to find in a store (20%).

Table 2 (left-hand side) shows that the respondents' current consumption of pulses and PBMA varied according to their sociodemographic characteristics. Lower than tertiary education and financial strain indicated less likely consumption of pulses and PBMA. Furthermore, age and gender were related to PBMA consumption: men and respondents over 35 years old had lower odds to consume PBMA than women and the youngest age group.

Our analysis of the association between pulse and PBMA consumption and perceived barriers showed that unpleasant taste and unfamiliarity with the foods resulted in their less likely consumption (Table 2, left-hand side). In addition, expensive price and the difficulty of finding the products in a store were linked to PBMA consumption: respondents finding expensive price and not being able to find the products in a store to be barriers were more likely to consume PBMA than those who did not perceive these as barriers.

## 4.2. Future pulse and PBMA consumption in relation to sociodemographic factors and perceived barriers

In future consumption of pulses and PBMA, the sociodemographic trends were largely similar to those detected above for current consumption (Table 2, right-hand side). Having a lower than tertiary education indicated lower odds for increasing pulse consumption, and financial strain was associated with less likely increase in PBMA use.

Increase in men's pulse consumption was less likely than women's, and the oldest respondents had lower odds of increasing their PBMA consumption than the youngest ones. In addition, respondents living in a rural area had lower odds of increasing their PBMA use.

The perceived barriers associated with future pulse consumption were not liking the taste and experiencing pulse products hard to find in a store. Not liking the taste of pulses was related to lower odds of increasing their use. Conversely, experiencing pulses and pulse-based products hard to find in a store led to higher odds of future increase in pulse consumption.

Experiencing pulses and pulse-based products unsuitable (e.g., unpleasant gut symptoms) was linked to lower odds for

<footnote>*Source: Statistics Finland (2021) and **Plant-based meat alternatives.</footnote>
<table><caption>TABLE 2 Estimates from multivariable logistic regression models: sociodemographic factors and perceived barriers predicting current and future consumption of pulses and plant-based meat alternatives (PBMAs), n = 1,000.</caption><thead><tr><th rowspan="2"></th><th colspan="2">Current use of pulses (less than once a month or never)</th><th colspan="2">Current use of PBMAs (never)</th><th colspan="2">Future use of pulses (increases)</th><th colspan="2">Future use of PBMAs (increases)</th></tr><tr><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th></tr></thead><tbody><tr><td><strong>Gender</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Women</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Men</td><td>1.08</td><td>(0.81-1.45)</td><td>1.37*</td><td>(1.04-1.80)</td><td>0.60**</td><td>(0.45-0.81)</td><td>0.72</td><td>(0.52-1.01)</td></tr><tr><td><strong>Age</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>18-34 years</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>35-54 years</td><td>0.77</td><td>(0.53-1.10)</td><td>1.58*</td><td>(1.12-2.24)</td><td>0.80</td><td>(0.55-1.16)</td><td>0.78</td><td>(0.52-1.15)</td></tr><tr><td>55-75 years</td><td>0.76</td><td>(0.53-1.09)</td><td>2.74***</td><td>(1.94-3.86)</td><td>0.87</td><td>(0.61-1.26)</td><td>0.46***</td><td>(0.30-0.70)</td></tr><tr><td><strong>Region</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Helsinki and Uusimaa</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Southern Finland</td><td>1.13</td><td>(0.74-1.72)</td><td>1.25</td><td>(0.85-1.84)</td><td>1.01</td><td>(0.67-1.52)</td><td>0.97</td><td>(0.61-1.54)</td></tr><tr><td>Western Finland</td><td>1.35</td><td>(0.91-1.99)</td><td>1.14</td><td>(0.79-1.64)</td><td>0.65*</td><td>(0.43-0.98)</td><td>0.80</td><td>(0.51-1.25)</td></tr><tr><td>Eastern and Northern Finland</td><td>1.44</td><td>(0.96-2.14)</td><td>1.17</td><td>(0.80-1.70)</td><td>0.99</td><td>(0.67-1.48)</td><td>0.92</td><td>(0.59-1.45)</td></tr><tr><td><strong>Urban-rural residence</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Urban area</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Rural area</td><td>1.15</td><td>(0.81-1.64)</td><td>1.29</td><td>(0.91-1.81)</td><td>0.67</td><td>(0.45-1.07)</td><td>0.60*</td><td>(0.37-0.95)</td></tr><tr><td><strong>Education level</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Tertiary</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Secondary</td><td>1.55**</td><td>(1.11-2.16)</td><td>1.96***</td><td>(1.45-2.65)</td><td>0.69*</td><td>(0.50-0.95)</td><td>0.68*</td><td>(0.48-0.98)</td></tr><tr><td>Elementary</td><td>2.19**</td><td>(1.37-3.48)</td><td>2.51***</td><td>(1.60-3.93)</td><td>0.46**</td><td>(0.27-0.78)</td><td>0.77</td><td>(0.44-1.35)</td></tr><tr><td><strong>Perceived financial situation</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No financial strain</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Ok when frugal</td><td>1.16</td><td>(0.83-1.60)</td><td>1.21</td><td>(0.89-1.64)</td><td>1.18</td><td>(0.84-1.64)</td><td>0.85</td><td>(0.59-1.23)</td></tr><tr><td>Financial strain</td><td>1.89**</td><td>(1.27-2.81)</td><td>1.69**</td><td>(1.15-2.50)</td><td>1.04</td><td>(0.68-1.60)</td><td>0.59*</td><td>(0.36-0.98)</td></tr><tr><td><strong>Barriers</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Not familiar</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>1.94***</td><td>(1.39-2.69)</td><td>1.52**</td><td>(1.11-2.08)</td><td>0.91</td><td>(0.64-1.28)</td><td>1.24</td><td>(0.85-1.81)</td></tr><tr><td>Expensive price</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>0.74</td><td>(0.54-1.01)</td><td>0.49***</td><td>(0.36-0.66)</td><td>1.11</td><td>(0.80-1.53)</td><td>1.22</td><td>(0.86-1.75)</td></tr><tr><td>Do not like the taste</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>1.97**</td><td>(1.33-2.90)</td><td>1.73**</td><td>(1.18-2.52)</td><td>0.50**</td><td>(0.32-0.76)</td><td>0.57*</td><td>(0.36-0.91)</td></tr><tr><td>Unpleasant mouthfeel</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>0.84</td><td>(0.56-1.25)</td><td>1.02</td><td>(0.69-1.50)</td><td>1.37</td><td>(0.89-2.13)</td><td>0.91</td><td>(0.56-1.47)</td></tr></tbody></table>

(Continued)
<table><caption>TABLE 2 (Continued)</caption><thead><tr><th rowspan="2"></th><th colspan="2">Current use of pulses (less than once a month or never)</th><th colspan="2">Current use of PBMA (never)</th><th colspan="2">Future use of pulses (increases)</th><th colspan="2">Future use of PBMA (increases)</th></tr><tr><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th></tr></thead><tbody><tr><td>Do not know how to prepare them</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>1.06</td><td>(0.73-1.55)</td><td>0.96</td><td>(0.67-1.37)</td><td>1.13</td><td>(0.77-1.67)</td><td>1.94**</td><td>(1.28-2.94)</td></tr><tr><td>Family does not want to eat them</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>0.90</td><td>(0.63-1.28)</td><td>1.02</td><td>(0.73-1.43)</td><td>1.33</td><td>(0.92-1.91)</td><td>1.03</td><td>(0.69-1.55)</td></tr><tr><td>Narrow product selection</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>1.01</td><td>(0.68-1.51)</td><td>1.13</td><td>(0.77-1.65)</td><td>1.07</td><td>(0.72-1.60)</td><td>0.89</td><td>(0.57-1.40)</td></tr><tr><td>Do not suit me (e.g., cause stomach problems)</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>1.00</td><td>(0.69-1.44)</td><td>1.15</td><td>(0.81-1.63)</td><td>0.63</td><td>(0.47-1.02)</td><td>0.59*</td><td>(0.37-0.93)</td></tr><tr><td>Preparing them is tedious</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>0.86</td><td>(0.57-1.30)</td><td>0.92</td><td>(0.62-1.37)</td><td>0.90</td><td>(0.59-1.38)</td><td>0.67</td><td>(0.41-1.07)</td></tr><tr><td>Hard to find in a store</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No barrier</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Barrier</td><td>0.57*</td><td>(0.37-0.88)</td><td>0.48***</td><td>(0.32-0.72)</td><td>1.80**</td><td>(1.19-2.71)</td><td>2.06**</td><td>(1.31-3.24)</td></tr></tbody></table>

increasing PBMA use in the future. Respondents perceiving pulses and pulse-based products hard to find in a store and not knowing how to cook them as barriers were more likely to increase their PBMA use.

### 4.3. Sociodemographic factors predicting perceived barriers

The results of the analysis on sociodemographic factors predicting perceived barriers are presented in Tables 3, 4.

**Gender** Men had lower odds of finding not being familiar with pulses being a barrier for pulse consumption than women did. Men also found not knowing how to cook pulses or pulses not suiting them to be less of a barrier than these were to women.

**Age** Compared to the youngest age group, the oldest age group had lower odds of perceiving pulses' expensive price a barrier. The oldest respondents were also less likely to find not liking the taste of pulses to be a barrier than the youngest age group. In addition, the oldest respondents had lower odds of not knowing how to cook

pulses and finding cooking pulses to be tedious than the youngest participants.

