Study of Electronic or Digital Link Disclosure

A Third-Party Evaluation of Challenges Impacting Access to Bioengineered Food Disclosure

July 2017

Contents

Executive Summary 04

Understanding the Law 06

The Study 08

Current Landscape 10

Methodology: Human-Centered Design & Crowdsourcing 22

The Reality: Understanding Digital Engagement with Consumers 34

Looking Ahead: Implementing the Law 64

Conclusion 70

References 72

Blue arrows throughout this report indicate factors outlined in the Law 

that this study must consider in its assessment of consumer access to 

the bioengineering disclosure through electronic or digital links.
04 Study of Electronic or Digital Link Disclosure

Executive Summary

04 Study of Electronic or Digital Link Disclosure

In compliance with the National Bioengineered Food 

Disclosure Standard (“the Law”), this study identifies 

potential challenges associated with accessing a 

bioengineering disclosure through an electronic or 

digital link. This study analyzes data from over 150 

observations or in-depth discussions and nearly 

1,000 crowdsourced participants across the country. 

All participants in this study were interested in 

accessing information on bioengineered food.

Across the country, 53 percent of adults say they 

care about the issue of bioengineered food, and a 

third of that group cares a great deal.1 In addition, 

half of all shoppers would likely be sensitive to 

labeling changes, as evidenced by increased 

consumer desire for food information in recent 

years.2 These behaviors are pervasive across region, 

age, income, and gender.1,2

Overall, 62 percent of study respondents did not 

voice challenges that might impact their access 

to information in a digital link. However, in direct 

observations of consumers who are interested in 

accessing the disclosure, researchers observed key 

technological challenges that prevented nearly all 

participants from obtaining the information through 

electronic or digital disclosure methods. Despite this 

finding, these challenges can be overcome through 

appropriate implementation of the Law.

The following are technological challenges that 

may impact consumer access to a bioengineering 

disclosure through electronic or digital links:

 Digital links are not inherently associated 

with additional food information, and 

consumers often assume they are for 

marketing and industry use.

Of 40 in-depth conversations with consumers, all 

40 either did not recognize the on-package digital 

link or did not associate it with food information. 

Retailers were also unfamiliar with digital links and 

thus were unable to assist consumers.

 Consumers may not have equipment 

capable of scanning digital links on their 

own, and in most cases there is not a viable 

alternative provided by retailers.

Twelve percent of interested consumers faced 

challenges accessing equipment capable of 

scanning digital links such as smartphones. Of 42 

retailers visited across the country, none provided 

scanners capable of accessing information in a 

digital link. Moreover, research demonstrates that 

landlines do not currently provide an equivalent 

means of accessing the disclosure.

 There are hundreds of scanning apps 

available in the market, many of which 

are not intuitive to use, causing consumer 

confusion and difficulty opening link results. 

In direct observations, 85 percent of consumers 

struggled with complicated mobile software 

applications (“apps”), regardless of their comfort 

using technology. This is partly due to wide variability 

in apps available. In addition, most apps contain 

advertisements that confuse consumers and run 

counter to how the Law requires disclosure when 

regulations are finalized and implemented.

 Consumers may be unable to connect to 

broadband, or connect at a speed that is so 

slow that they cannot load information.

Sixteen percent of consumers in crowdsourced 

discussions voiced challenges related to availability 

or quality of data or WiFi networks. While food retail 

stores are increasingly installing WiFi networks, 20 

percent of retail stores do not currently have instore WiFi, including 63 percent of small retailers.3
0505

In addition to potential technological challenges, 

a number of contributing factors may challenge 

consumers who are uncomfortable using 

technology or do not fully understand the 

complexity of bioengineering disclosures. This 

includes a lack of familiarity with scanning a link, 

limited technical knowledge on how to download or 

use a scanner app, and confusion around voluntary 

bioengineering disclosure language currently in use.

As outlined in the Law, this study considers whether 

consumer access to the bioengineering disclosure 

through electronic or digital disclosure methods is 

affected by the following factors:

 The availability of wireless Internet 

or cellular networks. Increasing availability 

of broadband networks will expand access, 

particularly, although not exclusively, in rural 

regions of the country.

 The availability of landline telephones in 

stores. Landlines are universally available in store. 

However, they do not provide a viable means of 

accessing the digital disclosure due to limited 

availability of such phones for consumer use and 

restricted manufacturer call center hours.

 Challenges facing small retailers and rural 

retailers. Rural retailers are less likely to have 

broadband access, and small retailers will struggle 

to make costly investments in WiFi networks. As 

a result, consumers who shop at these stores will 

face difficulties accessing digital disclosures.

 The efforts that retailers and other entities 

have taken to address potential technology 

and infrastructure challenges. Retailer efforts 

to expand WiFi networks will significantly impact 

consumer ability to access the bioengineering 

disclosure for consumers with personal devices 

capable of scanning. However, in-store scanners 

needed to access digital disclosure links are not 

widely available for consumer use.

 The costs and benefits of installing in retail 

stores electronic or digital link scanners 

or other evolving technology that provide 

bioengineering disclosure information. 

While scanners are modest in cost, in most cases 

they must link to WiFi, requiring installation of 

networks in stores. This may prove cost prohibitive, 

particularly for small and rural retailers. In addition, 

there are limited benefits due to limited consumer 

knowledge around digital disclosure today.

This study identifies meaningful steps that 

government and interested parties can take to 

improve access for consumers facing challenges: 

1. Education for consumers and retailers 

around electronic and digital disclosure links 

and bioengineered foods will improve access 

and understanding.

2. Offline options, such as those that provide 

the bioengineering disclosure through 

phone or text message, will increase access 

for consumers who lack smartphones or 

broadband access.

3. Developing or endorsing user-friendly 

scanner apps will ease the consumer 

experience.

Electronic and digital link technology will continue 

to change and evolve, resulting in shifting retailer 

and consumer adoption. Thoughtful action can help 

to make sure that consumers are able to use such 

methods to effectively access food information.
06 Study of Electronic or Digital Link Disclosure

Understanding the Law

The National Bioengineered Food Disclosure Standard mandates that 

food manufacturers disclose if food is bioengineered

The National Bioengineered Food Disclosure 

Standard was signed into law on July 29, 2016 

The Law requires that the United States 

Department of Agriculture (USDA) establish a 

national mandatory bioengineered food disclosure 

standard for any bioengineered food and any food 

that may be bioengineered, and set requirements 

and procedures to carry out the standard by July 

29, 2018. The Law preempts any state or local 

requirement relating to the labeling of whether 

a food or seed is genetically engineered or was 

developed or produced using genetic engineering. 

The Law allows for three disclosure options

Food manufacturers may select whether the 

bioengineering disclosure is in text, a symbol, or 

an electronic or digital link. Internet URLs that are 

not embedded in the link are not a valid option of 

electronic or digital disclosure, except for small food 

manufacturers.

The Law mandates a study be conducted on 

challenges using electronic or digital links 

Within a year of enactment, a study must be 

conducted to identify potential technological 

challenges that may impact whether consumers 

would have access to the bioengineering disclosure 

through electronic or digital disclosure methods. 

If the Secretary determines in this study that 

consumers will not have sufficient access, he 

shall provide additional disclosure options in 

consultation with retailers.

This document complies with the mandate. 

The Law applies to bioengineered foods

A bioengineered food disclosure is only required 

for food intended for human consumption. Meat, 

poultry, and egg products only require a disclosure 

under limited scenarios. Bioengineered food refers 

to food that contains genetic material that has 

been modified through in vitro recombinant DNA 

techniques to engineer organisms for desired traits 

for which the modification could not otherwise be 

obtained through conventional breeding or found 

in nature. 

USDA is required to determine the amount of a 

bioengineered substance that may be present in 

order for the food to be considered bioengineered. 

USDA must also establish a process for requesting 

an agency determination regarding the additional 

factors and conditions under which foods would be 

considered bioengineered.

When discussing bioengineered foods, researchers, 

scientists, and the general public commonly use 

the terms genetically modified organisms (GMOs), 

genetically modified (GM) foods, or genetically 

engineered (GE) foods interchangeably, though 

these terms may refer to different breeding 

processes.
07

The Law grants exclusions to disclosure

Certain foods will not be subject to the 

bioengineered food disclosure standard.

▪ Foods derived from animals will not be considered 

bioengineered solely because the animal 

consumed bioengineered feed

▪ Foods served in restaurants or other similar retail 

food establishments are excluded

▪ Foods sold by very small manufacturers — a term 

to be defined by USDA — are excluded

Bioengineered foods are neither more nor less 

safe than non-bioengineered alternatives

The Senate Agriculture Committee says that, “The 

comprehensive federal regulatory review process 

has determined that foods produced using 

bioengineering are safe and not materially different 

in any way from those made using other methods.”

Additional disclosure options exist for small 

food packages and small food manufacturers

The Law requires USDA to provide alternative 

reasonable disclosure options for food contained 

in small or very small packages. For small food 

manufacturers, the Law stipulates that USDA must 

provide additional on-package disclosure options 

that can be selected by the manufacturer, including: 

▪ A telephone number with language indicating that 

it provides access to additional information

▪ An Internet URL maintained by the manufacturer

This implementation date will not be earlier than 

one year after implementation of the regulations.

Special regulations exist for manufacturers 

who choose to use electronic or digital links

If the food manufacturer chooses the electronic or 

digital link option for disclosure, that link must: 

▪ Include on-package language stating only ‘Scan 

here for more food information,’ or equivalent 

language reflecting changes in the technology

▪ Provide access to the disclosure located in a 

consistent and conspicuous manner on the 

first product information page that appears, 

which shall exclude marketing and promotional 

information

▪ Not collect, analyze, or sell personally identifiable 

information about consumers or their devices 

unless necessary to carry out the Law, in which 

case it should be deleted immediately after use 

and not used for other purposes

▪ Include a telephone number that provides access 

to the disclosure

▪ Be of sufficient size to be easily and effectively 

scanned or read by a digital device
08 Study of Electronic or Digital Link Disclosure

The Study

This study is focused on understanding if consumers can access the 

bioengineering disclosure through the electronic or digital link option

What is an electronic or digital link?

Electronic or digital links are codes that 

consumers can scan to access more 

information. Currently, those links require 

the use of a laser scanner or smartphone 

camera. If the content is stored on an 

external site, the scanning tool would 

require broadband access to connect to 

information. 

The most common electronic or digital links 

are one and two dimensional codes, such as 

barcodes and Quick Response (QR) codes. 

However, as technology evolves, other types 

of codes or links are likely to gain traction. 

Already, companies are experimenting with 

other technologies, and rules concerning 

disclosure standards will need to remain 

relevant. 

This study explores potential challenges that 

may impact implementation 

The National Bioengineered Food Disclosure 

Standard requires that manufacturers inform 

consumers if a food is bioengineered. The 

disclosure must provide consumers information 

that informs them whether a food is produced 

with bioengineering. This study is one portion of 

that Law. 

This study is focused on understanding whether 

consumers who are interested in accessing 

information on the bioengineered status of 

their food can, in fact, access that information 

when it is provided only through an electronic 

or digital link. This study identifies the potential 

technological challenges that may impact access. 

This study considers five specific factors 

The Law identifies the following five factors that 

this study must address as it identifies challenges: 

▪ The availability of wireless Internet or cellular 

networks

▪ The availability of landline telephones in stores

▪ Challenges facing small and rural retailers

▪ The efforts that retailers and other entities 

have taken to address potential technology and 

infrastructure challenges

▪ The costs and benefits of installing in retail 

stores electronic or digital link scanners, 

or other evolving technology that provide 

bioengineering disclosure information
09

This study identifies potential 

challenges that may impact 

whether consumers can 

access the bioengineered food 

disclosure through electronic or 

digital links.
10 Study of Electronic or Digital Link Disclosure Study of Electronic or Digital Link Disclosure
11

IN THIS SECTION

A. Consumer Interest in Bioengineered Food

B. Electronic or Digital Link Technology Trends

C. Smartphone Ownership Among the US Population

D. Measuring Broadband Access

E. Retailer Infrastructure and Challenges

Current Landscape Key Takeaways

11

This section provides an overview of the opensourced information related to electronic or digital 

links, including the key trends impacting this type of 

disclosure. This research was used to assess the state 

of the industry and technology, identify geographic 

targets for ethnographic research, and uncover 

issues that may impact the feasibility of using an 

electronic or digital link.

3 53% of US adults say they care about the issue of 

bioengineered food

3 77% of Americans own a smartphone and 

ownership rates are trending upward

3 93.6% of Americans live in areas with sufficient 

broadband access to load a bioengineering 

disclosure through an electronic or digital link

3 Broadband access is currently lowest in rural 

areas and the Secretary of Agriculture has 

identified expansion of broadband networks in 

these regions as a priority

3 97% of regional chain stores and 100% of national 

chain stores provide WiFi in store, but only 37% of 

small retailers provide WiFi to consumers in store
12 Study of Electronic or Digital Link Disclosure

Current Landscape | Consumer Interest in Bioengineered Food

An increasing number of consumers express an interest in 

the issue of bioengineered foods and information access

Though many consumers care about the 

issue of bioengineered food, there is limited 

understanding of the issue 

According to the Pew Research Center, more 

than half of US adults care about the issue of 

bioengineered foods, with 16 percent saying they 

care a great deal and 37 percent saying they care 

some about the issue. At the same time, there is 

limited familiarity among the American public on 

bioengineered food. Overall, 71 percent have heard 

little to nothing about the issue.1

This limited familiarity may result in soft opinions 

that are more likely to change over time and be 

sensitive to question wording. With implementation 

of the Law, consumer attitudes may shift as 

information about bioengineered food becomes 

more readily available.

