FROM LAB TO FORKC R I T IC A L Q U E S T IO N S O N L A B O R A T O R Y- C R E A T E D
A N I M A L P R O D U C T A LT E R N A T I V E SAcknowledgements
This report was written by Dana Perls, M.C.P., Senior Food and Technology Campaigner,
Friends of the Earth U.S.
Friends of the Earth would like to thank Michael Hansen, Ph.D., Senior Scientist,
Consumers Union for review of this report.

About Friends of the Earth:Friends of the Earth United States, founded by David Brower in 1969, is the U.S. voice of the world’s largest
federation of grassroots environmental groups, with a presence in 75 countries. Friends of the Earth works to
defend the environment and champion a more healthy and just world. We have provided crucial leadership in
campaigns resulting in landmark environmental laws, precedent-setting legal victories and groundbreaking
reforms of domestic and international regulatory, corporate and financial institution policies.
Visit www.foe.org to learn more.

Any errors or omissions in this report are the responsibility of Friends of the Earth U.S.

©Copyright June 2018 by Friends of the Earth U.S.

2

BackgroundFor hundreds of years, people around the world have incorporated plant-based proteins like tofu into theirdiets. As problems with the increasingly industrial approach to livestock production have become widely
known, interest in “meat and dairy alternatives” other than plant-based products has also increased. Most recently, significant investment has been made in the research and development of non-plant based products in
an attempt to mimic animal-based products, ranging from animal tissue grown from animal cell cultures withanimal serum, to proteins produced by genetically engineered algae and yeast.
The makers of this new wave of products claim to minimize the environmental impact of industrial factory
farming by replacing animal products with synthetic products; but these engineered substances may also be
resource intensive in their use of energy and water, as well as using feedstocks, like sugar and methane, andchemicals. The new animal replacement products are being marketed or promoted as “clean meat,” “animal-free,” “plant-based” or “climate-friendly,” but with questionable substantiation.
This departure from plant-based foods includes a batch of biotech product proposals. Memphis Meats, forexample, is developing “the world’s first cultured meatball” and “cultured poultry,”1 by using animal serum
to grow animal cells into tissues. Other companies are using genetic engineering to manufacture ingredients that mimic animal proteins. For example, Impossible Foods has genetically engineered yeast to produce“plant blood” (leghemoglobin “heme” protein) for its “bleeding plant-based burger,” and Finless Foods
has genetically engineered algae to produce protein for its “algae-based shrimp.” In addition, several otheranimal replacement proposals with ingredients derived from genetically engineered yeast include Geltor’sgelatin replacement, Perfect Day’s milk replacement and Clara Foods’ egg white replacement.

Growing Investment

According to a recent study, over a 52-week period ending in August 2017, U.S. retail sales of plant-based
milk alternatives generated $1.5 billion in sales, with a growth rate of 3.1%. Meat substitutes generated $555
million and had a growth rate of 6.1%.2 Other studies suggest that the meat substitutes market could be
worth close to $6 billion by 2022.3 In the meantime, startups like Memphis Meats raised at least $22 million
in investments from Bill Gates, Cargill, DFJ Venture Capital, Richard Branson and Tyson Foods.4 Silicon Valley start-up Impossible Foods, maker of the Impossible Burger, has raised upwards of $300 million since2011 from investors including Bill Gates, Li Ka-shing, Temasek, and Khosla Ventures.5 These new investments
are not directed at truly plant-based products, but are in response to the growing market demand for plantbased foods.

Highly Processed

Whether made from genetically engineered yeast or through in vitro processes, these next-generation animal replacement products are manufactured in resource-intensive factories. The products are often madewith multiple processed ingredients, including gums, flavors, colors and other additives. Some products also
include novel, genetically engineered ingredients like the “heme” secreted from genetically engineered yeast,
which gives the Impossible Burger its “blood.”
Various “processing aids” are employed to make some of these products, including organisms (like genetically engineered bacteria, yeast and algae) that produce proteins, and chemicals to extract proteins. For example, chemicals like hexane are used to extract components of a food, like proteins (from peas, soy, corn etc.)
or compounds (from genetically engineered bacteria) to make xanthan gum. Currently, however, disclosure ofthese ingredients is not required. Other processing aids (e.g. bacteria, yeast, algae), including those that are
genetically engineered to produce proteins, are also not currently required to be disclosed on package labeling. The lack of transparency makes it difficult to assess the inputs and impact of their use.