**Education and perceived financial situation** Respondents with secondary education had higher odds of experiencing not being familiar with pulses a barrier compared to respondents with tertiary education. Financially strained respondents and respondents getting by when shopping frugally were more likely to find pulse-based products' expensive price a barrier than respondents with no such strain. Being financially strained was also related to experiencing more unfamiliarity with pulse-based products and finding cooking them tedious.

**Number of reported barriers** Altogether 19.2% reported 0 barriers and 18% reported 6 or more barriers (no table). The results from multinomial logistic regression revealed that financial strain was associated with reporting more barriers. Compared to participants with financial strain, those with no such strain had 1.7-fold odds of reporting 0 barriers (95% CI 1.03–2.90, *p*<0.05) and 0.6-fold odds of reporting 6 or more barriers (95% CI 0.38–0.96, *p*<0.05). Other sociodemographic factors were not significantly related to the number of reported barriers.

<footnote>***p<0.001, **p<0.01, and *p<0.05.</footnote>
<table><caption>TABLE 3 Estimates from multivariable logistic regression models: sociodemographic factors predicting perceived barriers (n = 1,000).</caption><thead><tr><th rowspan="2"></th><th colspan="2">Not familiar</th><th colspan="2">Expensive price</th><th colspan="2">Do not like the taste</th><th colspan="2">Unpleasant mouthfeel</th><th colspan="2">Do not know how to prepare [pulses]</th></tr><tr><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th></tr></thead><tbody><tr><td><strong>Gender</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Women</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Men</td><td>0.72*</td><td>(0.56-0.93)</td><td>1.03</td><td>(0.80-1.34)</td><td>0.97</td><td>(0.75-1.25)</td><td>0.99</td><td>(0.76-1.29)</td><td>0.70*</td><td>(0.53-0.92)</td></tr><tr><td><strong>Age</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>18-34 years</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>35-54 years</td><td>1.08</td><td>(0.78-1.49)</td><td>0.89</td><td>(0.64-1.23)</td><td>0.88</td><td>(0.64-1.21)</td><td>0.95</td><td>(0.68-1.33)</td><td>0.90</td><td>(0.64-1.26)</td></tr><tr><td>55-75 years</td><td>1.03</td><td>(0.75-1.41)</td><td>0.71*</td><td>(0.51-0.97)</td><td>0.66*</td><td>(0.48-0.91)</td><td>0.88</td><td>(0.63-1.23)</td><td>0.67*</td><td>(0.47-0.94)</td></tr><tr><td><strong>Region</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Helsinki and Uusimaa</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Southern Finland</td><td>1.04</td><td>(0.72-1.51)</td><td>0.83</td><td>(0.57-1.20)</td><td>0.89</td><td>(0.62-1.29)</td><td>0.98</td><td>(0.66-1.43)</td><td>0.74</td><td>(0.50-1.11)</td></tr><tr><td>Western Finland</td><td>1.30</td><td>(0.92-1.83)</td><td>1.01</td><td>(0.71-1.43)</td><td>1.03</td><td>(0.73-1.44)</td><td>1.18</td><td>(0.83-1.69)</td><td>0.83</td><td>(0.58-1.21)</td></tr><tr><td>Eastern and Northern Finland</td><td>1.37</td><td>(0.96-1.94)</td><td>1.06</td><td>(0.74-1.51)</td><td>1.14</td><td>(0.80-1.62)</td><td>1.29</td><td>(0.89-1.87)</td><td>1.22</td><td>(0.84-1.76)</td></tr><tr><td><strong>Urban-rural residence</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Urban area</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Rural area</td><td>0.75</td><td>(0.54-1.03)</td><td>0.82</td><td>(0.59-1.13)</td><td>0.95</td><td>(0.69-1.31)</td><td>0.66*</td><td>(0.46-0.93)</td><td>1.03</td><td>(0.73-1.45)</td></tr><tr><td><strong>Education</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Tertiary</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Secondary</td><td>1.37*</td><td>(1.03-1.82)</td><td>1.22</td><td>(0.91-1.62)</td><td>0.96</td><td>(0.72-1.27)</td><td>0.93</td><td>(0.69-1.24)</td><td>1.09</td><td>(0.80-1.47)</td></tr><tr><td>Elementary</td><td>1.17</td><td>(0.77-1.80)</td><td>1.17</td><td>(0.76-1.80)</td><td>0.79</td><td>(0.51-1.22)</td><td>0.66</td><td>(0.42-1.05)</td><td>0.87</td><td>(0.55-1.39)</td></tr><tr><td><strong>Perceived financial situation</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No financial strain</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Ok when frugal</td><td>1.11</td><td>(0.83-1.49)</td><td>1.62**</td><td>(1.22-2.16)</td><td>1.09</td><td>(0.82-1.46)</td><td>1.20</td><td>(0.89-1.62)</td><td>1.06</td><td>(0.78-1.44)</td></tr><tr><td>Financial strain</td><td>1.57*</td><td>(1.09-2.24)</td><td>2.76***</td><td>(1.92-3.98)</td><td>1.29</td><td>(0.90-1.85)</td><td>1.33</td><td>(0.92-1.94)</td><td>1.33</td><td>(0.91-1.95)</td></tr></tbody></table>

# 5. Discussion

We first discuss the general findings of the study. Thereafter we reflect on the findings by employing the COM-B model in analyzing the perceived barriers to pulse and other PBMA consumption. In addition, we take into account the role of sociodemographic factors in our analysis. Lastly, we consider possible measures for future interventions to increase pulse and PBMA consumption.

## 5.1. General findings

Our results show that pulses are consumed more often than PBMAs: over 90% of the respondents consumed pulses at least sometimes, while just over half of the respondents consumed PBMAs. In total about one

fourth of the respondents thought of increasing their pulse consumption, while roughly one fifth planned to increase their PBMA consumption. The most significant barriers for pulse consumption were unfamiliarity (44%), expensive price (44%), and unpleasant taste (41%) of pulses. These barriers represent rather well how all of the COM-B aspects affect the conditions of plant-based eating.

Male gender and older age was associated with lower current PBMA consumption. In addition, men had less intentions to increase their pulse consumption, and older respondents were not likely to increase their PBMA consumption. Siegrist and Hartmann (40) found that women are more likely consumers of meat alternatives, and Jallinoja et al. (25) that women consume beans more often than men. Graça et al. (38) point out that findings from various studies show that the male gender is often associated with unwillingness and the female gender with willingness to follow

<footnote>***p<0.001, **p<0.01, and *p<0.05.</footnote>
<table><caption>TABLE 4 Estimates from multivariable logistic regression models: sociodemographic factors predicting perceived barriers (n = 1,000).</caption><thead><tr><th rowspan="2"></th><th colspan="2">Family does not want to eat [pulses]</th><th colspan="2">Narrow product selection</th><th colspan="2">Do not suit me</th><th colspan="2">Preparing [pulses] is tedious</th><th colspan="2">Hard to find in a store</th></tr><tr><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR</th><th>95% CI</th><th>OR.</th><th>95% CI</th><th>OR</th><th>95% CI</th></tr></thead><tbody><tr><td><strong>Gender</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Women</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Men</td><td>0.78</td><td>(0.59-1.02)</td><td>1.26</td><td>(0.94-1.69)</td><td>0.64**</td><td>(0.47-0.87)</td><td>1.01</td><td>(0.75-1.37)</td><td>1.09</td><td>(0.80-1.49)</td></tr><tr><td><strong>Age</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>18-34 years</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>35-54 years</td><td>1.39</td><td>(0.99-1.95)</td><td>0.79</td><td>(0.55-1.15)</td><td>1.31</td><td>(0.89-1.91)</td><td>0.71</td><td>(0.49-1.04)</td><td>0.68</td><td>(0.46-1.00)</td></tr><tr><td>55-75 years</td><td>0.72</td><td>(0.51-1.03)</td><td>0.86</td><td>(0.59-1.23)</td><td>0.95</td><td>(0.65-1.41)</td><td>0.63*</td><td>(0.43-0.92)</td><td>0.73</td><td>(0.50-1.07)</td></tr><tr><td><strong>Region</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Helsinki and Uusimaa</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Southern Finland</td><td>0.98</td><td>(0.65-1.46)</td><td>0.76</td><td>(0.49-1.18)</td><td>1.14</td><td>(0.75-1.73)</td><td>0.76</td><td>(0.49-1.19)</td><td>0.68</td><td>(0.42-1.09)</td></tr><tr><td>Western Finland</td><td>1.07</td><td>(0.74-1.55)</td><td>0.96</td><td>(0.65-1.42)</td><td>0.79</td><td>(0.53-1.20)</td><td>0.92</td><td>(0.61-1.38)</td><td>0.96</td><td>(0.63-1.45)</td></tr><tr><td>Eastern and Northern Finland</td><td>1.29</td><td>(0.88-1.88)</td><td>1.12</td><td>(0.75-1.68)</td><td>0.89</td><td>(0.58-1.35)</td><td>1.05</td><td>(0.69-1.58)</td><td>1.15</td><td>(0.76-1.76)</td></tr><tr><td><strong>Urban-rural residence</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Urban area</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Rural area</td><td>1.28</td><td>(0.91-1.80)</td><td>0.85</td><td>(0.58-1.25)</td><td>1.16</td><td>(0.79-1.68)</td><td>0.95</td><td>(0.65-1.40)</td><td>0.98</td><td>(0.66-1.46)</td></tr><tr><td><strong>Education</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Tertiary</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Secondary</td><td>1.21</td><td>(0.90-1.65)</td><td>1.10</td><td>(0.79-1.53)</td><td>0.89</td><td>(0.64-1.24)</td><td>0.98</td><td>(0.70-1.37)</td><td>1.09</td><td>(0.77-1.55)</td></tr><tr><td>Elementary</td><td>0.89</td><td>(0.55-1.43)</td><td>0.79</td><td>(0.47-1.32)</td><td>0.82</td><td>(0.49-1.36)</td><td>0.83</td><td>(0.49-1.40)</td><td>0.78</td><td>(0.45-1.35)</td></tr><tr><td><strong>Perceived financial situation</strong></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>No financial strain</td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td><td>1</td><td></td></tr><tr><td>Ok when frugal</td><td>0.86</td><td>(0.63-1.17)</td><td>1.06</td><td>(0.76-1.49)</td><td>1.43*</td><td>(1.02-2.02)</td><td>1.06</td><td>(0.75-1.49)</td><td>0.88</td><td>(0.62-1.26)</td></tr><tr><td>Financial strain</td><td>1.07</td><td>(0.73-1.57)</td><td>1.45</td><td>(0.97-2.18)</td><td>1.43</td><td>(0.94-2.18)</td><td>1.53*</td><td>(1.01-2.31)</td><td>1.31</td><td>(0.85-2.01)</td></tr></tbody></table>

plant-based diets, but that results concerning age are mixed. Interestingly in our study, men and older respondents found certain barriers to limit their pulse consumption less than women and the young did, even though the latter are more often profiled to be more interested in plant-based foods.