A number of indicators point to consumer 

interest in bioengineered foods

Limited familiarity and soft opinions make it difficult 

to measure consumer interest in the issue of 

bioengineered foods. However, there are some 

behaviors that may indicate greater interest.

First, frequent consumers of organic foods care 

a great deal about the issue of bioengineered 

foods, with 31 percent saying they care a great 

deal compared to just 6 percent of those who 

eat little organic foods. Second, those who are 

vegan or vegetarian are more likely to care about 

bioengineered foods, as 39 percent care a great 

deal compared to 14 percent of those who are not. 

Third, those with food allergies are slightly more 

inclined to care about bioengineered foods, as 22 

percent care a great deal compared with 14 percent 

of those with no allergies or food intolerances.1

Factors influencing consumer purchasing 

behaviors are shifting

A Deloitte study conducted in association with the 

Grocery Manufacturers Association and the Food 

Marketing Institute found recent shifts in consumer 

preferences and behaviors.2 Historically, customer 

purchasing patterns were influenced by price, taste, 

and convenience. While these are still important 

considerations for grocery shoppers, about half of 

all consumers now consider health and wellness, 

safety, social impact, experience, and transparency 

in their purchasing decisions. These shifts are 

pervasive across region, age, income, and gender.2 

While bioengineered foods are not more or less 

healthy or safe than any other food, a disclosure 

of such information relates directly to consumers’ 

desire for greater transparency.

53% of US adults say they care about the 

issue of bioengineered foods, with a 

third of this group caring a great deal1 26% of consumers look for a non-GMO 

label on the front of a food package2
13

This study focused on consumers who expressed an 

interest in knowing whether their food is bioengineered.
14 Study of Electronic or Digital Link Disclosure

Current Landscape | Electronic or Digital Link Technology Trends

ONE-DIMENSIONAL CODES (E.G., BARCODE)4

These early forms of laser technology were used 

to transfer product information to cash registers. 

Now, Universal Product Code (UPC) barcodes can 

be used with a handheld scanner or through a free, 

downloadable smartphone scanner application 

that uses a camera to connect with digital content.

One-dimensional codes are used by retailers for 

product pricing information, and are widely used by 

consumers for the same activity.

▪ Require smartphone and camera-based scanner 

application or access to an in-store scanner

▪ Content may require access to broadband

▪ Require proper scanning technique

TWO-DIMENSIONAL CODES (E.G., QR CODE)4

Two-dimensional codes can store more data 

than a one-dimensional code, including URL links, 

geographic coordinates, and text. Consumers can 

use handheld scanners or most smartphones 

with a free, downloadable scanner application and 

camera to connect to the linked information.

These codes were originally used solely by 

manufacturers, but now are commonly used 

by manufacturers and retailers for a variety of 

purposes including marketing and retail payments.

▪ Require smartphone and camera-based scanner 

application or access to an in-store scanner

▪ Content may require access to broadband

▪ Contingent upon store environment (e.g., good 

lighting)

Electronic or digital links enable consumers to 

access information through the use of a laser 

scanner or smartphone with a scanning app 

and functioning camera. Currently, the most 

common electronic or digital links are one- and 

two-dimensional codes, which may contain 

a limited amount of information themselves. 

There are several emerging technologies that 

may impact future means of disclosure. The 

variety of digital links may make it difficult for 

retailers to keep up with evolving scanning 

technologies due to the investment required.

CURRENT USE

POSSIBLE CHALLENGES TO STAKEHOLDERS

A number of electronic and digital links currently exist that will enable 

and challenge access in different ways 

Existing technology used by consumers in the market
15

DIGITAL WATERMARKING5

Digital watermarks are two-dimensional codes 

embedded within a product’s image, detectable by 

computers and digital devices but imperceptible 

by consumers. They are more accurate than other 

forms of two-dimensional codes and rely less on 

store features, such as good lighting.

Digital watermarks are currently used by retailers 

as a pricing tool that reduces the amount of time 

cashiers and customers spend checking out, but 

may be used for consumer marketing in the future.

▪ Requires smartphone and camera-based scanner 

application or access to an in-store scanner

▪ Requires access to broadband

▪ Imperceptibility may lead to consumers not 

knowing that there is a watermark to scan

▪ May require special printing capabilities by 

manufacturer due to layering technique

NEAR FIELD COMMUNICATION6

Near Field Communication (NFC) enables noncontact communication between two electronic 

devices when they detect each other nearby, using 

wireless communication methods like Bluetooth. 

NFC is mainly used by retailers to send consumers 

information straight to their smartphones using 

beacon technologies or as a form of mobile 

payment.

▪ Requires smartphone

▪ Requires a Bluetooth-enabled device

▪ Requires location services to be enabled

VISUAL RECOGNITION TECHNOLOGY7

Visual recognition technology matches an image 

captured through a camera to items collected 

in an image library or multiple sources of rich 

data, without requiring a code or marking. The 

information can be retrieved through a tablet, 

smartphone, or computer.

Visual recognition technology is being tested by 

marketers and retailers as a means of measuring 

customer engagement with advertisements and 

increasing sales.

▪ Requires smartphone and camera-based scanner 

application or access to an in-store scanner

▪ Requires access to broadband

▪ Imperceptibility may result in lack of consumer 

knowledge around visual recognition technology

▪ Updates to database may be slow when packaging 

is changed, leading to problems finding products 

Emerging technology used mainly by industry

Technologies largely used by retailers but may be 

adapted for consumer use in the future
16 Study of Electronic or Digital Link Disclosure

Current Landscape | Smartphone Ownership Among the US Population

QR codes and barcodes are the most 

common electronic or digital methods of 

communicating food information

Barcodes are mainly used for storing an item’s price 

given their limited storage space, while QR codes 

have a wide range of uses, from serving as electronic 

airline tickets to assisting with auto manufacturing 

inventory. In 2015, ScanLife reported that product 

information, videos, eCommerce, app downloads, 

and customer relationship management were the 

top contents found in QR codes.8 In addition, QR 

codes are the most common method of providing 

additional food information through digital links, 

including voluntary bioengineering disclosures. 

With this in mind, QR codes were the predominant 

disclosure method used in this study. 

QR codes offer a means of communicating 

more information than barcodes

QR codes were developed as an alternative to 

traditional barcodes to give grocery stores increased 

storage space for product information. The codes 

can hold nearly seven-thousand characters 

compared to the twenty characters held by 

traditional barcodes. To make QR codes easier to 

scan, its developers used a unique ratio of black and 

white areas on printed matter to distinguish it from 

surrounding objects and allow devices to scan from 

any angle.9

QR codes have varied usage on food products

Using QR codes to provide additional food 

information has not been a prevalent practice in 

the industry. They typically contain various forms 

of marketing, but with passage of the Law, groups 

have emerged to assist manufacturers in providing 

additional information to consumers. Given that 

the Law has been enacted but not implemented, 

once disclosure regulations are written, more 

manufacturers may opt-in to platforms that 

assist them in complying with the Law. One such 

platform is SmartLabelTM, developed by the Grocery 

Manufacturers Association as a digital landing page 

that hosts food information for consumer access. 

Emerging technologies may improve on 

consumer use of electronic and digital links

Emerging technologies improve on gaps in previous 

technologies to make scanning more seamless. 

For example, digital watermarks are read more 

accurately and rely less on store features (e.g., 

lighting) than other one- and two-dimensional 

codes. 

One- and two-dimensional codes are the most 

prevalent digital links in use today
17

Smartphones are the most common means of 

scanning electronic or digital links

Most consumers scan electronic or digital links using 

their personal smartphones. To access these links, 

consumers must download a “scanner” or “reader” 

application through their system’s application 

marketplace. For AndroidTM and iOSTM, the two 

smartphone market share leaders, this means 

choosing from an array of more than 200 and 300 

apps, respectively. For Windows® and Blackberry®, 

the options are more limited with over 90 and 150 

applications, respectively.10-13

Smartphones are increasingly adding scanning 

capabilities to newer versions of software

As newer versions of smartphones are developed, 

capabilities become streamlined or obsolete. In the 

case of digital link readers, some major technology 

players have announced that future releases will 

begin integrating a digital link scanning capability, 

namely for QR codes. Apple® announced that 

the newest iPhone® software will have digital link 

scanning integrated into their camera; GoogleTM 

will add the function to their Internet browser, 

ChromeTM.14,15 As a result, some consumers will have 

greater ease of access to QR codes in the future.

Smartphone ownership in the US has grown 

rapidly since its inception

In 1995, the first smartphone was released in the 

US market as a combination of a cell phone and 

personal device assistant, but had short-lived 

success. Technology has since developed and a 

modern smartphone has the combined capabilities 

of a cell phone and computer — with smartphones 

growing into seeming ubiquity since their 

introduction in the market. However, smartphone 

ownership is not universal: 18 percent of Americans 

still own non-smartphone cellphones, and five 

percent do not own a mobile phone at all.16

Smartphone ownership rates are increasing across the US16,17

77% 67% 42% 64%

of Americans owned a smartphone 

in 2016, a 9 percentage point 

increase compared to 2015

of Americans living in rural locations 

owned a smartphone in 2016, a 15 

percentage point increase compared 

to 2015

of Americans 65 and older owned 

a smartphone in 2016, up 12 

percentage points from 2015

of low-income American households 

(those earning less than $30,000 per 

year) owned a smartphone in 2016, 

a 12 percentage point increase in 

ownership from 2015

Most consumers access information in electronic or digital links using 

a smartphone, but there are disparities in ownership rates
18 Study of Electronic or Digital Link Disclosure

Current Landscape | Measuring Broadband Access

Broadband refers to high-speed connection to 

the Internet, via wireless or cellular networks

The Federal Communications Commission (FCC) 

describes advanced broadband service as access to 

25 megabits per second (Mbps) download speed. 

This standard represents the FCC’s threshold for 

consumer access to high-quality broadband service 

across multiple devices.18

Sufficient broadband service must be available 

to access a digital link 

While basic two-dimensional codes may store 

information within themselves, such as a picture 

or text, a two-dimensional code that connects to a 

web link requires sufficient broadband coverage. 

Consumers can access a digital link at speeds far 

below the 25 Mbps FCC standard. However, the 

larger or more complex the web link, the faster the 

broadband speed required. 

The research team analyzed FCC data to develop a 

spectrum of broadband speeds required for digital 

disclosure, as illustrated in Figure 1.19 The minimum 

scan requirement uses a download speed of at least 

1.6 Mbps. This is calculated by considering that a 

basic webpage has an average size of 400 kilobytes 

(kB) and consumers will only wait about two seconds 

for a webpage to load, which industry experts define 

as a user-friendly wait time.20,21 

Establishing a standard for consumer 

expectation is key in understanding access

Manufacturers may choose to use a more complex 

webpage to communicate the bioengineering 

disclosure. The average Internet URL is 2.6 

megabytes (MB) in size.22 Assuming consumers’ 

expectations remain constant, a minimum speed of 

10 Mbps is required to load an average webpage at 

a speed that meets consumer expectation.19

Rural areas lack sufficient broadband to meet 

consumer expectation for speed of access

To better capture the broadband needed to 

access a digital disclosure, this study developed a 

composite broadband coverage score. This score 

evaluated the availability and speed of service 

within each county of the United States. Mapping 

coverage across the US revealed counties which 

lack adequate broadband service — most of 

which are rural. The Interagency Task Force on 

Agriculture and Rural Prosperity, a new initiative 

chaired by the Secretary of Agriculture, aims to 

improve infrastructure in rural counties, potentially 

increasing access to advanced broadband service.23 

Digital disclosure methods typically require broadband access to 

connect to linked webpages 
19

Figure 1: Broadband Speeds Required to Access Digital Disclosure19

93.6%

percent of all Americans (299 million people) live 

in counties with sufficient access to broadband 

service to load a digital bioengineering disclosure. 

This is based on one’s ability to load an averagesized webpage within a consumer expectation time 

of two seconds or less.

Conversely, 20.5 million Americans do not have 

access to adequate broadband. Seventy-seven 

percent of those residents live in rural areas. 

0 Mbps

No Access Minimum Scan

Requirement 

Average Consumer

Expectation 

FCC Guideline

1.6 Mbps 10 Mbps 25 Mbps
20 Study of Electronic or Digital Link Disclosure

Current Landscape | Retailer Infrastructure and Challenges

Retailers are integral in providing consumers 

with a means of accessing an electronic or 

digital disclosure link

The Law requires a look at retailer efforts in 

addressing potential challenges. Retailers will need 

to be prepared to aid consumers in accessing 

bioengineering disclosures. Although consumers 

have the option to conduct research outside of the 

store, they may choose to access bioengineering 

disclosures within stores. Infrastructural 

accommodations, coupled with employee 

knowledge of digital disclosure, will enable retailers 

to provide consumers a means of accessing 

digital links. Without this support, a heavy burden 

will be placed on consumers who want to know 

information about the food they purchase.