3

Key Concerns

This report will examine important questions and concerns about products like “lab meat” and genetically engineered animal replacement products. While several methods are used to make these second-generation animal replacement products, there are distinctions to make among them concerning disclosure requirements,
safety and environmental concerns, marketing claims, and resources required. These cost/benefit parameters
are important to include in a true assessment of the health and sustainability of each production technique,each product and each product category overall.

KEY QUESTIONS NEED TO BE ANSWERED BEFORE PRODUCTS ARE ALLOWED TO ENTER THE MARKET:•••Are second-generation animal replacement products truly sustainable?
Are they a viable solution to the numerous problems surrounding industrial animal production?
How do these products’ environmental impact compare to sustainably produced plant-based meat anddairy alternatives and products from animals raised in sustainable, high-welfare production systems?
Do they meet their marketing claims as sustainable and healthy
Should the safety of these new products be left to individual companies to determine?
Is there adequate independent safety assessment, regulatory oversight and transparency?
Do these products and their claims meet consumer expectations?

•
•
•
•

Overview of lab-grown meat and genetically engineered animal replacement products

Description ofTechnology

Regulatory Requirements
for Safety Assessment

Data on Health andEnvironmental Impact

4

Lab-Grown Meat

Genetically Engineered
Proteins

Artificial muscle tissue is producedin vitro by mass culturing stem cells
from animals (in energy-intensivesterile conditions).

Yeast, bacteria and algae are engineered to produce proteins thatmimic those derived from plants
and animals.8

The tissue is often cultured andgrown in solutions with bovine
serum,6 mixes of hormones, growth
factors, amino acids, vitamins andother food additives.7

Extraction and other processing
methods are often required toisolate protein(s).

The company may determine thesafety of the product.

The company may determine thesafety of the product.

Data on health and environmental
impact are often hidden as “confidential business information.”

Data on health and environmental impacts from production andcontamination are often hidden
as “confidential business information.”
The safety of genetically engineered “heme” protein in Impossible Burger was questioned by the
FDA.

Transparency

The FDA does not require notification of new food ingredients orprocesses.

The FDA does not require notification of new food ingredients orprocesses.

Manufacturing processes are
considered confidential businessinformation.

GMO ingredients are currently not
required to be labeled as such.

Ingredients used in culture mediums and other processing aids are
not required to be listed on theingredients panel.

Processing aids are currently notlisted on the ingredients panel
and can be considered confidential.

Marketing and Promotion
Claim Examples•••

Clean meat
Cultured meat
Sustainable

Examples of Companies

•
•
•
•

Memphis Meats
MosaMeats
Just, Inc.
Finless Foods•••

Fetal bovine serum13
Cell culture medium
Drugs and antibiotics in medium

Genetically engineered yeast,
bacteria or algae that produce
proteins and other ingredients.

•

Use of energy, water, feedstocks and other chemical
inputs. Lifecycle impacts notavailable.
Greenhouse gas emissions,plastics, water and sus­
tainability footprint.

•

Processing Aids
(not required on
ingredient panel)

Environmental Impacts
and Resource Use

•

•
•
•
•
•
•
•

•

Animal-freePlant-based
Climate-friendly
Sustainable
Impossible Foods (Impossible
Burger)9
Perfect Day (Milk substitute)10,11
Clara Foods (Egg white substitute)12

Use of energy, water, feedstocks and other chemical
inputs. Lifecycle impacts notavailable.
Risk of environmental contamination and escape of engineered organisms.