Earlier research shows that higher education predicts more frequent bean consumption (25), and readiness to accept PBMA (40, 41). Overall, higher socioeconomic status acts as an enabler to consume plant-based foods (38), and different economic situation may lead to different access to certain consumer goods (42). Our results are in line with this, as lower education level and financial strain were associated with lower pulse and PBMA consumption. Living area was not strongly associated with pulse and PBMA consumption, even though some earlier research has found that living in large or medium-sized cities often indicates a tendency to consume plant-based foods [e.g., (14)].

## 5.2. Capabilities, opportunities, and motivations limiting the consumption of pulses and pulse-based products

### 5.2.1. Unfamiliarity and preparation capabilities

Being unfamiliar with pulses and other plant-based foods is a significant barrier for their consumption, as earlier research [e.g., (29)] as well as our results show. Unfamiliarity affects the psychological capability to eat these kinds of foods. We discerned that current use of both pulses and PBMA products was likely to be limited due to unfamiliarity. In addition, some sociodemographic groups found unfamiliarity to be more of a barrier than others; most notably women and those with financial strain. We propose that the gender difference may be because some men are not that interested in consuming pulses or PBMA, and thus do not experience any barriers related to them either. Furthermore, if money is tight, it may feel safer to buy familiar

<footnote>***p < 0.001, **p < 0.01, and *p < 0.05.</footnote>
options to get one's money's worth (43, 44). Oude Groeniger et al. (45) argue that consuming healthy food is one mechanism for social distinction in the higher socioeconomic classes, and Bowman (46) points out that lower education level can in some cases be associated with the lack of knowledge of the benefits of more plant-based eating, and that plant-based eating might be seen as something that belongs to those with higher education (and thus often higher socioeconomic status). To summarize, pulse unfamiliarity as a psychological capability affects especially people with lower socioeconomic status and women.

Unfamiliarity is closely related to inability to cook pulses and pulse-based products and finding preparing them to be tedious, which can be classified as both psychological (e.g., not knowing how) and physical (e.g., not having enough time) capability. Nguyen et al. (47) conceptualize cooking skills as a physical capability, and their absence acts as a barrier to alternative protein source consumption. Again, women experienced the inability to cook pulses and pulse-based products to be more of a barrier than men did, which refers to the idea above that men may not be as interested in pulses, and thus have no barriers. However, women are more willing to eat plant-based foods (38) and to try vegetarian recipes (13) than men. Additionally, older respondents had less feelings of inability to cook pulses and pulse-based products, and they also found preparing pulses less tedious than younger respondents. We propose that this is an indication of older respondents being more used to cooking from scratch: convenience and time-saving is especially valued by the younger generation [(12); see also (48)].

### 5.2.2. Taste and unpleasant gut symptoms

Similarly to our findings, earlier studies have concluded that the unpleasant taste of pulses is a barrier to consuming them (28, 29, 31). Furthermore, doubting the taste of PBMs prevents their use (35), and liking meat is often a barrier for meat alternative consumption (47). In the context of eating, pleasure is one major motivation to consume certain kinds of foods (43, 49), and good taste is significant for achieving pleasure. Taste can be classified as *automatic motivation*. In our study, the unpleasant taste of pulses was a significant barrier for both current and future consumption of pulses and PBMs. Older respondents experienced the taste to be less of a barrier than the youngest, but Jallinoja et al. (23) found that young consumers were more likely to eat beans. Thus, we argue that taste of pulses may be perceived differently by different groups of people, depending on, e.g., their generation, social upbringing and taste preferences.

Pulses are often perceived to cause unpleasant gut symptoms: even up to one third of the Western population suffers pulse digestion problems (50). This can act as a barrier for pulse use, as undesired gastrointestinal symptoms may physically limit the capability to consume pulses. Winham and Hutchins (50) found that women were more likely to report gastrointestinal symptoms and sensations, which is in line with our finding that women found pulses causing unpleasant gut symptoms more of a barrier than men did. Earlier research has also concluded that pulses' gastrointestinal unsuitability limits the capability to consume them (14, 29, 31).

### 5.2.3. Price

Graça et al. (38) discuss the higher price of meat as a potential enabler for increased plant protein consumption. However, there are mixed results on perceived plant protein prices: Vainio et al. (28) discovered that the expensive price of plant protein foods was the

most significant barrier for their consumption, while Niva et al. (29) concluded that price was not a barrier. Furthermore, van den Berg et al. (13) found price to both prevent and enable eating PBMs: the perceived high price of PBMs was a barrier, but saving money was also seen as a reason to consume less meat and more plant proteins. In our study, pulses *per se* and pulse-based products were lumped together when enquiring about the price, even though their prices often differ significantly. We found that the price of pulses acted as a barrier for respondents struggling financially, thus limiting their *physical opportunity* to consume these products, which possibly indicates that they thought of pulse-based meat alternatives rather than pulses *per se*, as the latter are often quite inexpensive. Lower prices of pulse-based products would create more opportunities for consumers to increase their pulse intake (30). We also found that those already consuming PBMs perceived their price to be more of a barrier than non-consumers. We propose two explanations for this. First, there may be a group of non-consumers for whom the barrier is not the price of the products, but other factors. Secondly, there may be consumer groups, such as young students, who would like to consume more PBMs, but find their high price to limit their consumption opportunities.

Age can also be a factor affecting the perception of price: we found that the oldest respondents had less of a price barrier than the youngest, which suggests that they may be financially better off or that they may have thought of different pulse products, i.e., pulses *per se* versus processed products. Our notion of older respondents not consuming and not intending to consume PBMs supports this interpretation. In addition, perceptions of plant-based foods and their price may vary culturally: the Spanish found plant-based eating more affordable than the Danish (51). In Spain, the traditional Mediterranean diet includes affordable dried and fresh pulses (52), while Northern Europeans often like to emphasize the convenience of food products (53), and thus may prefer more expensive, ready-to-use pulse products.

### 5.2.4. Store and family environment

Another physical opportunity affecting pulse and PBMA consumption was having difficulties in locating these products in a store. Earlier research has noted that more prominent positioning of healthy foods (such as pulses) in grocery stores is related to healthier food choices (54) and that alternative protein foods are often placed separately from meat equivalents (55). Thus, with better placement of plant protein foods, grocery stores could advance their consumption. Curiously, respondents already consuming pulses and PBMs and intending to increase their consumption found not being able to find these products in a store to be more of a barrier than non-consumers. Again, there might be a group of non-consumers who have not even tried to find pulses in a store, which is why it is not a barrier. Other explanations can also be offered. The first is that some stores may not carry a large selection of pulse products, which is why they are hard to find (however, this did not seem to be an issue when examining "narrow product selection" barrier). The second is that some products might be stocked low and often sold out, resulting in not finding them. The third is that not all stores have clearly organised sections where all pulse products are conveniently on display, resulting in shoppers needing to navigate through multiple sections before finding the right product (or not finding it at all), which also calls for their better positioning.
Social environment can act either as barrier or enabler for decreasing meat consumption and/or increasing the portion of plant-based foods (38). We only examined family as the social environment (i.e., social opportunity) relating to pulse consumption barriers, and even though 30% of respondents perceived this as a barrier, it was not statistically significant in our study. Van den Berg et al. (13) had similar results, as they noted that people were mostly able to decide themselves which foods to consume regardless of the social environment. Other barriers which were not statistically significant in relation to current and future pulse and PBMA consumption in our study were mouthfeel (relating to the pleasure aspect of motivation) and narrow selection of pulse products (physical opportunity).

### 5.2.5. Intervention measure suggestions

Habits are often unconscious and triggered by the environment, and intentions do not necessarily translate into actual behavior (36). One behavior may be a barrier to another (34), and automatic motivation may override reflective motivation (35). Thus, to conclude our discussion, we propose some possible future intervention measures within the COM-B model to increase the consumption of pulses and PBMAs.