In-store WiFi will help extend broadband 

networks in retail outlets

Broadband is key for digital disclosure. This involves 

the availability of WiFi for consumer use while in 

food retail stores. According to the Food Marketing 

Institute, 97 percent of regional chain stores and 

100 percent of national chain stores provide 

customers with WiFi. However, this number drops to 

37 percent when looking at independently operated 

food retail outlets nationwide.3

Current use of scanners in stores is primarily 

limited to one-dimensional links

As consumer trends evolve, retailers implement 

newer technologies to improve the customer 

experience and increase efficiencies. However, 

even with the latest developments such as selfcheckout and Near Field Communication for mobile 

payments, one-dimensional link scanners (e.g., 

barcode scanners at cash registers) are still the most 

prevalent form of scanners available in retailers. 

This presents a challenge in accessing electronic 

or digital disclosures, which are primarily available 

through two-dimensional links. This is particularly 

true among small and rural retailers, some of which 

manually input prices into cash registers and do not 

have any kind of scanner in store.

Several big retailers have begun piloting programs 

that entail consumer use of hand-held scanners 

while they shop in store. According to a 2015 

Nielsen study, ten percent of consumers in North 

America have used a hand held store scanner to 

purchase products as they shop.24 Walmart’s® Scan 

& Go pilot sites and Target’s® Cartless Shopping 

equip consumers with hand-held portable scanners. 

Depending on the software, these might be able to 

scan both one- and two-dimensional codes.

Food retailer efforts are underway to address potential challenges in 

accessing bioengineering disclosures through electronic or digital links

In a survey conducted by the Food Marketing 

Institute of food retailers across the country, 

stores universally reported having a phone 

available for managers to use. While these 

may not be available for direct consumer use, 

managers could use them to assist consumers 

should they have no other way of accessing 

the disclosure. Respondents include a variety 

of retailers, including regional and national 

chains, small and independent stores, and 

wholesalers.3

The Law requires a phone number 

be included with all electronic or 

digital disclosure links

The efforts that retailers and other 

entities have taken to address potential 

technology and infrastructure 

challenges. Retailer efforts to expand WiFi 

networks will significantly impact consumer 

ability to access the bioengineering disclosure 

for consumers with personal devices capable 

of scanning. However, scanners needed to 

access digital disclosure links are not widely 

available for consumer use.
21

Small and rural retailers have declining customer 

bases, resulting in less ability to capture profit for 

store investments 

Rural residents are increasingly choosing to shop at 

large grocery chains farther from home. This is due to a 

combination of out-commuting consumers — who work 

in different towns and prefer to shop wherever is most 

convenient — and an increase in the accessibility of roads 

and automobiles.

At the same time, the average population needed to 

maintain a food retail store is increasing. In 2005, the 

average population needed to maintain a grocery store was 

3,252, up from 2,843 in 2000.25 Combined with decreasing 

customer bases, this results in less profit and smaller 

returns for retailers. 

These challenges result in a situation in which smaller 

stores struggle to cater to changing consumer desires, 

which in turn creates a further decline of their customer 

base. In Iowa, between 1995 and 2005, the number of 

grocery stores dropped from 1,400 to 700; at the same 

time, supercenter stores like Walmart® and Target®

increased by 175 percent.25 In such a market, small retailers 

struggle in their ability to provide competitive prices, which 

83 percent of consumers noted as the most important 

factor when deciding where to shop.26

Small retailers have fewer opportunities to gain 

economies of scale

Providing WiFi for employees and customers offers 

an opportunity to expand access to digital disclosure. 

However, grocery retailers see very little return on 

investment from installing WiFi networks. These stores 

experience only a 5.8 percent increase in earnings before 

interest, taxes, and amortization compared to other 

retailers or restaurants, who see a 32.1 percent increase.27

As such, small and rural retailers are not incentivized to 

provide WiFi, meaning customers without broadband may 

find it challenging to access the disclosure.

Small and rural retailers are less likely to have access 

to WiFi in store

Compared to near universal coverage in national and 

regional chain stores, only 37 percent of independently 

operated food retail outlets provide WiFi in store.3 Such a 

difference is likely attributable to the difficulty small and 

rural retailers face in capturing profit for store investments 

and lessened opportunities to gain economies of scale.

Small and rural retailers struggle to make the 

infrastructure investments needed to help consumers 

access digital disclosure

Challenges facing small retailers and rural 

retailers. Rural retailers are less likely to have 

broadband access, and small retailers will struggle 

to make costly investments in WiFi networks. As a 

result, consumers who shop at these stores will face 

difficulties accessing digital disclosures.
22 Study of Electronic or Digital Link Disclosure Study of Electronic or Digital Link Disclosure
23

IN THIS SECTION

A. Rationale for a Hybrid Model

B. Focused Human-Centered Design

C. National Sample, Crowdsourced Discussion

Methodology:

Human-Centered Design 

& Crowdsourcing

23

Scope of Work

A multi-modal research approach, employing humancentered design (HCD) and crowdsourcing, allowed 

for inclusion of a diverse, purposeful sample of 

US consumers — those with and without digital 

access in dense and rural populations. Combining 

these methods allowed the research team to gain a 

depth and breadth of knowledge around challenges 

consumers face in accessing information through 

digital disclosure links.

3 994 consumers from across the country engaged 

in crowdsourced discussions

3 4 sites were selected for field research, including 

one in each Census region of the United States

3 More than 150 direct observations provided input 

for human-centered design

▪ 40 in-depth conversations were conducted 

with consumers interested in accessing 

information on the bioengineered status of 

their food

▪ More than 75 consumers were observed 

while grocery shopping

▪ 42 retailers were visited to determine 

broadband access, landline availability, and 

ability to assist with scanning electronic or 

digital links
24 Study of Electronic or Digital Link Disclosure

Methodology | Rationale for a Hybrid Model

This study was informed by a multi-modal 

research approach

Employing human-centered design and 

crowdsourcing allowed researchers to access a 

diverse and purposeful sample of US consumers. 

This multi-modal approach was necessary so that 

consumers, with and without digital access, had the 

opportunity to participate in this study.

Human-Centered Design (HCD) provides detailed 

understanding of consumer behaviors

Human-centered design (also known as design 

thinking) is a multi-disciplinary approach used by 

leading companies over the last decade. It draws from 

the practices of ethnography, cognitive psychology, 

and design to understand users’ experiences with 

a product or service. By taking the time to truly 

understand a user’s perspective and rationale, areas 

of concern can be identified and fixed to provide a 

better and more seamless experience for consumers.

As it relates to digital disclosure, HCD facilitates an 

understanding of behavioral, technological, and 

infrastructural challenges (both real and perceived) 

that may affect consumers’ access to information 

about bioengineered ingredients in their food. 

Unlike surveys that capture a snapshot of people’s 

opinions from a fixed set of questions or big data that 

reveals trends by layering hundreds of thousands 

of anonymized data points, human-centered 

design gathers rich participant-driven data through 

observation and open-ended questions. Such an 

approach merges data with an understanding of the 

social context of human lives, creating deeper, more 

meaningful insights.

There were more than 150 direct observations 

that provided input for human-centered design. 

This includes 40 in-depth participant discussions, 

42 retailer visits, and more than 75 observations of 

consumers in store. Sites were selected according 

to characteristics meant to pinpoint locations where 

consumers might face challenges in accessing a 

digital link. In addition, each participant was screened 

for potential interest in bioengineered foods. At-risk 

groups were identified based on secondary research 

on the current landscape, including age, broadband 

access, and technology ownership. 

After conducting field research and interviews, 

researchers synthesized data and developed insights 

and themes to inform this study.

Combining research methods enabled breadth and depth of 

consumer perspectives across the country
25

Crowdsourcing provides insights through rich 

data and social interaction

Crowdsourcing provides an effective channel to 

engage consumers in a productive online discussion 

that builds on the insights gathered from field 

research and validates findings. The crowd brought 

together different types of consumers from across 

the country to discuss their views on digital disclosure. 

Interactions between participants led to in-depth 

conversations on the topic, and provided more 

nuanced information on consumers’ views than would 

have been available through a traditional survey or 

poll.

Crowdsourcing consumer opinions involves 

monitoring the number of discussion threads, the 

diversity of respondents, and the engagement of 

different segments. This allows the research team to 

adjust the balance of participants as needed to elicit 

coverage of a breadth of perspectives.

Nearly 1,000 participants were identified and 

recruited for the crowd, each a consumer with a 

potential interest in bioengineered food. The group 

served as an illustrative sample of the US population, 

capturing a wide diversity in age, income, race, 

geographic location, and shopping habits. 

Once launched, the crowd conversation was 

monitored to track participation, and refined as 

needed. Data was collected, grouped according to 

consumer segments and conversations, and analyzed 

to gain insight and understanding on challenges to 

access and potential solutions.

A hybrid approach allowed for depth and 

breadth of insight into the consumer experience

By combining these two research approaches, this 

study was able to develop and support insights into 

different challenges that consumers experience when 

accessing digital disclosure. 

Crowdsourcing provided an illustrative sample of 

American consumer opinions, while HCD added 

a depth of understanding through observation. 

Through both research methods, participants 

engaged in robust conversations about digital 

disclosure regarding bioengineered food. Each 

approach gleaned different types of data points 

and themes. Ultimately, data from both approaches 

was analyzed and synthesized, informing the major 

insights derived in this study.
26 Study of Electronic or Digital Link Disclosure

Methodology | Focused Human-Centered Design

At the heart of human-centered design is field 

research, otherwise known as ethnography

Ethnographic research is a subset of anthropology 

that focuses on the study of human cultures 

through observation of people’s behaviors in their 

natural environments. Observation is a powerful tool 

for gathering insights since what people say and do 

are often two different things. Simply put, the goal is 

to understand how people behave in their everyday 

lives. To better understand consumer access to 

additional food information through electronic or 

digital disclosure methods, this study observed and 

engaged a variety of American consumers through 

open conversation and observation of shopping 

patterns.

Ethnographic research is centered on 

objectivity, empathy, and open dialogue

The first guiding principle employed in the field was 

an emphasis on objectivity. Researchers worked to 

capture observations and facilitate conversation 

in an unbiased manner. So as to reduce the risk 

of participant bias, researchers did not disclose 

the full scope of the study in conducting research. 

The second guiding principle for human-centered 

design was framing conversations in a comfortable 

and empathetic manner in order to facilitate 

open conversation. In addition, participants were 

informed of their rights and signed consent forms 

before conversations officially began. Finally, 

participant-guided dialogue is a key component 

of successful ethnographic research. To this end, 

researchers asked questions in an open-ended 

manner, inviting participants to elaborate on their 

responses with context or stories.

Field research sites were selected to identify 

populations that face potential challenges 

accessing digital disclosure

Engaging a meaningful research sample is critical 

in conducting unbiased, insightful field research. 

Preliminary insights based on secondary research 

identified groups of American consumers who 

may face unique barriers to accessing information 

through electronic or digital disclosure methods. 

These include vulnerable and underserved 

populations, such as low-income, rural, or tribal 

communities. To effectively and meaningfully engage 

these populations, the researchers sought to reach 

a diverse sample of consumers from four carefullyselected regions across the United States.

This study considered five key characteristics in 

its site selection process: (1) consumer interest 

in bioengineered foods, (2) access to participants 

likely to face challenges, (3), broadband access, (4) 

geographic diversity, and (5) demographic diversity.

Human-centered design applies observational techniques and 

discussion to understand the voice of the customer

26 Study of Electronic or Digital Link Disclosure
27

Five key characteristics guided the human-centered 

design site selection process

Interest in the issue of bioengineered foods

Researchers focused on engaging populations potentially interested in accessing information on the 

bioengineered status of food purchases.

Access to participants likely to face challenges

Researchers sought to include participants likely to face challenges accessing food information via 

electronic or digital disclosure methods. Based on secondary research, this includes groups that may 

not own smartphones and may have difficulty using technology.

Limited broadband access

Three of the four sites selected had low access to broadband, determined using a broadband access 

map of the US based on US Census Bureau and FCC broadband data by county. The map uses a 

broadband coverage score, a composite of broadband availability and speed.

Geographic diversity

Sites were selected from each of the four major US Census Bureau regions of the United States — 

Midwest, Northeast, South, and West — providing a diversity of behavior and thought.

Diverse demographics

A portion of study participants engaged were from racially and ethnically diverse communities, 

including Hispanic, African American, and tribal populations.