5

Critical Areas to Examine:

1. Safety & Oversight
Altering an organism at the genetic level can create unexpected changes in the organism, as well as in thecompounds it produces. Animal replacement ingredients produced through genetic engineering may therefore pose unforeseen health risks.14,15 Currently, safety assessments specific to these genetic engineering
techniques are inadequate, and no mandatory regulatory oversight is in place for this swiftly moving set of
new technologies used to genetically engineer organisms. Regulations under the U.S. Department of Agriculture (USDA), Environmental Protection Agency (EPA) and the U.S. Food and Drug Administration (FDA) failto address the health and environmental impact, as well as the safety, of new genetic engineering applications, editing techniques (e.g. CRISPR) and products derived from them.16
Research has demonstrated that some new genetic engineering techniques may result in hundreds of surprise
off-target effects and genetic mutations.17 Theoretically, such mutations could lead to unexpected productionof toxic byproducts that could impact human health in unforeseen ways, such as causing allergic reactions inpeople who consume products with genetically engineered ingredients.18 Concerns run high particularly withregard to engineered proteins, as they may cause novel allergies.19
This lack of precision, together with the potential for unintended consequences, highlights the need for thesenew, genetically engineered organisms and their products to be thoroughly assessed, both in terms of thetechnology and methods used, and on a case-by-case basis, before entering our food system and environment.

NEW FOOD INGREDIENTS, PROCESSING AND TECHNOLOGIESThe safety and true sustainability of these new techniques and products, as well as the resources and inputs
necessary to produce them, have not been thoroughly assessed and require closer examination. New foodingredients, processing aids, and products can move quickly from lab development to marketed products,
without even being reported to the FDA. In fact, there is no tracking and little oversight of any new foodingredients on the market.20 Without strong oversight and clear third-party data, the long-term safety andsustainability of these novel food ingredients cannot be ensured or even understood.
The FDA does not have a viable process for evaluating the safety of novel food products, ingredients or foodadditives that are genetically engineered. In the U.S., new food additives, including those that are geneticallyengineered, are allowed to enter the market through the voluntary “Generally Recognized as Safe” (GRAS)
process. This allows a manufacturer to decide for itself, without FDA input or disclosure, and using only company data, whether or not a product is safe.
GRAS has been criticized for allowing the food industry to bypass critical safety checks for new ingredients.21
In 1958, GRAS was established to require companies to demonstrate that new ingredients were safe. There
was an exemption for “time tested substances” 22 that had already been common in diets and were known tobe safe, like salt or vinegar. In 1997, the FDA changed this rule. Now, companies are not required to notify the
public or the FDA about new food ingredients, additives or processing aids. The inadequate GRAS processapplies to all food additives, which means that ingredients that have not been reported or publicly evaluated,such as genetically engineered proteins and food additives, are escaping evaluation. The GRAS designation
does not require mandatory risk assessment, which can obscure health and environmental impacts.

6Grassfed Organic Burger Ingredients•

Lean organic grass feed beef

Ingredients that may be found in a
Meat-Replacement product•

Soy protein concentrate*•

Maltdextrin*•

Natural flavors including “smoke”•

Hydrolyzed corn or soy protein*•

Caramel color•

Pea protein isolate•

Leghemoglobin (soy)*•

Gum Arabic•

Cellulose•

Soy protein isolate*•

Carrageenan•

Autolyzed yeast extract*•

Oleoresin paprika (color)•

Potassium chloride•

Xanthan gum*

* Ingredients which may be derived fromgenetic engineering
7

CASE STUDY: THE IMPOSSIBLE BURGER
Although Impossible Foods did voluntarily disclose the use of “heme” derived from genetic engineering to the FDA, documents obtained from the FDA through the Freedom of Information Act(FOIA) indicated that Impossible Foods, maker of the Impossible Burger, was informed by FDA
officials that it had not provided adequate proof of safety for a key genetically engineered ingredient, the “soy leghemeglobin” (SLH), or “heme” protein, that gives the burger its meat-like taste andcolor. 23 This novel protein had never previously been introduced to the human diet. Documents also
showed that the manu­facturing SLH with genetically engineered yeast resulted in 46 unexpected
additional engineered proteins. Some of these surprise proteins are unidentified and none were assessed for safety in the dossier provided to the FDA. Impossible Foods presented that SLH is “substantially similar” to real heme found in the root of a soy plant, but not identical.24
The FOIA-procured documents state that the “FDA believes that the arguments presented, individually and collectively, do not establish the safety of SLH for consumption, nor do they point to a
general recognition of safety.” The company was warned by FDA officials that this ingredient would
not meet the basic FDA GRAS status. Despite this warning, Impossible Foods put a product (theImpossible Burger) with this ingredient on the market for public consumption.25 In addition, despite
the concerns of the FDA, Impossible Foods touted the color properties of the engineered “heme,”
but did not seek FDA approval for the “heme” as a color additive. 26