As the present results demonstrate, lower education level and financial struggle are associated with consuming pulses and PBMAs more infrequently. One commonly proposed solution is to increase the proportion of plant-based meals in workplace canteens, but the problem is that people with lower socioeconomic status often do not have access to these places (56) and consume homemade or bought food. However, in Finland, children are provided with free daycare and school lunches (57), and thus one way to increase plant-based eating could start from these public food services. There have been prior attempts to increase the amount of vegetarian food in schools that have led to mixed results: on the other hand, food waste increased and participation at lunch decreased, but some vegetarian dishes gained popularity (58). To further increase plant-based food consumption at school lunches, the physical opportunities need to be taken into account. One way to enhance this is to place plant-based dishes first on the serving line. However, for plant-based dishes to be more readily accepted, the social opportunities need to be present as well. At present, meat dishes are seen as more “normal,” as the need to specifically distinguish vegetarian food days in schools demonstrates: there is no talk of “meat food days.” Thus, plant-based foods should be normalized and not differentiate them from meat dishes conspicuously. In addition, home economics classes at schools can help to normalize plant-based foods and to achieve capabilities to cook tasty and nutritious plant-based meals. All these measures would also make pulses more familiar, which is an enabler for their consumption (10).

The present findings suggest that the food industry and retail trade can enhance the motivation and physical opportunities to eat plant protein foods. We noted that unpleasant taste was one significant barrier for consuming pulses and PBMAs. Improving taste qualities of plant protein foods and maybe offering appealing convenience meals without meat could increase the motivation to consume them. Furthermore, perceived high prices hindered plant protein food consumption. To steer consumers towards plant protein foods, changes in taxing meat and plant protein sources could make plant foods more appealing and financially more available to all. Finally,

grocery store settings could be modified to help consumers find meat alternatives without having to make a significant effort. For example, Piernas et al. (59) found that by placing alternative proteins in the meat aisle, their sales increased. Thus, by placing plant proteins next to meat products would make it easier for consumers to find and buy meatless alternatives.

## 5.3. Strengths and limitations

One strength of the study lies in using large and recent survey data including respondents who relatively well represent the general Finnish adult population in terms of gender, age, living area and education level. The most notable strength is that we analyzed the role of sociodemographic factors simultaneously with the consumption of pulses and PBMAs and the barriers related to them; a topic that is of importance if a transition towards more plant-based food consumption is to be achieved.

One limitation to consider is that pulses as raw ingredients and pulses as processed products were lumped together in the survey when enquiring about the factors perceived as barriers to their use. This is somewhat problematic, because pulses *per se* and processed pulse products often differ in price, preparation technique and taste, amongst other things. Furthermore, there is no certainty that the self-reported pulse consumption reflects actual consumption, or that intentions to increase consumption will actually be realized.

# 6. Conclusion

Our results show that the level of engagement among Finnish adults in the consumption of plant-based protein foods is currently not very high, and the intentions to increase their consumption are rather low as well. As our study demonstrates, sociodemographic factors have a role in pulse and PBMA consumption, most notably gender, age, education and perceived financial situation. Age and gender were also prominent factors in relation to perceived barriers to pulse and pulse-based product consumption. Our research also shows that the COM-B model is relevant when examining pulse and PBMA consumption. First, eating plant-based foods requires motivation to do so, and the major motivational barrier in our study was the unpleasant taste. Second, there needs to be suitable opportunities to further engage consumers in pulse and other plant-based protein consumption, e.g., in terms of affordability and store settings. Third, consumers need sufficient capabilities to be able to prepare enticing pulse- or other plant-based dishes, but unfamiliarity with and uncertainty in preparing pulses and PBMAs are barriers to their consumption. Thus, offering easy to use, tasty and affordable pulse and other plant protein-based dishes and products can pave the way towards more environmentally sustainable food consumption.

## Data availability statement

The raw data supporting the conclusions of this article will be made available by the authors, without undue reservation.
## Ethics statement

The studies involving humans were approved by University of Helsinki Ethical Review Board in Humanities and Social and Behavioral Sciences. The studies were conducted in accordance with the local legislation and institutional requirements. The participants provided their consent electronically.

## Author contributions

SK, MN, A-MP, KK, TM, and HK contributed to conception and design of the study. HK, KK, A-MP, and TM were responsible for data collection. SK performed statistical analyses, wrote the first draft of the manuscript, and had primary responsibility for the final content of the manuscript. HK collaborated in conducting the statistical analyses. HK, MN, A-MP, KK, and TM commented and critically revised the manuscript. All authors contributed to the article and approved the submitted version.

## Funding

This research was funded by the Strategic Research Council at the Academy of Finland (grants 327698 and 327700), the Academy of Finland (grants 309157 and 314135 to HK and grant 315898 to MN). Wihuri Foundation (grant 00210156 to SK) and Raisio Plc's Research

Foundation (personal grant to SK). The funding sources had no involvement in study design, data collection, analysis or interpretation, writing the article, or in the decision to submit the article for publication.

## Conflict of interest

The authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

## Publisher's note

All claims expressed in this article are solely those of the authors and do not necessarily represent those of their affiliated organizations, or those of the publisher, the editors and the reviewers. Any product that may be evaluated in this article, or claim that may be made by its manufacturer, is not guaranteed or endorsed by the publisher.

## Supplementary material

The Supplementary material for this article can be found online at: https://www.frontiersin.org/articles/10.3389/fnut.2023.1186165/full#supplementary-material

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<figure><img src="image_38.png" /></figure>

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OPEN ACCESS

EDITED BY
Jean-Francois Hocquette,
INRA UMR1213 Unité Mixte de Recherche sur
les Herbivores (UMRH), France

REVIEWED BY
Deepak Choudhury,
Bioprocessing Technology Institute (A*STAR),
Singapore
Wade Brorsen,
Oklahoma State University, United States

*CORRESPONDENCE

Josephine Wee
jmw970@psu.edu

RECEIVED 30 March 2023
ACCEPTED 24 August 2023
PUBLISHED 08 September 2023

CITATION

Failla M, Hopfer H and Wee J (2023) Evaluation of public submissions to the USDA for labeling of cell-cultured meat in the United States.
*Front. Nutr.* 10:1197111.
doi: 10.3389/fnut.2023.1197111

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# Evaluation of public submissions to the USDA for labeling of cell-cultured meat in the United States

Morgan Failla, Helene Hopfer and Josephine Wee*

Department of Food Science, The Pennsylvania State University, University Park, PA, United States

With the rapid advancement of cell-cultured meat processing technologies and regulations, commercialization of cell-cultured meat to market shelves requires the implementation of labeling that informs and protects consumers while ensuring economic competitiveness. In November 2022, the United States Food and Drug Administration (FDA) completed its first pre-market consultation of cell-cultured meat and did not question the safety of these products for human consumption. As of June 2023, commercialization of cell-cultured meat products has become a reality in the United States. To derive potential label terms and gain insight into how different stakeholders refer to these novel products, we analyzed 1,151 comments submitted to the 2021 U.S. Department of Agriculture's Food Safety and Inspection Services (USDA-FSIS) call on the labeling of cell-cultured meat and poultry. Our first aim was to systematically assess the nature of comments with regards to their length, cited references, and supplemental materials. In addition, we aimed to identify the most used terms to refer to these products through text analysis. We also asked how these analyses would vary by affiliation category and economic interest. Using the listed organizations for each comment, we first determined financial ties: 77 (7%) comments came from those with an economic interest, 12 (1%) of the comments did not have an identifiable economic interest, while for the remaining 1,062 (92%) comments economic interest could not be determined. We then grouped comments into affiliation categories. Cell-cultured meat companies and animal welfare non-profits had the highest median word count, whereas comments from the unknown affiliation category had the lowest. We found across all comments the predominantly mentioned potential label terms, in descending order, to be *cultured meat*, *lab-grown meat*, *cultivated meat*, *cell-cultured meat*, *clean meat*, and *cell-based meat*. While all label terms were discussed throughout overall submissions, percentages of comments mentioning each term differed between affiliation categories. Our findings suggest differences in how affiliation categories are discussing cell-cultured meat products for the US market. As a next step, the perception and acceptance of these terms must be evaluated to identify the optimal label term regarding the information and protection provided to consumers while ensuring economic competitiveness.

KEYWORDS

cellular agriculture, food policy, labeling, meat, public comment analysis, text analysis
# 1. Introduction

Alternative meat innovation has advanced with increased awareness of the traditional meat farming industry's impact on global sustainability and food security. US Americans are among the top five consumers of beef, veal, pork, and poultry meat (1). The impact of traditional meat production on greenhouse gas (GHG) emissions and water use poses global sustainability issues (2). Beef farming in particular represents almost half of GHG emission associated with agriculture in the United States (3). While research has prioritized decreasing environmental impacts of traditional meat production, several studies report that a majority of consumers are unaware of negative implications of meat production and consumption (4–6). Currently, few consumers choose meat alternatives to replace traditionally farmed meat due to their dissimilarity in terms of flavor and texture (7). Food insecurity has increased globally since the COVID-19 pandemic (8). The rising world population also imparts further issues toward adequate meat production; global food production must increase by 70% by 2050 to meet demands (9). The disruption of the economy from the pandemic paired with the influx of the world population creates an obstacle for consumers to purchase and consume protein-rich foods with a lower environmental impact (10).

Cell-cultured meat<fnref n="1" /> has emerged as an alternative and parallel production to traditional meat due to the potential positive impact on global sustainability, paired with a sensory experience that mimics that of traditionally farmed meat (11). However, it remains unclear how able the cell-cultured meat industry will be to successfully manufacture products that at the same time meet these goals. (12). As production processes are still being optimized, little is known of the taste, nutrition, safety, and environmental impact of large-scale production of these products (13, 14). Further, differences in acceptance of cell-cultured meat hinders broad public appeal (15, 16). Cell-cultured meat is produced through a process starting by (1) identifying and isolating target cell and tissue, (2) selecting and expressing target cells, (3) culturing of cells, (4) collecting of cell biomass, and (5) processing into a meat product (17). While this process has the potential to create meat products while using less water, consumer perception varies, which may be attributed to differences in consumer attitudes including food technology neophobia (13).