40in-depth 

participant 

discussions 75+consumer observations 42retailer 

locations 

visited
28 Study of Electronic or Digital Link Disclosure

Methodology | Focused Human-Centered Design

Figure 2: Limited Broadband Access Map for the United States, by County28

Ethnographic research targeted the six percent of Americans 

who live in regions of the country with limited broadband

No Access High Access

Continental US

Hawaii

Alaska

Southwest 

Tribal Region

Rocky Mountain 

Region Northeast 

Region

Appalachian 

Region

▪ 99.9% of counties have at least some access to broadband service

▪ Only four counties have no broadband access, all located in Alaska and comprising 

a population of less than 12,000 people

▪ 6.4% (20.5 million) of the American population has inadequate broadband service 

to successfully access digital disclosure, based on the 10 Mbps threshold

▪ These 20.5 million people with inadequate broadband live across 1,020 counties, 

88% of which are completely or mostly rural

Guam & US Virgin Islands

Arctic 

Region
29

The approach to site selection supported researchers in 

engaging key consumer groups

Using the guiding characteristics, broadband map, 

and US Census data, researchers selected four 

illustrative sites for field research. These included 

a site in a tribal region of the Southwest, rural 

Appalachia, rural Vermont, and a city in the Midwest. 

Many tribal communities in the US have 

demonstrated interest in the issue of bioengineered 

foods. In 2015, California’s largest tribe, the Yurok, 

banned the growing, raising, or release of GMOs 

within their territory. Many other tribes express 

similar concerns around the issue of bioengineered 

food, with Navajo Nation declaring itself GMO-free in 

2015.29,30 The Southwest tribal region includes these 

populations, and also faces challenges as a rural 

region with low broadband access. 

Appalachia is a region of the country with a rich 

agricultural influence. The importance of agriculture 

— the largest component of the regional economy 

— and a communal concern about food labeling 

made Appalachia an ideal target for research.31

Prior to passage of the Law, labeling efforts existed 

across a number of states. In the Northeast, 

Vermont was the first state to implement a

Figure 3: HCD Research Site Selection Factors

mandatory GMO labeling law and have it impact 

the marketplace. Rural communities were a major 

influence in pushing for this legislation, and some 

even held a “Right to Know” march, in favor of GMO 

labeling.32,33

In order to represent the voices of populations 

who may face challenges in accessing digital 

disclosure in an urban setting, researchers visited 

a Midwestern city. Like Appalachia, the Midwest 

is a key region for agricultural development in the 

US.34 Aside from being one the nation’s largest 

producers of dairy products, lead researchers in the 

field of bioengineered food hail from Midwestern 

universities; other researchers frequently travel to 

the region to perform studies.35 This area acts as 

a hub for a diverse population in a region that is 

influential in the field of bioengineered foods.

P OT EN T I AL I N T EREST I N T H E I SSU E OF G M O FOODS CONSUMER 

INTEREST

SITE 1 SITE 2 SITE 3 SITE 4

BROADBAND 

ACCESS LOW BROADBAND ACCESS (<10 MBPS) OTHER BARRIERS 

TO ACCESS

DEMOGRAPHICS TRIBAL RURAL

ACCESS TO 

HIGH-BARRIER 

PARTICIPANTS

 Smartphone and non-smartphone owners

 Access to low-income populations

 Access to study participants over the age of 60

SOUTHWEST 

T R I BAL R EG I ON APPALACHIA RURAL VERMONT MIDWESTERN CITY

LOCATION

SELECTION

GEOGRAPHY WEST SOUTH NORTHEAST MIDWEST

LOW-INCOME, 

DIVERSE
30 Study of Electronic or Digital Link Disclosure

Methodology | National Sample, Crowdsourced Discussion

Fostering meaningful conversations between 

diverse participants allowed researchers to 

develop crowd insights

In the context of this study, crowdsourced 

discussions provided the research team with 

data on participants’ thoughts around engaging 

with electronic and digital disclosure methods. 

In addition to gathering information on each 

participant, the crowd platform enabled individuals 

to interact with one another by responding to, 

and rating, each other’s comments. This created 

a robust dialogue that transformed traditionally 

qualitative feedback into a quantitative data set 

that articulated the key challenges individuals face 

when attempting to access digital information. It 

should be noted the focus of the discussion was on 

identifying challenges in compliance with the Law.

Participants were selected to determine 

challenges in accessing digital disclosure

This study engaged a broad and diverse population 

as a means of fostering dynamic discussion within 

the crowd platform. As in HCD, participants were 

selected based on the following characteristics:

▪ Interest in accessing information on 

bioengineered food

▪ Member of a group facing potential challenges, 

including low-income earners, rural residents, and 

members of Native American populations

All participants also had to have access to a 

technological device in order to participate, so it 

was assumed that underserved populations would 

be less represented through this research method 

and that those individuals would be better engaged 

through ethnographic research. In total, the crowd 

conversation included nearly 1,000 American 

consumers from around the country.

Consumers were broken into two groups 

to measure the impact of wording bias on 

responses around bioengineering disclosure

Research indicates that most consumers are 

unfamiliar with the GMO issue, and may have 

soft opinions that are sensitive to question 

wording. In order to account for this sensitivity, 

participants were broken into two separate 

crowd conversations. These crowds were highly 

similar in all aspects, except for a slight difference 

in question wording: the first group included a 

prompt that sought crowd thoughts around digital 

disclosure, and the second group included the 

same prompt with a reference to bioengineered 

or GMO foods. Upon a review of the results, there 

was no statistically significant difference between 

technological challenges referenced across the two 

groups and the results were consolidated into a 

single group for analysis.

All crowd participants engaged in the 

conversation through both direct feedback 

and social interaction

The crowd platform was structured to foster 

a dynamic discussion, where participants not 

only answered questions about their own views 

and behaviors, but reacted to one another’s. 

Participants were prompted with an initial, 

open-ended question where they provided 

thoughts around challenges they would face 

in using electronic or digital disclosure links. 

Next, participants rated comments from their 

peers based on how much they agreed with 

the comment and how much they cared about 

the issue discussed. Finally, crowd participants 

were able to reply to comments to continue the 

conversation with one another. This dynamic 

engagement created a dataset that fostered a 

networked sentiment analysis across participants 

by measuring the degree to which independent 

participants shared similar feelings around digital 

disclosure, and the extent to which those feelings 

were shared.

The crowd conversation provided insights at scale on the 

consumer experience in digital scanning
31

994

13,551

3,399

crowd participants who demonstrate potential 

interest in the issue of bioengineered foods, each 

providing an initial comment on challenges they 

would face accessing digital disclosure

ratings given, with consumers ranking how much 

they agreed with and cared about other comments 

(average of 13.6 ratings per comment)

written responses to comments

CLEAR RATINGS

RICH DISCUSSION

BROAD REACH
32 Study of Electronic or Digital Link Disclosure

Methodology | National Sample, Crowdsourced Discussion

Through interaction, the crowd coalesced into large 

groups with similar and overlapping concerns

Crowd interactions pointed to common 

concerns among consumers

Through the crowd platform, participants 

read, rated, and reacted to other opinions and 

comments. The exposure between various 

perspectives allowed the research team to learn 

more about each participant’s sentiments than 

the information they originally included in their 

comment. Researchers measured the level of 

agreement between each of the participants to 

identify groups with similar opinions on digital 

disclosure. This enabled the development 

of a network map to visualize the natural 

“conversations” that developed between crowd 

participants. 

The research team identified key challenges and 

behaviors mentioned by the crowd participants 

in their comments. The crowdsourced discussion 

helped identify the demographic groups most likely 

to be concerned about each of the challenges. 

Furthermore, the interactions in the crowd allowed 

the identification of commonalities between 

different concerns. Crowd participants rated 

comments on two parameters: (1) how much they 

agreed or disagreed with the comment and (2) how 

important they thought the comment to be. The 

research team was able to extrapolate additional 

perspectives from each participant based on the 

other comments with which they highly agreed.

32 Study of Electronic or Digital Link Disclosure
33

Participant

Each dot represents a comment from a crowd 

participant. Only the comments considered 

highly important by at least one other person 

are included.

How to read the network map:

Levels of Agreement

The distance between two comments, or 

the length of the arrow, indicates the level of 

agreement. The higher the level of agreement, 

the shorter the distance between two dots. 

In general, the closer two comments are to 

each other, the more the crowd participants 

shared common viewpoints.

Interaction

Each arrow represents a rating given from 

one participant to another, with an arrow 

pointing to the comment that was rated. Only 

the strongest ratings, where participants 

highly agreed with the comments and thought 

they were important perspectives, are shown.

Lower level

of agreement

Higher level

of agreement
34 Study of Electronic or Digital Link Disclosure Study of Electronic or Digital Link Disclosure
35

The Reality: 

Understanding Digital 

Engagement with 

Consumers

Key Takeaways

35

Currently, low awareness of digital links results in 

low recognition of their use for food information. 

As consumers attempt to access bioengineering 

disclosures through electronic or digital methods, 

some face key challenges. These challenges include 

difficulties recognizing the link, accessing it through 

use of tools, scanning the link appropriately, and 

loading the webpage to view information, among 

others.

IN THIS SECTION

A. The Consumer Journey

B. Technological Challenges

C. Contributing Factors

3 62% of interested consumers believe they would 

be able to access an electronic or digital food 

disclosure

3 Among the population included in this study, 

consumers face four primary technological 

challenges in using electronic or digital links:

▪ Digital links are not inherently associated 

with additional food information

▪ Consumers may not have access to 

equipment capable of scanning digital links

▪ The market provides hundreds of scanning 

apps, many of which are not intuitive to use

▪ Consumers may be unable to connect to 

broadband

3 Technological challenges disproportionately 

impact low-income earners, rural residents, and 

Americans over the age of 65

3 Consumers who are uncomfortable using 

technology or unfamiliar with the issue of 

bioengineered foods have additional contributing 

factors that may challenge access
36 Study of Electronic or Digital Link Disclosure

= 10 crowd respondents

The Reality | Consumer Journey

62 percent

of crowd respondents did not comment 

on challenges that might affect access to 

information included in a digital link

When asked, most interested consumers believe that they 

would be able to use an electronic or digital link to access a 

bioengineering disclosure 

Through crowdsourced conversations, nearly 

1,000 consumers provided insight into their 

grocery shopping behaviors and potential 

challenges in accessing the bioengineering 

disclosure through an electronic or digital 

method.

The majority of crowd participants did not comment 

on challenges when asked about electronic or digital 

disclosure methods. Many in this group explicitly noted 

a lack of barriers, indicating that those with ready 

access to technology typically did not see technological 

challenges. Other respondents that did not comment 

on challenges shared positive feelings towards the 

idea of scanning food products for more information. 

Still others offered additional thoughts related to 

implementation of the law or regarding consumer 

behaviors that are unrelated to challenges associated 

with scanning.
37

Yet, in observations, some consumers faced 

challenges that impeded access to disclosure

Consumers may not initially remark on challenges in accessing a 

bioengineering disclosure through electronic or digital methods. However, 

observations of the ways in which people scan point to key impediments 

in their ability to access information through such links. Even those 

comfortable using technology faced challenges in scanning. Put simply, 

consumers may not know the challenges they face in accessing 

digital disclosure until they actually try to access it.

The following pages outline a consumer journey, the steps a consumer 

must take to access information through an electronic or digital disclosure 

method. Throughout the consumer journey, technological challenges and 

contributing factors may impede consumers along the way. Technological 

challenges directly impact whether a consumer would have access to the 

bioengineering disclosure through an electronic or digital link. Contributing 

factors are issues that can inhibit adoption of or engagement with digital 

disclosure.
38 Study of Electronic or Digital Link Disclosure

The Reality | Consumer Journey

Most consumers were equally concerned with a range of topics, 

pointing to relationships between different challenges

Interconnected consumer networks 

reflect a variety of overlapping concerns

The graphic to the right connects participants 

to comments that they most strongly 

agreed with to identify the most common 

perspectives. Each color represents a group 

with a similar reaction to digital disclosure. 

The groups identified here allowed the 

research team to link together challenges 

and behaviors based on common concerns 

to identify root causes and develop more 

effective mitigation strategies.

The research team found that most groups 

discussed a variety of topics around a central 

theme. For example, participants that stated 

they did not know how to use a scanner app 

tended to highly agree with participants that 

stated they did not have a phone capable 

of reading electronic or digital disclosure 

links, indicating that groups with these kinds 

of barriers may have many members in 

common.

Figure 4: Crowd Network Map
39

I would use this scannable technology 

if it was available to me, I am not aware 

of it in the grocery store where I shop. 

If a smartphone is needed then I would 

have a problem with product labeling 

and information, because I do not have 

any of these devices.

– Crowd participant

I really do not know much about the 

technology involved with QR codes and 

scanning.

– Crowd participant

Sometimes the signal for my cell phone 

in the store gets very weak. I have 

mentioned it to the store manager 

who said they would look into it. They 

currently have a scanning system for 

reduced pricing but I am unable to use 

it because of the above mentioned.