2. Transparency
Environmental and health risk assessments of new food ingredients, processing materials or products areoften not publically accessible, because most of the related data are produced by companies that do nothave to disclose information. This means that any impact on health or the environment is obscured by confidential business information (CBI) pro­tections. CBI obstructs external review, independent of industry-funded
research interests. It can also impede transparency around a company’s decision-making process regarding
safety and whether or not to bring a product to market.
This lack of transparency makes several of the safety and sustainability parameters described above difficult
to assess. Companies can essentially determine the safety of these novel ingredients, technology applications
and products without being required to disclose how those decisions were made or even that a new foodingredient is headed to market.

3. Truth in Marketing
PROMOTIONAL CLAIMS
Some animal replacement product companies, like Perfect Day,27 Clara Foods28 and Impossible Foods,29 havebegun to make “sustainability” claims based on limited evidence or proprietary studies. Many of these novel
products are coming to market with sustainability claims. The Impossible Burger is marketed as “sustainable,”and Perfect Day claims to be “earth friendly,” despite the lack of data on energy consumption, emissions, or
dependency on industrial feedstocks like genetically engineered corn used to feed the genetically engineered
yeast that produce key ingredients. Clara Foods markets its egg whites as “purely from plants,”30 despite key
proteins being derived from genetically engineered yeast. These are just a few of the confusing promotional
claims being made. When making claims about the environmental sustainability of these and similar products,
companies should base them on a publicly available, full life-cycle assessment.

8

INGREDIENT DISCLOSURE AND LABELING
Many companies making ingredients derived from genetic engineering, including for plant or animal replacement products, are not clear with the public about the manufacturing techniques that they use, nor are theyrequired to be.
Impossible Foods initially claimed that its “heme” protein from engineered yeast was “identical to”31 thatwhich the company is trying to emulate from animals, but this does not match the official documentationon the biochemical structures provided to the FDA. In fact, documents obtained from the FDA showed that
Impossible Burger inadvertently contains 46 additional engineered proteins. It is not clear how they will or
will not be disclosed on the label. 32 Processing aids, including those that are genetically engineered, are notrequired to be disclosed on the ingredient label.

4. Environmental Sustainability
Second-generation, lab-created animal replacement products have entered the market before being demonstrated to be safe, affordable, and sustainable solutions to food animal production challenges. Overall life-cycle analyses of the various animal protein replacement products in development or on the market have notbeen done. We do not yet understand the net resource use or the impacts of manufacturing these novel foodproducts, especially at scale.

RESOURCE AND WASTE IMPLICATIONS
Making genetically engineered animal replacement products and lab meat involves complex manufacturing
and processing. Unfortunately, while proponents claim that these methods may use fewer resources or may
be sustainable, the resource inputs for genetically engineered animal replacement products and lab meat
have not been fully evaluated. These resources include the energy, water, fossil fuels, chemicals, plastics andfeedstocks used to manufacture the 15-20 ingredients33, 34, 35 that commonly make up these products. Before
claims of sustainability can be corroborated, waste production also needs to be assessed, including greenhouse gas emissions, water, plastic and nutrient management, along with disposal of genetically engineeredorganisms and the materials used in the process.
One study in 2015 suggested that while lab meat might end up using fewer agricultural inputs and land thanlivestock, the overall energy consumed to produce lab-grown meat might be equivalent to or more than thatused to produce animal-derived meats.36

FEEDSTOCK IMPLICATIONS
One hidden environmental cost to these second-generation protein foods is the feedstocks required to produce them; these include sugarcane, corn and natural gas. Although the industry is in its infancy, the envisioned “synthetic bio-economy,”37 once at scale, would require expanding production of these feedstocks,