In the United States, the FDA approved cell-cultured meat production in November 2022 followed by the USDA's approval for commercialization in June 2023 (17, 18). While the regulatory barriers for production and sales of cell-cultured meats have been lowered, there is a gap in determining how these products should be labeled. In 2021, the United States Department of Agriculture's Food Safety and Inspection Services (USDA-FSIS) published an advanced notice of proposed rulemaking (ANPR), open to public submission. They sought public input regarding the labeling of cell-cultured meat and poultry (19). The purpose of the ANPR is to establish the intent of a new rule or regulation and allow for public comment via an open response forum to gain insights into public

opinion to facilitate rule development. There are no requirements regarding who is able to submit a comment. According to the Federal Register, an "*Advance Notice is a formal invitation to participate in shaping the proposed rule and starts the notice-and-comment process in motion*" (20).

Specifically, the ANPR gathered public comments on cell-cultured meat with 14 questions provided by FSIS (see Supplementary Table S1). These questions prompted responses on potential labeling strategies, the impact of the label terms on the meat market, and how these labels would differentiate cell-cultured meat products from traditionally farmed meats (19). To understand the views of the public, we analyzed ANPR comments with text analysis tools to gain insight into how proposed labels differ between affiliation categories of comment submitters.

Regulation and identification of cell-cultured meat within the standards of identity of meat must be implemented for consumers to make informed purchase decisions. There are two sections within the Code of Federal Regulations in which cell-cultured meat must be addressed, namely, how meat is defined and how meat is labeled. The Federal Meat Inspection Act, found in 9 CFR 301.2, legally defines foods including meat, meat byproduct, and meat food product (21). While cell-cultured meat does not abide by the definitions for meat or meat byproduct as it is not “part of the muscle of cattle” or “any part capable of use as human food” (21), it certainly would fit into the definition of a meat food product, “any article capable of use as human food which is made wholly or in part from any meat or other portion of the carcass…” (21). This legal ambiguity of what differentiates traditional meat from cell-cultured meats is part of the challenge of how to label these products, not only in the United States but around the world (22).

Labeling definitions and characteristics of meat, meat byproducts, and meat food products are regulated as described in 9 CFR 317.2 (23). There it is stated that for any product with no common or usual name, a descriptive designation used as a product name must clearly and completely identify the product. Further, meat preparation processes (e.g., smoking, salting) must be identified on the label and industry relevant terms (e.g., “picnic,” “cala”) shall not be used as the product name unless paired with descriptive terms (e.g., flavorings, marinades), or with a list of ingredients, to ensure transparency (23). With cell-cultured meat companies, such as Upside Foods and Good Meat, recently receiving regulatory clearance for production and sales, stakeholders must consider these parameters when establishing labeling strategies. Such strategies could include omission of the word ‘meat’ all together and/or use of another term, such as ‘protein’.

With commercialization of cell-cultured meat in the United States, meat industry stakeholders vary in their support for these new products. Due to the potential for cell-cultured meat to take over a percentage of the market share within the traditional meat industry, established traditional meat farmers may experience negative impacts in terms of food security and profits (24). On the other hand, success in the cell-cultured meat industry could be dependent on cell lines obtained from healthy cattle raised by traditional meat farmers, therefore transparency and communication strategies must be enforced to ensure fairness and equity between these two groups. Here, we seek to identify differences in proposed labeling strategies submitted to the ANPR as a function of meat industry stakeholder groups and affiliations (e.g., cell-cultured meat vs. traditional meat companies).

<footnote n="1">¹ In this study, we will align with the USDA-FSIS referencing food products produced by cell-culture as “cell-cultured meat.”</footnote>
An interesting case in this effort represents Tyson Foods, a top investor in cell-cultured meat as well as an established leader in the traditional meat farming industry. Tyson has invested in companies developing cell-cultured meat such as Upside Foods, Memphis Meats, and Future Meat Technologies (25–27). As such, Tyson Foods’ comments on how cell-cultured meat should be commercialized and labeled presents an opportunity to analyze how potential opposing viewpoints could be resolved. For these reasons, we chose to analyze Tyson Foods’ submission separately.

We outlined three main objectives for this study. First, we aimed to determine the extent and disclosure of comments as they relate to economic interests and affiliation. We hypothesized that those with a stated economic interest will have a higher percentage of submissions compared to those without identified financial ties. Here, we further defined an economic interest as those who experience impact to their economic status with the commercialization of cell-cultured meat. Further, we also hypothesized that different affiliate categories will differ in their submissions with regards to length and extent of providing scientific evidence and supplemental materials, with cell-cultured meat companies hypothesized to provide more external reference citations than traditional meat companies.

For the second objective, to identify the predominant labeling terms used for cell-cultured meat across the different affiliation categories, we hypothesized that the cell-cultured meat industry and traditional meat farming industry will refer to these novel products in their submission using different label terms. Further, we evaluated the diversity of label term constructs (i.e., hyphenated, preceding, and root terms). For example, label term constructs could be “cell-cultured meat,” “man-made protein,” which were similarly analyzed to create a comprehensive list.

Last, the submission received by Tyson Foods was treated as a special case due to the economic interests of this company in both traditional meat farming and cell-cultured meats. Analyzing this submission as described above, we hypothesize that the Tyson Foods submission will mention label terms similar to the predominant labels mentioned by the traditional meat farming affiliation group due to their longer history in the traditional meat industry.

Outcomes from a systematic and scientific evaluation of the comments submitted to the USDA-FSIS ANPR will provide an overview of submission extent, disclosure, and label term use for industry and regulatory professionals to gain insight on current terminology regarding cell-cultured meat in various sectors. Results from our systematic analysis could form the basis of future consumer insights research, to assess perception and acceptance of different labels for these novel food products. Our analytical method, pairing automated text analysis tools with manual evaluation, allows for a comprehensive assessment of terms used to discuss these products.

# 2. Materials and methods

## 2.1. Dataset

On 3rd September 2021, the USDA-FSIS started collecting open responses *via* an ANPR regarding “labeling of meat or poultry products comprised of or containing cultured animal cells.” The proposed rule contained 14 items (see Supplementary Table S1) for public comments including how products should be labeled, how label

terms impact consumer choice, standards of identity, and the meat market. The submission period was initially opened until 2nd November 2021, but extended until 2nd December 2021. A total of 1,207 comments were received during this timeline, of which 1,180 were available for download. The remaining 27 comments were inaccessible due to the USDA-FSIS quality standards; no further information was provided. The data was accessed for analysis on 12th September 2022 *via* the USDA-FSIS website and exported to Microsoft Excel. While most comments were viewable in the Excel file, some comments were extracted by downloading pdf and/or Microsoft Word files that were available in the Excel file as downloadable attachments. All data analyzed in this study were retrieved from Regulations.gov, the United States Federal government website document repository.<fnref n="2" />

## 2.2. Data analysis

A comprehensive outline of our data analysis procedures is summarized in Supplementary Figure S1. Upon manual inspection of all submissions, those that were duplicated (n=18), unrelated (n=2), blank response (n=2), or requesting an extension for the submission period (n=5) were omitted from further analysis. One submitted Excel file, containing 6,028 identical entries, was also omitted from analysis. Supplemental submission materials were not analyzed as part of the median word count analysis. In addition, citations, welcoming introductions, repeated USDA-FSIS proposed questions, and closing remarks were manually removed to standardize submission comments to only contain information regarding labeling of cell-cultured meat. After cleaning, 1,152 comments, including the Tyson Foods submission, were used for analysis. Over 99% of submissions (1,143 out of 1,152) were made by individuals or entities residing in the United States, based on the stated location for each comment.

Several inferences were made for our analysis. Economic interest of submissions was evaluated to determine the extent and disclosure of comments relative to their economic relation to the cell-cultured meat industry. Economic interest was determined by manual web and/or social media searches and established using one or more of the following parameters:

1) Direct connections to the cell-cultured meat industry, e.g., cell-cultured meat companies.

2) Cell-cultured meat production and sales may directly affect their market share in the meat industry, e.g., traditional meat farmers.

3) Economic interest was outwardly stated in comment.

4) Non-profit organizations who represent the interests of companies satisfying points 1 or 2, due to dependency on each other for economic success.

5) Research organizations who receive funding related to the cell-cultured meat industry.

6) Investments in companies satisfying 1 or 2.

Affiliation categorization was determined by manually researching each organization and sorting submissions into affiliation categories

<footnote n="2">2 https://www.regulations.gov/docket/FSIS-2020-0036/comments</footnote>
that were identified *via* discussions by the author team (see *Supplementary Table S2*): cell-cultured meat companies, traditional meat farmers, research organizations, farmer advocacy groups, federal, state, and government agencies, animal welfare non-profits, other, and no affiliation. Cell-cultured meat companies included companies that produce cell-cultured meat. Traditional meat farmers included companies that produce traditionally farmed meat. Research organizations included organizations that perform research related to cell-cultured meat, agricultural sustainability, human nutrition, food safety, and genetically modified foods. Farmer advocacy groups included organizations that advocate for traditional meat farming practices. Federal, state, and government agencies included responses from those agencies and representatives of those agencies. Animal welfare non-profits included organizations that advocate for ethical farming practices. Other was recorded when there was an affiliation listed but it did not fit into the previously listed categories. Unknown affiliation included those who commented that did not identify an affiliation. This included 131 submissions made from differing individual submitters that started “As an Arkansas farmer ...” Due to lack of disclosure of an organization, these submissions were categorized in the ‘unknown’ category.