– Crowd participant

Crowd Conversation Categories

Conversations focused on scanning

Equally concerned with a wide range of topics

Inexperience with digital links and security concerns

Concerned with abilities to scan, prefer a physical label

Interested in scanning, dependent on time constraints

Conversations focused on tools

Worried about not having the tools needed to access 

the scan, including data service, smartphones, and an app

Concerned phones will not be able to read information

Concerned with lack of smartphones and broadband

Concerned the technology will not work

Concerned about impact to phone battery and data

Conversation focused on positive feelings

Conversation focused on other topics

Generally feel positively about digital scanning

Various other concerns shared by only a few people

Conversation has many focuses

39
40 Study of Electronic or Digital Link Disclosure

CONSUMER 

JOURNEY

The Reality | Consumer Journey

Study of Electronic or Digital Link Disclosure

Barriers that directly impact 

consumer access

TECHNOLOGIC AL 

CHALLENGES

The consumer journey maps 

the key steps a consumer 

must take in order to access 

information via electronic or 

digital disclosure methods

Contributing factors that 

can inhibit adoption of or 

engagement with the digital 

disclosure

CONTRIBUTING 

FACTORS

Four technological challenges may inhibit consumer access to additional 

food information through an electronic or digital disclosure method

RECOGNIZE

the electronic or digital disclosure the tools required to scan

ACCESS

Lack of familiarity with scanning

Consumers may recognize electronic 

or digital links, but do not know how 

to access information due to a lack 

of familiarity with scanning

Lack of technical knowledge

Scanning digital links is not 

an intuitive process for many 

consumers who lack technical 

knowledge on how to download 

and use scanner apps

Low association 

with additional food 

information

Digital links are not 

inherently associated 

with additional food 

information, and 

consumers often assume 

they are for marketing or 

industry use

Lack of suitable 

equipment to scan

Consumers may not 

have equipment capable 

of scanning digital links 

on their own, and in 

most cases there is 

not a viable alternative 

provided by retailers
41

the electronic or digital link the associated webpage the disclosure contents

SCAN LOAD UNDERSTAND

Unclear disclosure language

The language used in current 

voluntary bioengineering 

disclosures is not clear or 

consistent across products, 

resulting in misunderstanding 

among interested consumers

Confusing or 

malfunctioning apps

There are hundreds of 

scanning apps available 

in the market, many of 

which are not intuitive to 

use, causing consumer 

confusion and difficulty 

opening link results

Low broadband access

Consumers may be 

unable to connect to 

broadband, or connect 

at a speed that is so slow 

that they cannot load 

information
42 Study of Electronic or Digital Link Disclosure

The Reality | Technological Challenge: Recognize

I’ve seen it before, I know it’s a barcode and I mean, that’s all I can 

tell you about it. - Ronnie, referring to a QR code on a food product

42 Study of Electronic or Digital Link Disclosure

Digital links are not inherently associated with 

additional food information, and consumers often 

assume they are for marketing or industry use

Digital links are not generally recognized as a means of communicating food 

information. They have been used for a wide array of purposes — from 

marketing to electronic coupons to mobile pay — and not exclusively by food 

manufacturers. As a result, consumers do not necessarily associate them with 

additional food information.

Moreover, many consumers do not notice an electronic or digital link or 

assume that it is relevant only for retailer or manufacturer use. This is likely a 

result of the varied usage of digital links, and the fact that food information has 

only recently become available through such methods. At the time this study 

was conducted, the Law’s regulations were not yet implemented. In addition, 

as newer technologies emerge, the types of digital links will change and may 

further confuse consumers who seek to access electronic information. Such 

misunderstandings around the use of digital links point to the need for an 

educational campaign.

LOW ASSOCIATION WITH ADDITIONAL FOOD INFORMATION
43

Consumers are unfamiliar with QR codes

A QR code is currently the most widely used form of 

electronic or digital disclosure on product labels. Yet, 

in detailed conversations with consumers, 29 out of 

40 participants did not know what a QR code was. 

A number of participants assumed that it was a tool 

for manufacturers or retailers, akin to a new type of 

barcode. Ronnie, a single father of two living in rural 

Appalachia, had seen a QR code before but did not 

know anything more about it — he did not know 

that it contained food information, he did not know 

how to scan it, and he did not know it was accessible 

to consumers. Rather, he assumed the QR code was 

for the manufacturer and did not concern him.

A lack of knowledge around QR codes was most 

clearly seen in direct observation and open-ended 

discussion with study participants. However, even in 

crowdsourced conversations, 24 respondents noted 

low recognition of electronic or digital codes. While 

this is a small portion of all crowd participants, these 

respondents addressed this issue without being 

asked about it directly.

Secondary research echoes these findings. A 

study conducted by the Annenberg Public Policy 

Center in July 2016 found that only 15 percent 

of Americans scanned barcodes or QR codes to 

find information about a product’s ingredients or 

nutrition information in the prior year; 29 percent 

had scanned these to find the price of a product or 

to check out at a store during the same period.36

These consumer perceptions are validated by 

retailer and manufacturer use of QR codes for 

varied purposes. While they are increasingly 

employed as a means of providing food information, 

QR codes also currently deliver other product 

information, videos, eCommerce, app downloads, 

and customer relationship management.8 This 

was readily seen in field observations, where retail 

outlets display QR codes at self-checkout, and store 

signage and advertisements include QR codes which 

can be scanned for marketing purposes.

YOUR TICKET

GATE TERMINAL

14 1

DEPARTS

12:00PM

STATUS

On Time
44 Study of Electronic or Digital Link Disclosure

Consumers do not know that digital links 

contain food information 

While some participants observed in this study 

did not know what a QR code was, those that did 

know did not realize it could contain additional food 

information. A number of case studies illustrate 

the varied associations that consumers have with 

QR codes and the resultant lack of association with 

additional food information.

Travis, an agricultural professional in Appalachia, 

had an app that stores all of his retailer membership 

reward cards. When grocery shopping, Travis takes 

out his phone, opens his app, and the app produces 

a QR code. Travis then takes his phone to a store 

kiosk, scans the QR code, and the kiosk downloads 

coupons to his smartphone. Upon checkout, Travis 

scans the QR code on his app again, and all the 

coupon discounts apply directly to his purchase. 

In this way, Travis was very comfortable using QR

codes, but he only associated them with sales, 

discounts, and coupons. He added, “Well, it’s just 

even knowing what they’re for...What are they? Why 

are they on the box?” He did not understand that a

QR code would link to product information.

Natalie, a mother of two young boys, uses QR 

codes regularly as part of her scrapbooking. She 

likes to include videos in the scrapbook pages, so 

she uploads them to a webpage that generates 

a corresponding QR code. As a result, her kids 

recognize QR codes and constantly ask her to scan 

whenever they see one. However, Natalie had never 

encountered one with additional food information, 

and assumed that QR codes on food packages were 

used for advertising.

Shannon lives in a tribal region in the Southwest. 

She had seen QR codes before and knew that her 

sister scanned them for “price deals.” As a result, she 

thought these were a new type of barcode. Indeed, 

QR codes were extremely prevalent in her county, 

but they were used in a variety of different settings 

— including mobile checkout or company marketing 

— and not necessarily linked to food information. 

Simply recognizing QR codes did not help Shannon 

to understand that she might be able to access a 

bioengineering disclosure this way.

Just as a lack of recognition of QR codes was most 

clearly seen in direct observation, the fact that 

consumers do not associate these codes with 

food information was best noted in ethnographic 

study. Yet a small group of crowd participants 

also commented on a lack of knowledge that QR 

codes contain additional food information. The 

conversation prompt included a reference to 

additional food information being available in digital 

links; 20 participants noted that they did not 

know that such links were used for this purpose. 

As with a low recognition of QR codes, other crowd 

participants may have shared these associations, 

but did not choose to comment on this in their 

textual responses.

The Reality | Technological Challenge: Recognize

I don’t know how I would go 

about using them. Would 

I need to have some kind 

of app? Would the app be 

secure? Would I be tracked?

- Crowd participant, discussing a lack of 

knowledge around using digital links
45

Retailers are also unaware that digital links 

include additional food information

In visits to 42 retailers across four regions, only two 

knew that digital links would provide additional food 

information. In a visit to a high-end national specialty 

food retailer in a Midwestern city, researchers asked 

eight employees what they would find in scanning a 

digital link and not a single person knew the content 

or how to access it.

Retailer assumptions regarding digital links are 

made based on past and present link usage

Unsurprisingly, like consumers, retailers generally 

associated QR codes with coupons, marketing, 

or manufacturer use. At a corner store in 

a Southwestern tribal region, an employee 

commented that scanning a digital link would lead 

to a brand marketing video. In reality, though not yet 

required by law, the digital link connected to a page 

with food information, including a bioengineering 

disclosure. This encounter illustrates how, going 

forward, consumers may receive inaccurate and 

inconsistent information from retailers — even if well 

intentioned — leading to further confusion.

Instructional text may help to guide consumers, 

but will not be enough to educate them on use

Consumer confusion could be solved in part 

by the Law’s mandate stating that digital links 

used for bioengineering disclosure must say, 

“Scan here for more food information” or other 

equivalent language. However, both retailers and 

consumers in the field tended to overlook guiding 

words surrounding the digital link, making it even 

more imperative that retailers possess a better 

understanding of the disclosure. Further, such 

language does not specify that the additional food 

information is a bioengineering disclosure.

Current QR code uses that may 

contribute to consumer confusion8

Tickets (Concerts, Movies, Transportation)

Brand Marketing (Sports, Products)

App Downloads

Self-Checkout for Retailers

Food Recipes

Coupons & Promotions

Classroom Learning

Military Identifications

Social Media Sites

Scrapbooking

“[It’s] for people who don’t 

want to read [the information] 

on the box.” 

– A cashier explaining content

found on QR codes 

“That code? I don’t 

know. That’s the code 

[manufacturers] use, we don’t 

use it.” 

– A young store employee

“That’s a SmartLabelTM. I don’t 

know what it’ll show you, but 

several items have it.” 

- A regional chain store manager
46 Study of Electronic or Digital Link Disclosure

The Reality | Technological Challenge: Access

Yes, you can scan it, but I don’t have anything to scan it with... 

I have a basic flip-phone, as do most of us up here.

- Pam, describing the lack of access to scanning equipment in her rural town 

46 Study of Electronic or Digital Link Disclosure

Consumers may not have equipment capable of 

scanning digital links on their own, and in most cases 

there is not a viable alternative provided by retailers

Many consumers lack access to the basic equipment needed to scan digital 

links. Across the country, 23 percent of Americans do not own a smartphone. 

While ownership rates are increasing nationwide, low-income earners, rural 

residents, and those above the age of 65 face more limited access to such 

devices.18

Most who own smartphones will be able to scan using their smart devices. 

Yet smartphone ownership is not necessarily a proxy for access, as some 

smartphones are not capable of scanning electronic or digital links. A device 

might be older, malfunctioning, or lack storage space, inhibiting one from 

scanning effectively. For those who do not have a scanning tool of their own, 

retailers are not currently equipped with scanners for consumers to use.

LACK OF SUITABLE EQUIPMENT TO SCAN
47

Twelve percent of study participants noted 

challenges in accessing the tools needed to scan

Currently, electronic and digital disclosure methods 

require a device that can scan a link on a product 

package. While in-store scanners may be used, 

consumers primarily use their personal devices for 

this activity. Some smartphones may be able to scan 

links with a built-in camera; others require consumers 

to download a scanner application. However, not all 

consumers own smartphones. A study conducted by 

the Pew Research Center in January 2017 found that 

23 percent of the adult population in the US does 

not own a smartphone.16 While not all members of 

this population will care to access the bioengineering 

disclosure, those who do will be challenged in 

attempting to obtain this information through an 

electronic or digital link.

In direct observation and crowd responses, 

consumers across the board noted a lack of access 

to this basic equipment as a concern. However, this 

concern was most profoundly articulated by older and 

low-income consumers. Even in the crowd discussion 

— which was facilitated online, and thus likely involves 

participants who are more technologically enabled 

than the broader population — six percent of 

respondents did not own a smartphone. Double this 

number noted challenges in accessing the equipment 

needed to scan, including not owning a smartphone, 

having a smartphone that could not scan, limited or 

no phone storage available for a scanning app, or lack 

of a scanner available in retail stores.

Participants echoed these concerns in direct 

observations. In one encounter, Pam, a long-time 

resident of rural Vermont, discussed great interest 

in accessing food information, including the 

bioengineered status of her food. However, she owns 

a flip-phone and would not be able to scan QR codes 

on her own.

Jolanda, a mother of two who shops for her large 

family in a tribal region in the Southwest, owns a 

smartphone but cannot use it for anything other than 

phone calls or text messages unless it is plugged in. 

Otherwise, her battery dies quickly and her phone 

shuts off, causing her frustration and embarrassment.

Peter and Yemi, a couple in a Midwestern city, spoke 

about their constant struggle to find space for needed 

apps on their smartphones. In the midst of our 

conversation, Yemi received a pop-up notification that 

she was running low on storage space. Neither had 

space available for a new app, particularly without 

knowing what they would get from scanning a digital 

link on a food package.

NO SMARTPHONE OR 

SCANNER TOOL

Older and low-income consumers 

in particular may not own a 

smartphone or other equipment 

that would allow them to scan an 

electronic or digital link.

SMARTPHONE OR TOOL IS 

INCAPABLE OF SCANNING

A phone may be too old to scan 

electronic or digital links; or 

malfunctioning tools may prevent 

apps from downloading or 

scanning.

SMARTPHONE OR TOOL 

DOES NOT HAVE ENOUGH 

MEMORY FOR AN APP

Smartphone storage capacity 

varies based on manufacturer, 

age, software, and hard drive.