9

largely produced through environmentally devastating, chemical-intensive industrial monocultures, as with
GMO corn or sugar, or with natural gas (which is produced with techniques like hydraulic fracturing or “fracking”). As an example, increasing demand for sugarcane could exacerbate the current destruction of criticalsavannah and rain forest ecosystems in Africa, Southeast Asia and Latin America (including some of Brazil’s
most eco-sensitive areas of land).38,39 Industrial feedstock production requires large amounts of synthetic fertilizers (which pollute the water and the air), as well as toxic pesticides and herbicides, such as chlorpyrifos,
glyphosate and atrazine, 40, 41, 42 which are linked to cancer and associated with developmental and reproductive harm.

CONTAMINATION QUESTIONSGenetically engineered yeast, algae and bacteria are manufactured in incubating vats; given the prolific nature of these organisms, complete containment is difficult, if not impossible. Due to their microscopic size,organisms like microalgae will inevitably escape from any industrial cultivation facility — and potentiallybecome air­borne or spread via water.43 Because such organisms reproduce (and some can cross breed withrelated organisms or even, in the case of microbes, “swap genes” with unrelated species through horizontal
gene transfer)44 the escape of genetically engineered organisms could have negative ecological consequences. These include genetic contamination of wild species and disruption of natural ecosystems.45

5. Consumer Data
Market data shows that 68 percent of consumers want to know where their food comes from and how it isproduced.46 Consumer polls show that 57 percent of consumers do not want to eat genetically engineered
food,47 and that approximately 95 percent of consumers agree that GMO food should be labeled as such.48 As
the demand for “natural” food increases, survey data indicates that many consumers assume the designationof “natural” to mean that no artificial or genetically engineered substances are among the ingredients.49
Additional surveys record that 88 percent of Americans support mandatory labeling of foods containing
GMOs, and 91 percent agree with the statement that people have the right to know if they are purchasing or
eating food and products containing GMOs.50 Currently, the government does not require GMO ingredients tobe labeled as such, nor does it require disclosure of genetically engineered processing aids.

6. Comparison to Demonstrated Benefit from Sustainable Cropand Animal Farm Practices
Determination of safety or any potential benefits of these products should include analyses of the impact onhuman health and the environment (full lifecycle assessment). Analyses should also consider consumer expectations of sustainable products, including ingredients and claims. Those parameters should be measured
against animal replacement products that are truly plant-based, and products from animals raised throughregenerative, high-welfare farming practices.
Evidence demonstrates that eating less and better meat and eating more truly plant-based products produced with organic and regenerative farming practices has many health, animal welfare and environmental
benefits.
Nutrition from whole plants (such as legumes and other protein-rich plants) produced through ecologicalfarming practices do not carry any of the risks associated with genetically engineered or other lab-produced
proteins; 51 therefore, they should be considered the preferred alternative to animal products resulting fromunsustainable, inhumane52 and destructive factory-farmed methods. In addition, innovative animal farming
practices, such as well-managed, high-welfare pasture-based systems, fit within a regenerative, humane,10just and ecologically sustainable food production model and have well-documented environmental, animal
welfare, economic, social and public health benefits that consumers are already demanding.53 For example,
studies have shown that organic and pasture-based methods of production result in cleaner water,54 promotehealthier soils that can sequester more carbon,55,56 release fewer toxins and improve biodiversity57 and pollinator habitat.58