Once submissions were cleaned and categorized, a combination of manual and automated analyses in R, NVivo, and Microsoft Excel was conducted across all comment submissions and per affiliation category. The number of scientific references and supplemental information was manually quantified and recorded for each submission. This was performed by examining footnotes, bibliographies, and in-text citations. The percent reported was calculated by counting the number of comments containing cited references for each affiliation category. Mean citation count was quantified by reporting the total number of references for each submission and calculating the mean for each category. Supplemental information included slide presentations, attached research articles, and summary booklets. Supplemental information counts were quantified from manually counting and calculating total submissions that attached supplemental information counts. Analysis was performed in R (V.4.2.1), using the RStudio environment (V.2022.7.2.576, Boston, MA) with the additional packages ggplot (28), dplyr (29), tidytext (30), and ggpubr (31). We used dplyr and tidytext to evaluate the word count for each group by affiliation and economic interest reported as median and range word count. Comments were analyzed directly in RStudio, as they were within the cell character limit of Excel (32,767 characters). However, two comments (Good Food Institute, Harvard Animal Law & Policy Clinic/Harvard Food Law and Policy Clinic), which had content larger than this were analyzed manually *via* Microsoft Word.

Then each submission was analyzed for commonly mentioned label terms (e.g., cell-cultured, cultivated, clean, etc.) – this was done in step-wise manner using NVivo (version 12, QSR International, Burlington, MA): First, common words and phrases were identified surrounding the most common word mentioned ‘meat’. We used the ‘word tree’ function to identify the hyphenated and preceding terms to ‘meat’. Then each term was evaluated by ‘text search queries’ to identify the most common label term constructs used overall. We further performed a forwards and backwards analysis of preceding and hyphenated terms by word trees to evaluate root terms used to discuss these products. An overview of label term constructs was recorded in Excel (see *Supplementary Table S3*).

Using the most common label terms identified in overall comments, the Microsoft Excel advanced search was used to obtain counts of comments mentioning each term. All text search analysis was performed by searching for the full label term construct. The results were recorded in Excel for data visualization in R. We analyzed the percentage of submissions mentioning each label term overall and by affiliation category. To compare between affiliation categories, which differed in number of submissions, we report percentages of submissions within each affiliation group mentioning each label term. This was calculated by quantifying the number of submissions that mentioned each label within each affiliation category, divided by the total submission count for each category, and multiplied by 100. The same analysis was completed for the Tyson Foods submission. However, for Tyson Foods we did not calculate a percentage since n=1 in this case.

# 3. Results

## 3.1. Economic ties and affiliation do not predict total submission count or word count

Our first research question addressed the extent and disclosure of comments related to economic interest. Extent is defined as the length and content of the submission which we evaluated using word count, number of references, and supplemental information. When there was an organizational tie which could identify economic interest, we used the term ‘disclosure’ to identify this group. We defined economic interest as those who have a financial tie to the cell-cultured meat or traditional meat farming industry (see Materials & Methods section). We hypothesized that those with economic interest will have a higher percentage of submissions both in number as well as length (i.e., median word count) in comparison to those without an identified economic interest. However, our analysis shows (*Supplementary Table S4*) that only 77 (6.7%) comments were submitted by an entity with an identifiable economic interest, 12 (1.0%) comments were entered by those without an identified economic interest, and the vast majority, 1,062 comments (92.3%) were submitted where the economic interest could not be identified (e.g., anonymous submission or submission as a private citizen).

Table 1 provides an overview of the origin and characterization of submissions by affiliation category. The parameters of comment composition (e.g., word count, number of references, and extent of supplemental information) was hypothesized to predict economic interest. We found that affiliation category did not impact submission extent or disclosure. Percentages of submissions by affiliation were calculated for each category and reported in Table 1. The majority of comments came from those with unknown affiliation (n = 1,062; 92.3% of submissions) which also had the lowest median word count of 68, or roughly one paragraph (Table 1). Cell-cultured meat companies made up 1.2% of submissions and had the second largest median word count of 2048, or roughly 2.5 letter sized pages single spaced (Table 1). The lowest number of submissions came from traditional meat farmers with 2 submissions (0.2%), neither of which included references or supplemental information, and had a median word count of 1,208. The greatest number of comments from those with a listed affiliation came from farmer advocacy groups, who
<table><caption>TABLE 1 Presence of affiliations, citation of scientific evidence, supplemental information, and median word count.</caption><thead><tr><td>Affiliation category</td><td>% of Total (n)</td><td>% Citing references (n)</td><td>Mean citation count</td><td>Median word count (Range)</td><td>Comments with supplemental information</td></tr></thead><tbody><tr><td>Cell-cultured meat companies</td><td>1.2 (14)</td><td>64.3 (9)</td><td>8.1</td><td>2048 (283-4,614)</td><td>2</td></tr><tr><td>Traditional meat farmers</td><td>0.2 (2)</td><td>0 (0)</td><td>0</td><td>1,208 (848-1,567)</td><td>0</td></tr><tr><td>Research organizations</td><td>1.0 (11)</td><td>90.9 (10)</td><td>7.8</td><td>1,337 (359-5,990)</td><td>1</td></tr><tr><td>Farmer advocacy groups</td><td>3.2 (37)</td><td>13.5 (5)</td><td>1.1</td><td>756 (202-4,771)</td><td>1</td></tr><tr><td>Animal welfare non-profits</td><td>0.3 (4)</td><td>75.0 (3)</td><td>18.8</td><td>2,379 (626-3,291)</td><td>1</td></tr><tr><td>Government agencies</td><td>1.0 (11)</td><td>9.1 (1)</td><td>0.8</td><td>642 (323-1969)</td><td>0</td></tr><tr><td>Other</td><td>0.9 (10)</td><td>30 (3)</td><td>15.5</td><td>742 (66-8,731)</td><td>1</td></tr><tr><td>Unknown affiliation</td><td>92.3 (1062)</td><td>0.5 (5)</td><td>0.1</td><td>68 (1-4,609)</td><td>6</td></tr></tbody></table>

submitted 37 comments (3.2%), with a median word count of 756 (Table 1). All other affiliations had comparable submission numbers ranging from 2 to 14 submissions (Table 1). The highest median word count of 2,379 were made by animal welfare non-profits who also had the highest mean citation count (Table 1).

Percent citing references and mean citation counts differed greatly both by economic interest and affiliation: we found that those without identified economic interests (N=12) had the highest mean citation count (M=19.2), highest percent citing references (32%), and highest median word count (Mdn=1766) (Table 1). The affiliation category with the highest percent of cited references included research organizations – of the 11 submissions in this group 90% cited references in their comments. The inclusion of supplemental material, as previously defined as additionally submitted materials together with the comment, did not differ by economic interest or affiliation categories (Supplementary Tables S1, S3). However, the comments for which no affiliation could be assigned showed the highest number of comments with supplemental information (Table 1). Upon further manual inspection these included PowerPoint presentations, figures, and peer-reviewed scientific manuscripts.

## 3.2. The same top 6 label terms were identified across all comments, however, label term mentions differ greatly across affiliation categories

Our second research question assessed how different commenters referred to these novel food products in their submissions, as an indirect way of identifying potential labels for these products. Using NVivo to identify the top label terms, we found the most widely used overall, in descending order of percent of comments mentioned, to be *cultured meat* (29.8%), *lab-grown meat* (13.6%), *cultivated meat* (8.2%), *cell-cultured meat* (5.6%), *clean meat* (5.2%), and *cell-based meat* (3%).

These top 6 terms accounted for 2/3 of all comments.

Due to the ambiguity in application of the current standards of identity for meat, potential labels could also omit the root term ‘meat’. Therefore, an additional analysis was carried out to identify root terms other than ‘meat’ or no root term at all, across all submissions and by affiliation category. Upon analyzing the top 6 hyphenated and preceding terms regardless of root term (i.e., searching without the root term ‘meat’), a similar rank order was found, except for *cell-based* and *clean*. Compared to analysis including the ‘meat’ root term, mentions of *cell-based* and *clean* switched rank order, with *cell-based* (9%) having higher mentions than *clean* (8%) (Figure 1B). The analysis without the root term *meat* also identified the label *lab-cultured* as a top label term (12%) (Figure 1B), as it was referenced by the unknown and government agencies affiliation groups in conjunction with the root term ‘protein’.