SUMMARY OF CHALLENGES TO ACCESS
48 Study of Electronic or Digital Link Disclosure

The Reality | Technological Challenge: Access

Older, low-income, and rural residents face 

greater challenges accessing scanning tools

Rates of smartphone ownership in the US are 

increasing across all demographic groups, but 

a few key populations still face lower rates of 

ownership. According to the Pew Research 

Center 2017 Mobile Survey, 58 percent of 

Americans over the age of 65, 36 percent of 

those earning less than $30,000 a year, and 33 

percent of those living in rural areas do not own 

a smartphone.16

While not all of these consumers are interested 

in accessing a bioengineering disclosure, similar 

findings emerged in analysis of crowd responses. 

Respondents earning less than $25,000 and 

those over the age of 60 were far more likely to 

mention a lack of effective scanning equipment 

as a challenge. Smartphones and mobile plans 

are costly, and even cheaper phones and 

plans can constitute major hurdles for lowincome budgets. Older Americans, as well, are 

less likely to own smartphones, partly due to 

limited income and partly due to technological 

discomfort and inexperience.

Figure 5: Percentage of crowd respondents noting 

challenges accessing scanning tools, by annual 

household income

Figure 6: Percentage of crowd 

respondents noting challenges accessing 

scanning tools, by age

24% of respondents earning less than $25,000 mentioned a 

challenge accessing scanning tools, compared to 8-10% of those 

with annual incomes greater than $75,000

More than 20% of respondents over the age of 60 

mentioned a lack of scanning equipment in their initial 

crowd comment

20%

22%

24%

18%

16%

14%

12%

10%

8%

6%

4%

2%

0%

18-34 35-44 45-59 60 and 

above

20%

22%

24%

18%

16%

14%

12%

10%

8%

6%

4%

2%

0%

Less than 

$25,000

$25,000 - 

$49,999

$50,000 - 

$74,999

$75,000 - 

$99,999

$100,000

or more
49

Consumers without phones are unlikely to 

find in-store scanners available

In field visits to 42 retailers across the country, 

not a single retail outlet had a scanner available 

for consumers to use to scan electronic or digital 

links. This included supercenters, grocery stores, 

specialty stores, general stores, and corner stores. 

While this may be a solution at one point in the 

future, few retail outlets are currently equipped to 

provide such devices for consumer use.

Landlines do not provide a viable means of 

accessing the bioengineering disclosure

At first glance, contacting a manufacturer via a 

phone number would seem to offer a helpful 

alternative for consumers who do not have access 

to a scanning device. In research conducted by 

the Food Marketing Institute, all stores reported 

having an accessible landline phone.3 However, 

as discovered in field research, there are certain 

problems that consumers face in trying to 

use landlines to access a bioengineered food 

disclosure.

First, landlines are not in place for consumer use. 

In visiting a regional chain in Appalachia, members 

of the research team asked a retailer to use a 

landline to access disclosure on a food product. A 

manager at the store offered her personal phone 

to researchers to dial the number provided on the 

food product. While stores may technically have 

landlines in place, availability of the phone and 

convenience during the shopping experience is 

compromised.

Second, phone lines currently do not provide 

the same type of information or experience as 

electronic or digital disclosure. In attempting to 

access information by phone, researchers found 

phone lines that were only open during East Coast 

business hours; this presents a clear challenge for 

many consumers who shop and seek information 

in the evening or on weekends. In addition, those 

answering calls may not be equipped to provide 

information on the bioengineered status of food 

products.

In one attempt to seek a bioengineering disclosure 

through a landline, a researcher visiting a general 

store in rural Appalachia was directed to a 

telephone by a store employee. She called a 

phone number provided on the package and was 

asked to provide personal information including 

first and last name, a contact number, and an 

email address. She waited over seven minutes on 

the line only to find that the person on the line 

worked for the retail chain and did not know if 

the product contained bioengineered ingredients. 

The researcher would need to follow up once the 

retailer heard back from the manufacturer. It took 

six weeks to receive a voice mail response, which 

came at 6am on a Saturday morning, saying that 

the product is “non-GMO.” Such an experience 

clearly illustrates the challenges inherent in 

attempting to obtain food information over the 

phone.

of stores surveyed by the Food Marketing Institute reported having phone 

lines that store managers could use on behalf of a customer 100%

3

49

The availability of landline telephones in 

stores. Landlines are universally available in 

store. However, they do not provide a viable 

means of accessing the digital disclosure 

due to limited availability of such phones for 

consumer use and restricted manufacturer 

call center hours.
50 Study of Electronic or Digital Link Disclosure

Why do I have to go visit this or rate it right there?...I’m not here to 

like your page. I’m here to see what the contents are.

- Peter, referring to links that came up on his app when he scanned the QR code

The Reality | Technological Challenge: Scan

50 Study of Electronic or Digital Link Disclosure

There are hundreds of scanning apps available in the 

market, many of which are not intuitive to use, causing 

consumer confusion and difficulty opening link results

While newer smartphones promise to scan electronic links directly through 

a camera, most smartphones require the use of an app to scan. Some of 

these are user-friendly, but the plethora of available options offer inconsistent 

experiences. This presents the greatest obstacle to those who are the least 

tech-savvy, but even those with great comfort using technology — including 

young consumers — face problems in using apps. 

Of particular concern, many apps include pop-up advertisements. These result 

in poor user experience and run counter to standards set forth for disclosure in 

the Law. App development is not managed for consistency, with apps designed 

for revenue generation instead of information access.

CONFUSING OR MALFUNCTIONING APPS
51

Scanner apps vary in design and operation, 

with some more difficult to use than others

There are hundreds of apps available that allow 

consumers to scan or read digital links on a 

smartphone. The availability of these apps depend 

on type of smartphone and operating system that 

a consumer uses. The two smartphone market 

share leaders, AndroidTM and iOSTM, have more than 

200 and more than 300 mobile scanning apps, 

respectively. Windows® and Blackberry® have more 

than 90 and more than 150 applications available, 

respectively.10-13

Each app operates slightly differently. Some contain 

instructions, while others rely on a greater amount 

of user knowledge. Some only scan digital links, 

while others include additional options like price 

comparison or health information. Some link directly 

to information, while others require that users click 

on a web link once the digital link is scanned.

While this variety may cater to diverse consumer 

desires, the sheer scale of options results in 

consumers being unable to determine which app is 

most appropriate for their needs. In conversations 

with consumers, even those who were comfortable 

navigating smartphone technology struggled to 

download appropriate link readers. Only one 

consumer out of 40 observed had a phone with 

built-in scanning capability, so most consumers 

needed to have an app to scan.

Dane, a college student in a tribal region of 

the Southwest, was very comfortable using his 

smartphone. He had never scanned a QR code 

before, but was able to find an app that could 

scan the digital links. However, it took him several 

tries to figure out that he had to click on a web 

link rather than an advertisement to be redirected 

to the webpage linked in the QR code. After 

scanning a few different products, he expressed 

his frustration, noting, “You just can’t touch the 

advertisements.”

Hannah, a recent college graduate living in a city in 

the Midwest, did not have a scanning app on her 

smartphone. To find out which one she should use, 

she typed “how to scan label with smartphone” in 

a search engine. She downloaded a scanner fairly 

easily, but questioned the reliability of the app she 

was using as it lacked legitimacy in how it looked and 

felt to use. While she was interested in accessing the 

bioengineering disclosure, she was wary of doing so 

using a tool that she did not trust.

As technology constantly changes, consumers 

struggle to choose a single scanner app 

As electronic and digital link technology evolves, 

readers will need to adapt to be compatible with 

new scan methods. This can already be seen today 

as barcode scanners are modernized to read 

QR codes as well, but will likely change as newer 

technologies — like digital watermarking or visual 

recognition — are integrated into food products.

Consumers discussed the challenges associated in 

trying to use multiple apps to scan, and determining 

which apps could be used across different types of 

scans. One crowd participant noted that she would 

prefer to use “one downloadable app that could 

read each and every single QR code, barcode and/

or other electronic [link].” Another commented that 

she did not want to download an app for different 

brands, but would download one that “could be 

used for all food items.”

As different types of scans are integrated into the 

market, scanning may become simpler and more 

streamlined for consumers. Yet it could also become 

increasingly challenging for consumers to navigate 

the phones and apps needed to read electronic and 

digital links.
52 Study of Electronic or Digital Link Disclosure

The Reality | Technological Challenge: Scan

Unclear instructions cause confusion and 

prevent user troubleshooting

Existing electronic or digital link scanner 

applications may offer inadequate or unclear 

instructions for use. This disproportionately 

disadvantages consumers who are not techfluent, often relying on technological jargon (e.g., 

scroll, swipe, aim).

Advertisements lead to unwanted detours 

and user distrust of resulting information

Scanner applications, particularly those that 

are free to download, often contain popup and embedded advertisements. Often 

hard to distinguish from other app features, 

advertisements can lead to user confusion 

and misnavigation. Overall, 40 percent of 

observed participants struggled to navigate and 

troubleshoot apps with advertisements.

Unexplained delays in page loading cause 

early user abandonment

Given mixed media use in scan results, some 

embedded links take longer to load than others. 

However, existing apps provide no explanation 

for delays in loading, causing user confusion 

and eventual abandonment.

Inconsistent scan results interrupt the 

user experience

Scanner applications vary in how they package 

electronic or digital link results. Some apps 

directly link to the embedded landing page, 

while others generate a URL code for a user to 

click on to open.

Variable in-app scanning requirements 

cause confusion and frustration

Some scanner applications require certain 

standards for packaging, lighting, and link 

placement, often prolonging the scanning 

experience and causing user frustration. 

Existing apps provide little to no guidance on 

troubleshooting scanning challenges.

CLICK TO OPEN LINK:

HTTPS://DIGITALDISCLOSURE/LINK.COM

AIM AT QR CODE

LOADING...

ADVERTISEMENT ADVERTISEMENT

Figure 7: A variety of design issues with apps challenge consumers who 

seek to access bioengineering disclosure through digital links
53

Pop-up advertisements confuse consumers 

and run counter to the intent of the Law

The vast majority of scanner applications are free 

to download — between 98 and 99 percent.10-13

Yet these apps are generally not designed for 

information access; they are designed for revenue 

generation. As such, they are incentivized to include 

advertisements so as to garner profit.

Built in to the structure of most apps, pop-up 

advertisements confuse and distract consumers. 

Many consumers are frustrated with the redirect 

and do not know how to navigate to the information 

they were originally seeking, at times testing 

patience and causing consumers to give up.

These advertisements are particularly troublesome 

for those less familiar navigating smartphone 

technology. Marjorie, a rural resident who did not 

own a smartphone of her own, used researchers’ 

phones to scan. She did not understand why an 

advertisement for a game came up on the screen 

after she scanned. She was not able to close out 

of this window to find the voluntary bioengineering 

disclosure on her own.

The use of marketing and promotional information 

runs counter to standards set forth in the Law. 

According to the Law, electronic and digital 

disclosure links must provide access to the 

bioengineering disclosure without marketing or 

promotional information. The challenge is that 

app developers and food manufacturers do not 

have the same incentives or deterrents, yet both 

need to operate together. As such, USDA will need 

to consider how to address the hundreds of apps 

currently in the market that operate counter to the 

intent of the Law.

According to the Law, USDA 

must ensure that an electronic 

or digital link disclosure 

“provide access to the 

bioengineering disclosure 

located, in a consistent and 

conspicuous manner, on the 

first product information 

page that appears... which 

shall exclude marketing and 

promotional information.” 
54 Study of Electronic or Digital Link Disclosure

Now the cellular coverage up here is tough. Sometimes depending 

on where you are you may not get any reception whatsoever.

The Reality | Technological Challenge: Load

Study of Electronic or Digital Link Disclosure

- Norm, referring to challenges accessing data service in rural Appalachia

Consumers may be unable to connect to 

broadband, or connect at a speed that is so slow 

that they cannot load information

Across the US, 6.4 percent of consumers have inadequate broadband 

access to load a basic digital link — particularly, though not exclusively, in 

rural locations. Compared to FCC standards, 39 percent of rural Americans 

and 41 percent of Americans living on tribal lands lack access to advanced 

broadband service.18,28

Food retailers are increasing the availability of free WiFi offered in store, but 

there are still limitations to how consumers can use those networks. This is 

especially significant for consumers who have limited data usage on their 

mobile plans. While data service may technically be available in an area, this 

group often cannot afford to access the Internet outside of WiFi networks, 

indicating that alternative means of access will be required in certain areas.