Conclusion

Second-generation, lab-created animal protein replacement products are not yet proven to be safe or sustainable by regulators or via transparent, independent third-party assessments. Rather, there are increasing
concerns and questions that remain unanswered, and existing analyses show that these products may beproblems masquerading as solutions.
New food ingredients, especially those derived from emerging technologies, should be required to be assessed for safety before being allowed to be used in food or going to market. Safety concerns have alreadybeen raised regarding these products, which are not considerations for plant and animal-based foods produced through regenerative organic farming.59 Whether these new lab-created animal replacement products
will be widely accepted by an increasingly discerning public that demands “real” food, along with transparency and sustainability in the food system, remains to be seen.
Companies making animal replacement products using genetic engineering and in vitro processes are making
a range of claims to position their products as more sustainable than their animal product counterparts. Ifhighly processed engineered foods, manufactured in laboratories with new, unassessed food ingredients andprocesses are going to replace even some of the existing animal protein from farm-based systems, then thesenovel food ingredients need to be carefully vetted. We recognize and applaud those looking for ways to shift
away from unsustainable and inhumane factory farming, but we must carefully evaluate the benefits, andidentify and mitigate the costs and inadvertent consequences, of alternatives. The true cost of second-generation animal replacement proteins has not been fully assessed, but should be before these products enter themarket and our food supply at scale.

FOR MORE INFORMATION SEE:••

GMOs 2.0: Synthetic biology https://foe.org/projects/synthetic-biology/
Challenging factory farming and shifting diets https://foe.org/projects/animal-agriculture/1

Marston, J. (2018). Lab Grown Meat Just Got Another Shot of Investment. The Spoon. Retrieved May 22, 		
2018, from https://thespoon.tech/lab-grown-meat-just-got-another-shot-of-investment/

2

Plant Based Foods Association. Nielson Retail Sales Data for Plant Based Foods. Retrieved May 22, 2018, 		
from Plant basedfoods.org

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3

Drovers. (2018). Do-Good Meat: Are Investors Only After Their Pound of Flesh? Retrieved May 22, 2018, 		
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Sorvino, C. (2018). Tyson Invests In Lab-Grown Protein Startup Memphis Meats, Joining Bill Gates 			
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Loizos, C. (2017). Impossible Foods just Raised 75 Million for Its Plant based Burgers.
TechCrunch. Retrieved May 22, 2018, from https://techcrunch.com/2017/08/01/impossible-foodsjustraised-75-million-for-its-plant-based-burgers/

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Mandelbaum, R. (2017). Gizmodo. Behind the Hype of ‘Lab-Grown’ Meat. Retrieved May 22, 2018,from https://gizmodo.com/behind-the-hype-of-lab-grown-meat-1797383294

7

Swartz, E. (2017). The Science Behind Lab-Grown Meat. Retrieved May 22, 2018, from http://elliotswartz.
squarespace.com/science-related/invitromeat

8Open Philanthropy Project (2015). Animal Product Alternatives. Retrieved May 22, 2018, fromhttp://www.openphilanthropy.org/research/cause-reports/animal-productalternatives#
footnoteref99_9db9z59

9Perls, D. (2017). Is ‘Food-Tech’ the Future of Food? Medium. Retrieved May 22, 2018, from https://
medium.com/@foe_us/is-food-tech-the-future-of-food-49bd414cfb8b10

Perfect Day (2016). Retrieved May 22, 2018, from http://www.perfectdayfoods.com/

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Kowitt, B. (2016). This Startup Wants to Make Cow’s Milk – Without Cows. Fortune. Retrieved May
22, 2018, from http://fortune.com/2016/08/31/animal-free-cows-milk-perfect-day/

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Buhr, S. (2015). Clara Foods Cooks Up $1.7 Million In Funding To Make Egg Whites From Yeast
Instead Of Chickens. Tech Crunch. Retrieved May 22, 2018, from https://techcrunch.com/2015/07/09/
clara-foods-cooks-up-1-7-million-in-funding-to-make-egg-whites-from-yeast-instead-of-chickens/13

Mandelbaum, R.F. (2017). Behind the Hype of ‘Lab-Grown’ Meat. Gizmodo. Retrieved May 22,
2018, from https://gizmodo.com/behind-the-hype-of-lab-grown-meat-1797383294

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FOIA documents retrieved May 22, 2018, from https://1bps6437gg8c169i0y1drtgzwpengine.
netdna-ssl.com/wp-content/uploads/2017/08/072717_Impossible_Burger_FOIA_documents.pdf

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IEA Bioenergy: Task 39. (2017). State of technology review – Algae bioenergy: An IEA Bioenergy
Inter-Task Strategic Project. Retrieved May 22, 2018, from http://www.ieabioenergy.com/wpcontent/
uploads/2017/02/IEA-Bioenergy-Algae-report-update-Final-template-20170131.pdf