Using the top 6 terms in conjunction with the root term ‘meat’ identified in our analysis, we then focused on our second research question of how percentages of label terms mentioned in comments might differ across affiliation categories (Figure 2). To better understand the use of the hyphenated and preceding label terms, we further analyzed them without the root term ‘meat’ in Supplementary Figure S2. It was observed that overall trends of label mentions for each affiliation category were similar when analyzed with and without the root term ‘meat’ (Figure 2, Supplementary Figure S2). Among the mentions of the top 6 terms, differences in percentages are apparent between affiliation categories: While cell-cultured meat companies predominantly used the term *cultivated meat* (64.3%), all other terms were mentioned between 25–50%, except *cell-based meat* which was mentioned in less than 10% of submissions (Figure 2A). On the other hand, traditional meat farmers primarily used the terms *cell-cultured meat* and *cell-based meat* 100% of the time (Figure 2B). However, it is important to note that only 2 submissions made up the traditional meat farmers affiliation category. Interestingly, research
<figure><img src="image_39.png" /><figcaption>FIGURE 1</figcaption></figure>

Overall percentages of submissions mentioning top label terms. (A) Overall percent of comments mentioning each hyphenated and/or preceding label term together with the root term 'meat'. (B) Overall percent of comments mentioning each hyphenated and/or preceding label term, analyzed without the root term 'meat'.

organizations mentioned *cell-cultured meat* in 63.6% of comments (Figure 2C). Farmer support non-profits, the affiliation category with the highest number of submission (n = 37), mentioned the terms *cell-cultured meat* and *cultured meat* in a moderate percent of submissions (43.2, 48.6% respectively) (Figure 2D). Similarly, *cultured meat* and *cell-cultured meat* were the most frequently (both 75%) mentioned terms for submissions made by animal welfare non-profits (Figure 2F). Those categorized as “other” moderately mentioned *cultivated meat* (50%) and *cultured meat* (40%) (Figure 2G), while those with an unknown affiliation mentioned all terms sparingly (less than 25%), with *cultured meat* being the most commonly used term (28.7%) (Figure 2H). The comments within the unknown affiliation category beginning with “As an Arkansas farmer…” all proposed the term *lab-cultured protein*. Therefore, they did not affect the results in Figure 2, but contributed to the findings of Figure 1B and Supplementary Figure S2 indicating *lab-cultured* as a top hyphenated and preceding label term when analyzed without the root term ‘meat’.

Only 3 of the 6 label terms were mentioned across all affiliation categories, namely, *cell-cultured meat*, *cultured meat*, and *lab-grown meat* (Figure 2). While cell-cultured meat companies, research organizations, farmer advocacy groups, and animal welfare non-profits discussed all top 6 label terms, several affiliation groups completely omitted certain label terms. For example, traditional meat farmers predominately mentioned the terms *cell-cultured meat* and *cell-based meat* (Figure 2B), while omitting the label term *clean meat*. Similarly, government agencies did not mention *cultivated meat* or *cell-based meat* (Figure 2E), and *clean meat* was not mentioned in comments made by the “other” affiliation category (Figure 2G). Comments from unknown affiliations (Figure 2H) and government agencies (Figure 2D) scarcely mentioned any of the proposed labels.

### 3.3. Tyson foods, with interests in both cell-cultured and traditional meat, proposes three terms: *cultivated*, *cell-based*, *cultured*

Our third research question evaluated the comments submitted by Tyson Foods and how their suggested label terms compared to

cell-cultured meat and traditional meat professionals. The Tyson Foods submission contained 1,669 words, 4 citations, and no supplemental information. Of the top label terms identified from the overall comments submitted to the ANPR (see Figure 2), only *cultured meat* and *cultivated meat* were mentioned by Tyson Foods. However, their submission mentioned a three-part conjoined term, “*cultivated/cell-based/cultured*” (mentioned 11 times), with the root term mentioned as being “along with the appropriate standard of identity or common or usual name.” When discussing these products, Tyson Foods most often referenced them as *cultured animal cells*. This suggests a work-around the existing limitations for cell-cultured meats with regards to the meat standard of identity regulation.

## 4. Discussion

The present study systematically evaluated comments submitted to a response ANPR that sought public input on cell-cultured meat labeling. Using our research hypotheses that economic interest and affiliation would affect submission extent and quantity, we found an effect opposite of what we expected. Further, the median length of submissions was highest for those without economic interest. This finding may be due to the nature of the organizations without economic ties submitting from the “other” and animal welfare non-profit affiliation categories, as they customarily voice their opinion on government policy. For example, within the affiliation category “other,” law students in the Harvard Animal Law and Policy Clinic and the Food Law and Policy Clinic submitted an 18-page response to the ANPR (33). They supported their sizeable comment by indicating the potential implications mandated labeling of these novel products has on First Amendment rights. Within the animal welfare non-profits, groups such as PETA submitted responses of length to express their outlook on the importance of these novel products for animal welfare. Three of the four submissions within this affiliation category responded to the prompted questions by the USDA-FSIS. While these organizations rely on voicing their opinions to guide policy, their lack of economic interest may also compel their extensive submissions as their relevance is not financially motivated, but ethically. Conversely,
<figure><img src="image_40.png" /></figure>

<figure><img src="image_41.png" /></figure>

<figure><img src="image_42.png" /></figure>

<figure><img src="image_43.png" /></figure>

<figure><img src="image_44.png" /></figure>

<figure><img src="image_45.png" /></figure>

<figure><img src="image_46.png" /></figure>

<figure><img src="image_47.png" /></figure>

FIGURE 2

Percentages of submissions mentioning top label terms by affiliation. The percentages of submissions mentioning each of the top label terms in conjunction with the root term 'meat' was calculated for (A) cell-cultured meat companies (n = 14), (B) traditional meat farmers (n = 2), (C) research organizations (n = 11), (D) farmer advocacy groups (n = 37), (E) animal welfare non-profits (n = 4), (F) government agencies (n = 11), (G) other (n = 10), and (H) unknown affiliations (n = 1,062).

those with economic ties may not feel that it is necessary to support their argument in this manner as they are closely tied to the field, making their opinions inherently relevant.

While identified affiliation and economic interest were not predictors of submission quantity or length of submitted comments, percentages grouped by affiliation identified which types of
organizations were most intrigued to submit. In terms of economic interest, we identified an overwhelming number of submissions from those with unknown ties. With this finding, we reject our first hypothesis that those with economic interest will have the highest number of submissions. It is also possible that these submissions chose to not disclose an economic interest. Only a small fraction of submissions were made by non-United States entities. There were 22 international submissions originating from Australia, Canada, Denmark, Germany, Israel, Netherlands, New Zealand, Saudi Arabia, Singapore, Spain, Uganda, and the United Kingdom. Of the international submissions, none had an identifiable organization. However, we found that 3 submissions from Canadian government agencies did not designate a country of origin; it is possible that other submissions did not declare their country of origin.

Interestingly, submissions made by individuals with unknown economic interest were much shorter as indicated by the lowest median word count of roughly a paragraph compared to those with and without economic interest of 1.5-3.5 standard pages. We infer that these submissions (i.e., with unknown ties) may represent the concerns and opinions of everyday consumers on how such products should be labeled. The differences in median word count could also be attributed to the lack of response to each of the 14 proposed rules that the FSIS provided with the ANPR. In general, comments that disclosed the submitting organization were much longer and provided comments on more of the 14 proposed rules – we believe that is reflective of organizational tie, regardless of economic impact.

Our findings regarding what types of affiliations submitted comments identified farmer advocacy groups to be the largest group of commenters with an identifiable organizational tie, submitting more than double the number of comments than the cell-cultured meat industry. It is apparent that these organizations likely voiced group opinions of traditional meat farmers as direct submissions from traditional meat farmers were minimal. Of the various farmer advocacy groups, it is known that the United States Cattlemen's Association (USCA) is petitioning against the use of the term *meat* within labeling of meat alternative products, evidenced by their 2018 submitted petition to the FSIS to establish meat labeling requirements. This petition did not receive a response until 2021, in which the reply resulted in the release of the ANPR evaluated in this paper (34, 35). This suggests that the traditional meat industry has recognized cell-cultured meat commercialization as a significant impact to their livelihood and economy. Further, they advocate for transparent labeling that does not negatively impact profits of traditional meat products.

Our text analysis results identified several potential label terms for these novel food products, both with and without the root term 'meat'. This forms a basis to further explore suitable labels. We quantified the percentages of label terms mentioned by each affiliation, which may provide evidence of how these affiliation groups differ in discussing these products. For example, the omission of *clean meat* by traditional meat farmers and the "other" affiliation category indicates that these groups do not identify it to be a potential label. We also found that all top 6 label terms were mentioned similarly when analyzed with and without the root term 'meat', which could indicate a labelling strategy including these hyphenated and preceding terms that would circumvent the potential restrictions of use of the term 'meat'.

Our investigation of the most widely mentioned label terms allowed for visualization of the diversity in discussion of these novel products. Overall, *cultured meat* was mentioned in about 1/3 of comments, the highest percent of all top label terms identified (Figure 1A). However, when analyzing terms by affiliation category, differences in percentages of label mentions became apparent (Figure 2). Cell-cultured meat companies frequently mentioned the term *cultivated meat*, whereas traditional meat farmers frequently mentioned the terms *cell-cultured meat* and *cell-based meat*. This suggests that these two industries, thought to have directly opposing viewpoints, reference these products with different terminology. Our finding supports our second hypothesis regarding differences in predominant label terms mentioned in comments by these two affiliation categories. Further, the percent mentions by farmer advocacy groups revealed partial alignment with submissions by traditional meat farmers through similar percentages mentioning *cell-cultured meat*. The predominant labels *cultured meat* and *cell-cultured meat* by animal welfare non-profits may provide insight of how these products are being discussed by those who feel passionately about animal welfare. The scarcity of label mentions by government agencies and the unknown affiliate group makes it difficult to identify how these products are being discussed by these affiliations. However, from Supplementary Figure S2 it is apparent that these affiliation categories referenced these products primarily using the preceding term *cultured*, indicating use of a different root term or no root term at all.