LOW BROADBAND ACCESS
55

The 6.4 percent 

of Americans with 

inadequate broadband 

are spread across 

1,020 counties

COUNTIES WITH 

INADEQUATE BROADBAND

40% 

completely 

rural

6.4%

12% 

mostly 

urban

48% 

mostly 

rural

Figure 8: Broadband access across the US28

Broadband access is not universal, particularly 

in rural regions of the US

According to the FCC, 34 million Americans (10 

percent of the population) lack access to advanced 

broadband service. This is particularly true in 

rural and tribal areas, with 23 million Americans 

living in rural areas (39 percent) and 1.6 million 

living on tribal lands (41 percent) lacking access to 

advanced broadband.18 The Secretary of Agriculture 

promotes expansion of broadband networks in 

rural areas as part of infrastructural improvements 

and technological innovation in rural America. He 

stated, “We think we ought to have the same push 

to have broadband connectivity all over the country 

because in the 21st century it is just as important as 

a telephone, water, sewer, roads.”37

The FCC’s advanced broadband standard is based 

on a threshold of 25 Mbps download speed, with 

the expectation that, at such speeds, consumers 

are able to access high-quality broadband service 

across multiple devices. Yet gaps remain even 

when adjusting for the more modest service likely 

needed to download information available through 

a digital scan. This study focuses on a threshold of 

only 10 Mbps download speed, as a digital link for 

a single webpage requires a lower speed to access 

information. Based on the 10 Mbps standard, this 

study finds that 20.5 million people (6.4 percent of 

the US population) have inadequate broadband to 

load a basic electronic or digital link.28

Similar to FCC reports on access to advanced 

broadband service, this study found that rural 

Americans are more likely to experience challenges 

accessing broadband at levels needed to load a 

bioengineering disclosure webpage. Of the 1,020 

counties with inadequate broadband, 88 percent 

are mostly or completely rural. This represents 15.8 

million rural Americans, or 38 percent of the rural 

population.28

Moreover, while broadband may technically be 

available in a specific location, individual access 

is often dependent on provider. In attempting to 

access disclosure webpages in locations across 

the US, load times — and even data access itself 

— were often notably different when connecting 

through different providers. Standing side by 

side, one individual may be able to easily scan a 

disclosure link, whereas another may scan without 

successfully accessing information.
56 Study of Electronic or Digital Link Disclosure

The Reality | Technological Challenge: Load

Rural and low-income respondents were most 

likely to note broadband availability as a 

challenge in accessing digital disclosure

Access to data or WiFi networks was the most 

commonly cited challenge among crowd 

respondents, with 16 percent of participants noting 

limited broadband in their initial comments. This 

included those who lacked access to adequate 

data or WiFi networks, had problems with slow 

connections, or mentioned limited data usage 

available on phones.

Rural respondents were most likely to comment 

on low broadband access, with 22 percent of those 

living in rural areas mentioning this as a challenge. 

As seen in Figure 8, access to broadband is 

particularly difficult in rural areas, echoing FCC 

findings.

Field research mirrored these findings. In 

open-ended conversations, many participants 

mentioned the need for quality broadband to scan, 

but those living in rural areas were more vocal 

about broadband challenges. In these locations, 

consumers could cite which carriers provided 

reliable service in the county, and which grocery 

stores were in the middle of broadband ‘dead 

zones.’

Figure 8: Percentage of crowd respondents 

noting challenges accessing broadband, by 

geography

22%

20%

18%

16%

14%

12%

10%

8%

6%

4%

2%

0%

Rural Suburban Urban

Though rural residents were more likely to 

note challenges accessing reliable broadband 

networks, urban and suburban consumers also 

shared this concern, with 16 percent and 14 

percent mentioning this in their crowd responses, 

respectively. Indeed, according to the FCC, 4 

percent of urban residents in the United States 

lack access to advanced broadband service.18

In addition, many of these comments reflect the 

diversity of issues surrounding the availability 

of broadband, including the lack of store WiFi, 

slow connection speeds, and limited data usage 

on phone. All of these contribute to consumer 

challenges in accessing disclosure through 

electronic or digital methods.

Scott, a Veteran living in a city in the Midwest, 

explained that his data service is always turned 

off to avoid going over on his limited monthly data 

plan. He looks for free WiFi wherever he goes, and 

generally links to store networks when they are 

available. Without store WiFi, Scott would not be 

able to connect to the digital disclosure webpage.

22% of rural respondents commented on broadband access as a 

challenge in accessing information via an electronic or digital link
57

My grocery store 

is in a dead zone 

where I have 

no cell phone 

reception and the 

store WiFi is slow. 

If I had to access 

the Internet for 

information about 

the food, it would 

likely take me three 

hours to do my 

grocery shopping.

When access is slow, consumers assume that 

digital links do not work 

A lack of data or WiFi service will prohibit access 

to a digital scan, but slow load times may confuse 

consumers who do not understand why a 

page remains blank. This may be particularly 

problematic with complex webpages that contain 

more content to load, such as videos or graphics.

In observations, when pages were slow to load, 

consumers often assumed that they made a 

mistake in scanning. After 55 seconds of trying 

to scan and waiting for the page to load, Jonni, a 

young woman in a tribal region in the Southwest, 

asked if she should make another attempt. After 

waiting 30 seconds on her second try, she gave 

up, thinking that the link was not working. 

Figure 9: Sample of retailers and associated broadband access

Retailer WiFi Access Data Access 

(1-5 bars) Scan Time

National Discount Chain

Appalachia 30 seconds (data)

General Store

Appalachia 25 seconds (data)

Regional Chain

Midwestern City 2 seconds (data)

Supercenter Store

Tribal Southwest

2-5 minutes (WiFi)

7 seconds (data)

Regional Chain

Rural Vermont 12 seconds (data)

General Store

Rural Vermont 2 seconds (data)

– Crowd participant, 

commenting on 

difficulties accessing 

broadband in store
58 Study of Electronic or Digital Link Disclosure

The Reality | Technological Challenge: Load

Food retail outlets across the country report 

strong and growing coverage of WiFi networks 

in store

The Food Marketing Institute represents nearly 

40,000 retail food stores across the country, 

including single owner grocery stores, large multistore supermarket chains, and mixed retail stores.38

Based on a representative sample of its members, 

the Food Marketing Institute found that there is 

strong coverage of WiFi networks in stores across 

the country. Over 80 percent report some level 

of coverage in store. Regional and national chains 

report close to 100 percent WiFi coverage, with 

access provided in at least some sections of the 

store. Independent operators (i.e., wholesalers with 

independently owned stores) reported far less WiFi 

coverage (37 percent).3 As consumers increasingly 

demand access to WiFi networks, many stores are 

investing in this infrastructure to provide increased 

coverage in the coming years and stay competitive 

in the market. 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Independent

Operators

Regional

Brands

National

Brands

Combined

Figure 10: Percentage of stores with WiFi access in 

store, by type of food retailer

Researchers took a screenshot of a phone in a regional 

brand store that had no WiFi available. The only data 

service available was through an extended network.

The availability of wireless Internet or 

cellular networks. Increasing availability 

of broadband networks will expand access, 

particularly, although not exclusively, in rural 

regions of the country.
59

Despite strong coverage, in-store WiFi may be 

limited for consumers

Retailer initiatives to increase the availability of WiFi 

networks will improve access for consumers who 

seek to scan electronic or digital links. However, 

while many stores have complete WiFi coverage, 

there are still limitations to how consumers can 

use those networks.

First, many retailers place limits on the amount 

of time that consumers are able to use store 

WiFi. In conducting field research at stores across 

the country, researchers found 15 retailers that 

advertised available WiFi. However, most only 

provided access for a limited period of time, 

sometimes as low as 30 minutes. The average 

time spent grocery shopping is 43 minutes.39 If 

consumers were to stop and scan digital links, 

that time would likely increase and may come up 

against WiFi time limits.

Second, connection speeds may be so slow that 

consumers assume the signal is not working. For 

example, in a supercenter with free WiFi advertised 

around the store, it took 90 seconds to connect to 

a webpage after scanning a product, far beyond 

the two second wait time that most consumers 

expect when loading a webpage.

Third, access is often variable throughout the store. 

Indeed, network strength and availability may 

change from aisle to aisle. In visiting retailers, signal 

strength was generally best towards the front of 

the store and weakest towards the back.

Small and rural retailers often lack access to 

WiFi in store

In contrast to regional and national chains, 

independently owned stores have lower rates 

of WiFi availability, with only 

37 percent reporting coverage.3 This is likely 

due to high capital costs associated with this 

infrastructural investment.

Such challenges were readily apparent in field 

research in rural and tribal regions. In a rural 

Appalachian town, none of the local retailers — 

including independent, regional, and national 

chain stores — offered WiFi available for public 

use. While visiting a regional grocery chain in the 

tribal Southwest, researchers were informed that 

access to WiFi was only available at the fast food 

restaurant across the street. The closest grocery 

store with WiFi was a supercenter located a half 

hour away.

59
60 Study of Electronic or Digital Link Disclosure

So, what do I do? Click it like I’m clicking a photo?...See to me this 

is hard. Because it’s hard to get a good angle on it...I can’t get it. 

I can’t get it! What am I doing wrong?

60 Study of Electronic or Digital Link Disclosure

The Reality | Contributing Factors

– Amy, struggling to 

scan a digital link

Supplementary factors may challenge consumers 

who are low-tech or do not fully understand the 

complexity of bioengineered food disclosures

Throughout the consumer journey, there are a number of contributing 

factors that may inhibit adoption of or engagement with digital disclosure, 

but do not directly impact consumer access. First, consumers may recognize 

digital links but lack familiarity with scanning. Second, scanning is not intuitive 

for consumers who lack technical knowledge on how to download and use 

scanner apps. Third, the language used in current voluntary bioengineering 

disclosures is unclear and inconsistent across products, resulting in 

misunderstanding among interested consumers.

Tech-savvy consumers may be able to overcome a contributing factor on 

their own, whereas technological challenges may prevent consumers from 

being able to access the desired information. However, consumers who have 

the least comfort using technology will struggle with these factors, as they 

involve a familiarity with the tools and skills needed to scan.

CONTRIBUTING FACTORS
61

Contributing factors impact a variety of 

consumers, but particularly groups less 

likely to have smartphones

Technological challenges have a 

disproportionate impact on certain consumer 

groups. Namely, of those who are interested 

in accessing the bioengineering disclosure, 

low-income populations, rural residents, and 

consumers over the age of 60 are more likely 

to lack the tools and broadband services 

needed to effectively access an electronic or 

digital link.

Contributing factors, too, are more likely to 

impact specific groups, including low-income 

participants and those above the age of 60 — 

the same groups that are less likely to have 

access to devices needed to scan. Looking 

at consumer responses in the crowd, these 

two populations were more likely to comment 

on a lack of familiarity with scanning, limited 

technical knowledge in downloading or using 

apps or scanning technology, and confusion 

with labeling information.

Figure 12: Percentage of crowd respondents 

noting contributing factors, by age

10% of crowd participants commented 

on a contributing factor

Figure 11: Percentage of crowd respondents 

noting contributing factors, by income

Respondents over the age of 60 were more likely to name 

contributing factors as potential barriers to access than 

younger participants

Low-income respondents were more likely to name contributing 

factors as potential barriers to access than higher-income 

earners

16%

14%

12%

10%

6%

8%

4%

2%

0%

16%

14%

12%

10%

6%

8%

4%

2%

0% Less than 

$25,000

$25,000 - 

$49,999

$50,000 - 

$74,999

$75,000 - 

$99,999

$100,000

or more

18-34 35-44 45-59 60 and above
62 Study of Electronic or Digital Link Disclosure

Many consumers are unfamiliar scanning 

electronic or digital links

Most consumers observed in this study had never 

scanned an electronic or digital link before and 

did not know what they were supposed to do to 

get the information from a digital link. Secondary 

studies find this pattern repeated more broadly 

across the American population. A survey 

conducted by the Annenberg Public Policy Center

in July of 2016 found that 85 percent of Americans 

had not used barcodes or QR codes to find 

information about a product’s ingredients or 

nutrition information in the prior year.36 For most 

consumers, scanning electronic or digital links is a 

new practice.

In practice, this meant that a diverse group of 

consumers had questions around scanning. Some 

turned to a search engine for answers that were 

not always right. Can I use my phone or do I need 

an app to scan? How closely should I hold the 

camera? Where should I click to access the link? 

Scanning electronic or digital links is new for most 

consumers. Many will likely learn to use electronic 

or digital links on their own; others may not.

Some consumers lack the technical 

knowledge needed to download or use an app 

or scanning technology

While many consumers who are unfamiliar with 

scanning will be able to troubleshoot issues and 

successfully scan on their own, those who are not 

comfortable using smartphone technology may 

struggle in two key ways: downloading an app and 

using the app or scanning technology.

First, a number of consumers were unable to 

download a scanner app on their own. In one 

observation, Erica, a young mother living in a city 

in the Midwest, did not know what a QR code 

was called. She decided to turn to a web search 

to figure out which app to choose on her own. 

Her results led her to try to download a Fitbit 

application — a tool which is designed to track 

health activity, not to scan QR codes. A lack of 

guidance on which app she should use to scan led 

her to an app that didn’t let her scan at all.

Second, some consumers lack the technical 

abilities to scan electronic or digital links on their 

own. Barbara, a longtime resident of a rural 

Appalachian area, only owned a flip phone and had 

never scanned a QR code before. When she was 

given a smartphone to scan a QR code, she held 

the food product over the phone screen rather 

than directing the camera at the product, similar to 

how one might scan a barcode at a store checkout.