16

National Academies of Sciences, Engineering, and Medicine (2017). Genetically engineered crops:
experiences and prospects. National Academies Press. Retrieved May 22, 2018, from https://www.nap.edu/read/23395/chapter/3

17

Wolt, J.D., Wang, K., Sashital, D., Lawrence-Dill, C.J. (November 2016) Achieving Plant CRISPR
Targeting that Limits Off-Target Effects. Plant Genome, 9(3). Retrieved May 22, 2018, from https://www.ncbi.nlm.nih.gov/pubmed/27902801

12

18

Federation of American Scientists (2011). Risks Associated with GM Farm Animals. Retrieved May
22, 2018, from http://fas.org/biosecurity/education/dualuse-agriculture/2.-agriculturalbiotechnology/
risks-associated-with-gm-farm-animals. html

19

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20 Quinn, E., Young, C. (2015). The Center for Public Integrity. Why the FDA doesn’t really know
what’s in your food. Retrieved May 22, 2018, from https://www.publicintegrity.org/2015/04/14/17112/
why-fda-doesnt-really-know-whats-your-food
21

Morgan Lewis (May 2017). Lawsuit Challenges GRAS Rule on Food Substance Safety. Retrieved
May 22, 2018, from https://www.morganlewis.com/pubs/lawsuit-challenges-gras-rule-on-foodsubstancesafety

22 Interlandi, J. (August 2016). Consumer Reports. GRAS: The Hidden Substances in Your Food.
Retrieved May 22, 2018, from https://www.consumerreports.org/food-safety/gras-hiddeningredientsin-your-food/
23 FOIA documents retrieved May 22, 2018, from https://1bps6437gg8c169i0y1drtgzwpengine.
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25 Ibid.
26 Ibid.
27 Retrieved May 22, 2018, from http://www.perfectdayfoods.com/
28 Retrieved May 22, 2018, from http://www.clarafoods.com/media/#learnmore
29 Impossible Foods (2017). Sustainability is Our Main Ingredient. Retrieved May 22, 2018, from https://im		
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30 Retrieved May 22, 2018, from http://www.clarafoods.com
31

Retrieved May 22, 2018, from https://www.impossiblefoods.com/faq/

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33 Beyond Meat. Ingredients. Retrieved May 22, 2018, from http://beyondmeat.com/products/view/
beyond-burger
34 Tofurky. Ingredients. Retrieved May 22, 2018, from http://www.tofurky.com/what-we-make/delislices/peppered/13

35 Lightlife. Ingredients. Retrieved May 22, 2018, from http://lightlife.com/products/smart-bacon
36 Mattick, C. (2015). Anticipatory Life Cycle Analysis of In Vitro Biomass Cultivation for Cultured
Meat Production in the United States. Environmental, Science and Technology, 49 (19), 11941–11949.
Retrieved May 22, 2018, from https://pubs.acs.org/doi/10.1021/acs.est.5b01614
37 ETC Group. Synthetic Biology: The Bioeconomy of Landlessness and Hunger. Retrieved May 22,
2018, from http://www.etcgroup.org/content/synthetic-biology-bioeconomy-landlessness-andhunger
38 World Wildlife Fund. Sugarcane. Retrieved May 22, 2018, from http://www.worldwildlife.org/
industries/sugarcane
39 Mendonca, M. L. (2009). Brazil: Sugar cane plantations devastate vital Cerrado region. Pacific
Ecologist, (17), 25-28.
40 Health Care Without Harm. Environmental Nutrition; Redefining Healthy Food in the Health Care
Sector. Retrieved May 22, 2018, from https://noharm-uscanada.org/sites/default/files/documentsfiles/
2819/Environmental_Nutrition_HCWH_September_2014.pdf
41

E. D. Perry et al. (2016). Genetically engineered crops and pesticide use in U.S. maize and soybeans. Sci		
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42 Pesticide Action Network. Chlorpyrifos. Retrieved May 22, 2018, from http://www.panna.org/
resources/chlorpyrifos-facts
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