We speculate that the hyphenated term *cell-among* the predominant label terms mentioned by traditional meat farmers, may indicate a preference for technology-oriented terminology. While labeling these products using the term *cell-*has been shown to increase consumer understanding, it may elicit a negative consumer response related to food technology neophobia, or perceived naturalness of these products (36). Further, the lack of the term *clean meat* in submissions made by traditional meat farmers may be due to the adverse effects that labeling cell-cultured meat as *clean meat* would have on the perception of traditional meat (inferring that traditional meat may be “unclean” or “dirty”). A recent study by Malerich & Bryant also scanned submissions to the ANPR to identify different labels for their consumer research study. They sought to identify consumer perception of the various label terms with regards to transparency, appeal, purchase intent, and perceived safety (16). While using the prefix ‘cell-’ increased consumer understanding of the product, however, appeal, purchase intent, and perceived safety for beef products was highest when presented with the term *cultivated meat* (16). As this term is the predominant label term mentioned by cell-cultured meat companies, we speculate that cell-cultured meat companies are proposing labeling of these products with more appealing terminology. Due to the limited analysis of the ANPR comments in Malerich & Bryant’s – in which they used an online tracker which only contained comments with an identifiable organization tie, and only analyzed the preceding label term, there are differences in the overall hierarchy of label terms identified in their and our study. Nonetheless, their findings confirm 5 of the top 6 labels we identified, with the except of the term *clean meat*, which we identified to be mentioned in 5% of comments.

We analyzed the submission by Tyson Foods separately due to their affiliation with both the traditional and cell-cultured meat industry. Their proposal of three potential terms *cultivated/cell-based/cultured* provides a term for each parameter of importance for a label:
appeal (cultivated), understandability (cell-based), and neutrality (cultured) (37). Interestingly, each label term within the three-part conjoined term relates to the predominantly mentioned label terms by cultivated meat companies, traditional meat farmers, and overall submissions, respectively. Our findings suggest partial alignment with our hypothesis, namely, that Tyson Foods references these products using labels similar to those suggested by traditional meat farmers. However, we identified that the labels mentioned by Tyson were used by both traditional meat farmers and cell-cultured meat companies, which is opposite to what we initially hypothesized. Advantages and disadvantages for these three potential labels have been previously researched (38–41). While the term *cultivated meat* was found to provide greater consumer appeal, the term *cell-based meat* was more clearly understood (22). Label transparency was evaluated in a recent study by Hallman et al. (42). They also found that labels including the term “cell-” were more easily differentiated from traditional meat by a sample of 4,385 US consumers (42). Therefore, we speculate that major players within the cell-cultured meat industry may opt for a label that is both transparent and appealing to consumers.

Prior research has explored the use of different label terms with the public and measured consumer understanding, acceptance, perceived safety, and likelihood to purchase (16, 22, 43–45). Regardless of the lack of specified label terminology for such food products, a study in New Zealand suggested cell-cultured meat to be “rebranded as *clean meat*,” as recent studies demonstrated this label term was highest in positive consumer attitude and acceptance (45). While it is argued that this label leads to higher consumer acceptance, it is not recognized as being a neutral term and may create a negative bias on the traditional meat farming industry (22). The Good Food Institute (GFI) previously encouraged the use of the term *clean meat*, placing an emphasis on the importance of consumer appeal over neutrality and consumer understanding of the label (with the basis of all labels meeting a minimum standard of neutrality) (37). GFI provided one of the longest submissions to the ANPR with the most substantial supplemental materials (6 sections, 118 pages). While we were expecting submissions from academic researchers working in this area, we could not identify submissions from individuals working and publishing in the field. The submission from the Harvard Animal Law & Policy Clinic/Harvard Food Law & Policy Clinic on behalf of five academic researchers affiliated with this group, was the longest within the research organizations affiliation category and contained the largest number of scientific references. The most common term used throughout this submission was *cultivated meat*. In terms of relation to common everyday language, a paper evaluating tweets for mentions of cell-cultured meat indicates that *meat, cultured, cell, based, cultivated, clean, and cells* were among the top words used on Twitter about cell-cultured meat in the United States (46). This reinforces the focal points of a suitable label that were outlined previously and reiterates that the terms identified from social networks and the ANPR alike are commonly used among consumers and thus, provide understandable labeling strategies.

We analyzed all top preceding label terms (e.g., *cultured, cultivated, cell-cultured*) with and without the term meat. Previous research has shown that inclusion of the word *meat* does not play a significant role in consumer understanding (47). However, identifying these products as meat has implications for the standards of identity for meat and meat products as outlined in the introduction. This has become increasingly important with the commercialization of cell-cultured

meat; the FSIS sought specific inputs on this issue in questions 7, 8, 10, and 11 (see Supplementary Table S1). As stated previously, not every submission provided comments on these specific questions. It is unclear why, but nonetheless, to use the term *meat* for these products, they either are recognized as meat under the current version of the CFR, or the CFR must be widened to encompass also cell-cultured meat. While cell-cultured meat has the potential to be recognized as a meat preparation process, to distinguish between cell-cultured meat and traditionally farmed meat, changes to 9 CFR317.2 to allow for cell-cultured meat labeling may in turn force the traditional meat industry to label their products as well. These labels may include terms such as “traditionally slaughtered” or “traditionally processed.” While the USDA-FSIS has not provided any follow-up announcements regarding the labeling of these products, it is currently stated on their website that “FSIS will ensure that cell-cultured products are labeled truthfully and consistent with coordinated FDA and FSIS labeling principles… FSIS does intend to publish new labeling regulations for such products” (48).

To further understand the use of the preceding terms by affiliation categories, we evaluated the percentage of comments for each preceding term of the top label terms (see Supplementary Figure S2). The majority of affiliation groups referenced all top preceding terms in at least 25% of submissions. While our analysis of label terms including the word *meat* revealed lower percentages of submissions referencing these terms, this may be attributed to the variety of root terms used (e.g., *protein, chicken, beef, cultured animal cells*). We also found that some submissions discussed using only the preceding term without a root term. Overall, proposed label term constructs varied in hyphenated, preceding, and root terms (see Supplementary Table S3). Those in support of cell-cultured meat commercialization often proposed consumer friendly label terms containing the root term ‘meat’ and used hyphenated and/or preceding terms such as *slaughter-free, ethical*. Those opposing commercialization often expressed that the term ‘meat’ should not be used to discuss these products. This may be due to the perception of these products as unnatural (49). Others felt that the term ‘meat’ was suitable, but in conjunction with preceding and/or hyphenated terms that may trigger disgust or neophobia within consumers (e.g., *synthetic, fake*) (36, 45). Further, some comments proposed novel terms (e.g., cegan, meatalin). Our findings exemplify the diversity in opinions on how these products should be labeled regarding all portions of label constructs (i.e., hyphenated, preceding, and root terms).

While a portion of submitters feel that these novel products should not be labeled with the root term ‘meat’, a similar case lies with plant-based meat and milk alternatives. The FDA has yet to establish appropriate labeling guidelines for these products. In January 2019, the National Milk Producers Federation (NMPF) submitted a comment to the FDA regarding the use of the word “milk” in plant-based products (32). The impact of labeling terminology on consumer choice and understanding of the nutritional value of plant-based milk products has reached significant concern at the level of the US government. In April 2021, the Dairy Pride Act was introduced in the Senate to enforce against misbranded milk alternatives (50). In 2022, the FDA has listed both of these topics as a part of the “Foods Program Guidance Under Development” (51). Draft recommendations for “the naming of plant-based foods that are marketed and sold as alternatives to milk” was released February 22, 2023, which ultimately allows for these products to be sold as “milk” and recommends a voluntary
nutrient statement (52). No further recommendations have been made regarding the labeling of plant-based meat.

Due to the unique nature of our data sourcing, several limitations of our study exist. The low submission count from traditional meat farmers, in contrast to farmer non-profits and cell-cultured meat companies, impacts our comparison of label use rate between affiliate groups. Another limitation is our inability to identify organizational ties for the vast majority of submissions. Although it could be that these anonymous submissions were provided by everyday consumers, we can only assume these comments represent consumers' attitudes toward labeling of cell-cultured meats. A limitation of our study design is that we quantified the percentage of label mentions rather than the direction of the statements relative to the labels (i.e., positive vs. neutral vs. negative sentiment). Sentiment analysis and other emotion analysis approaches could be performed to further understand negative and positive associations for each proposed label (53). This could consist of further identifying the support, or lack thereof, for each identified most common label term per submission.

Here, we set out to analyze the composition, extent, and disclosure of USDA ANPR submissions for the labeling of cell-cultured meat and poultry products. We identified several potential label terms for consideration. Future studies will evaluate each label term for consistency, transparency, and consumer acceptability. This may help explain *why* consumer appeal varies by label as evidenced by several studies (11, 29, 33). Once cell-cultured meat products are available for tasting, research on the interaction between label terms and perception will provide further insights into consumer acceptance of novel food products.

## Data availability statement

The original contributions presented in the study are included in the article/Supplementary material, further inquiries can be directed to the corresponding author.

## Author contributions

MF, HH, and JW conceived and designed the study. MF performed all text and statistical analysis with support from HH and JW. MF wrote the manuscript with input from HH and JW. HH and

JW supervised the project. All authors contributed to the article and approved the submitted version.

## Funding

This work is supported by the USDA National Institute of Food and Agriculture and Hatch Appropriations under Project #PEN04699 and accession #1019351 to JW, project #PEN04792 and accession #7002577 to HH and a College of Agricultural Sciences SNIP grant to JW and HH.

## Acknowledgments

The authors thank to The Pennsylvania State University libraries, especially John Russell, for help with the NVivo analysis portion of this work.

## Conflict of interest

The authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

## Publisher's note

All claims expressed in this article are solely those of the authors and do not necessarily represent those of their affiliated organizations, or those of the publisher, the editors and the reviewers. Any product that may be evaluated in this article, or claim that may be made by its manufacturer, is not guaranteed or endorsed by the publisher.

## Supplementary material

The Supplementary material for this article can be found online at: https://www.frontiersin.org/articles/10.3389/fnut.2023.1197111/full#supplementary-material

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