I’m not very good at figuring out how scanning QR codes works. I consider 

myself pretty tech-savvy, but I still don’t know if you need an app to read 

them. - Crowd participant, noting a lack of 

understanding in scanning digital links

The Reality | Contributing Factors
63

Living in a city in the Midwest, Shirley also did not 

own a smartphone of her own. Just like Barbara, 

she initially held the food product over the phone 

screen instead of directing the camera at the QR 

code. Realizing that the product wasn’t scanning, 

she paused and read the instructions on the 

screen: “Aim at QR code.” She again tried to scan 

using the same technique, before researchers 

assisted her. 

With appropriate instruction, both Barbara and 

Shirley were able to scan successfully. Yet without 

direct assistance, they were not able to access the 

bioengineering disclosure available through the 

digital link. 

Voluntary language currently used in 

bioengineering disclosures is not always 

understood by consumers

The issue of bioengineered foods is complex, with 

terms like genetically modified organisms (GMOs), 

genetically engineered (GE), and bioengineered 

communicating distinct ideas but often used 

interchangeably. For example, many of the items 

currently containing a bioengineering disclosure 

include the following text: “This product includes 

ingredients sourced from Genetically Engineered 

(GE) crops, commonly known as GMOs.” However, 

genetic engineering and genetic modification are 

considered by some to refer to distinct processes.

The use of multiple terms is compounded by a 

general lack of knowledge around the issue of 

bioengineered foods. A study conducted by the 

Pew Research Center in December 2016 found 

that many Americans have limited familiarity with 

the issue of genetically modified foods, and 71 

percent have heard little to nothing about the 

issue.1 The use of multiple terms, and a lack of 

clarity over what they are communicating, may 

further confuse consumers with interest, but little 

understanding, in the issue of bioengineered 

foods.

Many of the considerations surrounding a 

lack of clarity in or understanding of the 

bioengineering disclosure will be resolved 

as the law is implemented and consumers 

learn more about bioengineered 

foods. Yet consumers currently face 

bioengineering disclosures that are 

challenging to understand.

For example, Rich is passionate about 

the food he eats and regularly calls manufacturers 

to try to obtain product information that is not 

readily available on label. He cares about accessing 

information on the bioengineered status of his 

food, but was confused by the material presented 

to him in the bioengineering disclosure. He noted, 

“Do it in human language...consumer language, not 

things relating to chemical engineering or biology, 

or things of that nature. Pick simple words to use 

for the consumer that would be important.”

63
64 Study of Electronic or Digital Link Disclosure Study of Electronic or Digital Link Disclosure
65

Looking Ahead: 

Implementing the Law Key Takeaways

In implementing the National Bioengineered Food 

Disclosure Standard, government and interested 

groups can take meaningful steps to improve 

information access for consumers facing potential 

technological challenges. 

IN THIS SECTION

A. Investing in Retailer Infrastructure: A Cost-Benefit Analysis

B. Additional Implementation Considerations

3 In order for the Law to have intended outcomes 

for interested consumers, USDA and interested 

groups should address technological challenges 

and contributing factors

3 Scanners require the installation of WiFi networks 

in store, which may be cost prohibitive for small 

retailers 

3 Installing in-store scanners provides limited 

benefit to retailers due to limited consumer 

understanding and rapidly changing technology

3 Without an educational campaign, the law 

may result in increased cost to retailers and 

manufacturers without providing additional 

benefit for consumers

3 Offline alternatives are necessary for consumers 

who lack access to a scanning device or 

broadband

3 USDA should consider developing or endorsing 

user-friendly scanner apps to enable consumers 

to access information and implement the Law as 

intended
66 Study of Electronic or Digital Link Disclosure

Looking Ahead | Investing in Retailer Infrastructure

There are two options for installing scanning 

technology, each with associated costs

The first and simpler means of scanning electronic 

or digital links in store is through a smartphone or 

hand-held scanning device. This phone or device 

must have a built-in screen and be capable of 

accessing the Internet. Such devices can cost as 

little as $30, and the necessary applications can be 

downloaded free of charge.40 Professional handheld QR scanning devices are often more expensive, 

starting at $1,000.41

The other option is a handy scanner connected to a 

tablet or monitor via Bluetooth or USB. The scanner 

reads the electronic or digital code and sends that 

information to the monitor or tablet which displays 

the disclosure on the screen. Handy scanners 

are often found in retailers. Newer versions are 

capable of scanning both traditional barcodes and 

QR codes, and can cost as little as $40.42 Additional 

software may be required but is often available free 

of charge. Tablets and monitors vary in cost, with 

monitors starting at $100 and tablets at $80.43,44

Electronic and digital links other than QR 

codes are beginning to be used more broadly

One emerging scanning technology is digital 

watermarking, a technique owned and developed 

by DigimarcTM. Similar to QR codes, apps available 

on smartphones and similar devices enable users 

to scan digital watermarks. However, most handy 

scanners are not yet capable of scanning digital 

watermarks. Some have begun to integrate the 

capability into existing scanners, but these scanners 

are often much more expensive, with some starting 

around $250 per scanner.45

Other technologies, such as Near Field 

Communication and visual recognition, are limited 

to apps on smartphones or similar devices. While 

these may be used by manufacturers in the future, 

existing scanners do not yet have the capability to 

read these types of electronic or digital links.

A parallel example to the implementation of in-store 

scanners can be seen in the transition of debit/

credit card systems to chip readers. Only 39 percent 

of retailers have adapted to chip technology, while 

49 percent have plans in place to upgrade. A major 

reason many retailers have been slow to transition 

is a lack of implementation strategy.46

Retailer investments can increase access to digital disclosures, 

but may prove cost prohibitive for small and rural retailers

$

30

$

250

Starting cost of a smartphone capable 

of downloading applications that can 

scan most electronic or digital links40

$

120

Starting cost estimate for a handy 

scanner with QR capabilities and 

tablet/monitor combination42,44

Starting cost estimate for a 

handy scanner with digital 

watermarking capabilities45
67

Digital disclosure requires access to the 

Internet

Electronic and digital disclosure methods 

not only require a scanning tool, but access 

to a reliable wireless network. This is the 

primary cost for retailers seeking to improve 

consumer access to digital disclosure. Many 

retailers have already integrated WiFi in 

their storefronts or have plans to install 

networks in the near future. However, small, 

independent, and rural retailers are less likely 

to have WiFi installed due to the high capital 

costs and limited economies of scale.

Retailers can either provide WiFi access 

for the entire store or can create a 

designated scanning area

Providing WiFi is a significant expense for 

retail stores. One year of WiFi in a retail 

store could cost $10,050 to cover 0 to 

5,000 square feet of space.47 To improve 

the quality of service, retailers could pay for 

extended coverage, with costs increasing in 

relation to a store’s size, as seen in Figure 

13. Supercenters are the only exception, as 

their large size results in them paying less 

for coverage per square foot.47 Thus, smaller 

stores would bear a disproportionate cost. 

Furthermore, costs are highly dependent on 

the number of concurrent users in addition 

to the square footage of the coverage.

Top providers also mentioned that 

broadband service is not always available 

in all locations.48-52 While providers did not 

specify exact locations where service was not 

available, the national broadband heat map 

indicates that rural areas are most limited in 

the availability of these services.

Retailers see little return on 

investments when installing WiFi

While installing WiFi networks increases 

access for consumers, retailers see little 

return on this costly investment. Food 

retailers experience only a 5.8 percent 

increase in earnings before interest, taxes, 

and amortization compared to other 

retailers or restaurants, who see a 32.1 

percent increase.27 These limited benefits 

are especially challenging for small and rural 

retailers, and may be overly costly given their 

limited ability to gain economies of scale.

Figure 13: Average WiFi costs for complete store coverage, 

by cost per year47

$

10,050 Cost of one year of WiFi, including installation 

fees, for 0 to 5,000 square feet of coverage47

186,000

$129,744

$52,800

45,000

$25,800

20,000

$10,050

5,000

Supercenter

Large

Medium

0 40,000 80,000 120,000 160,000 200,000

Small

Cost (in Dollars)

Size (in SqFt)

Small retailers bear a disproportionate 

cost to install WiFi in store

The costs and benefits of installing in retail stores 

electronic or digital link scanners or other evolving 

technology that provide bioengineering disclosure 

information. While scanners are modest in cost, they 

must link to WiFi, requiring installation of networks in 

stores where they do not currently exist. This may prove 

cost prohibitive, particularly for small and rural retailers. 

In addition, there are limited benefits due to limited 

consumer knowledge around digital disclosure.
68 Study of Electronic or Digital Link Disclosure

Looking Ahead | Additional Implementation Considerations

Study of Electronic or Digital Link Disclosure

Educating consumers on digital disclosure can 

improve access 

Many consumers simply do not know that food 

information is available through electronic or digital 

disclosure methods. Effective education campaigns 

can help inform consumers on how to access and 

understand information available through such 

methods. These could include the use of community 

resources such as local radio stations or community 

centers, social media networks, and publications 

targeted at specific demographics.

Several study participants noted that Facebook®

community groups are an essential means of 

communication and information sharing, especially 

in rural and tribal areas where smaller, tight-knit 

communities are more prevalent and homes are 

spread out. In addition, partnerships at the local 

level may be an effective way to educate consumers 

using community networks. A public servant working 

in a tribal region noted that fostering relationships 

between youths and elders was an effective 

means of sharing lessons on technology use in the 

community.

Educating retailers on digital disclosure can 

improve access

Many of the same approaches to educate 

consumers on the use of electronic or digital 

links can be harnessed to educate retailers on 

the same issue. An additional means of reaching 

food retail employees could be through industry 

partners, which provide especially effective channels 

of sharing knowledge. For example, the Food 

Marketing Institute could work with its network of 

retail stores to inform employees on the types of 

information available through electronic or digital 

links and how to access this. As a result, retailers 

would be better equipped to help consumers access 

this information.

Educating the American public can improve 

understanding of bioengineered food

Most Americans have limited familiarity with the 

issue of bioengineered or GMO food. Educational 

campaigns could work to expand understanding on 

the issue for the public, at large, building on many of 

the same methods used to educate them on digital 

disclosure more generally.

A digital link itself could be used for such a purpose. 

Such a method of disclosure allows for much more 

information to be shared than is possible on a 

traditional food label, and thus provides an excellent 

opportunity for consumer education regarding 

what it means for a food to be bioengineered. 

Moreover, digital links could increase access to food 

information due to the increased flexibility of such 

methods of disclosure. 

Thoughtful action can improve access for consumers facing 

technological challenges
69

For example, if disclosure webpages were to 

incorporate a translation function, information 

could be more easily understandable for consumers 

who are not comfortable reading English. As a 

result, these methods present an opportunity to 

make information on bioengineered foods more 

accessible and understandable for a diverse array of 

consumers. 

Offline options can increase access for 

consumers who lack smartphones or 

broadband access

In seeking to provide greater access for populations 

who lack smartphones or broadband, on-package 

identification could link consumers to data that is 

available offline. As the Law already requires that the 

electronic disclosure is accompanied by a telephone 

number, this could be an especially effective 

means of expanding access to the bioengineering 

disclosure. Consumers could use this number 

through landlines and/or non-smartphone 

cellphones as a means of obtaining information on 

the bioengineered status of their food.

There are two primary ways in which this might be 

achieved. First, a landline-enabled bioengineering 

disclosure could allow consumers to call into a 

phone number with a code that provides them 

24-hour disclosure information via an automated 

recording. (This would account for the fact that 

many customer service centers are open only 

during business hours, when many consumers are 

not shopping for food.)

Alternatively, packages could include a text message 

alternative for consumers who have access to a 

mobile phone. Such an approach is seen in cities 

across the US, where public transit riders can use 

their phones to request estimated arrival times of 

buses or subways when traveling. Often subway 

stations have displays that list estimated arrival 

times, but most bus stops do not list these directly. 

However, many municipalities provide arrival times 

through an SMS text system, allowing those without 

smartphones access to estimated bus arrival times. 

Riders locate a bus stop code number on their bus 

stop sign and text the code to a designated number. 

Within moments, they received estimated arrival 

times for the bus stop. A similar approach could 

be taken with food products, where consumers 

could text a code to a phone number provided on 

package and receive the bioengineering disclosure 

via SMS text.

Developing or endorsing user-friendly scanner 

apps can ease the consumer experience

Consumers face significantly different experiences 

when using different apps to scan digital links. 

Endorsement or development of user-friendly apps 

can help to make sure that consumers are able to 

access bioengineering disclosure information clearly 

and correctly.

Creating standards for apps, or endorsing apps that 

meet a certain set of standards, would help to link 

consumers appropriately to information available 

in electronic or digital disclosures. In an example of 

government and private industry partnership, the 

IRS endorses third party filing software — including 

the apps they provide for tax-filers — to help 

taxpayers e-file safely and appropriately. These 

standards could help provide a more consistent 

consumer experience. Examples include requiring 

that scanner apps have clear instructions for 

scanning, no advertisements, and are free to 

download.

Alternatively, USDA could develop a scanner app 

that meets standards set forth in the Law.
Study of Electronic or Digital Link Disclosure

A lot of the things could be really beneficial if we 

take the time to find out about them and I think 

the information is out there, it’s just taking the 

time to look it up... but that’s so overwhelming 

because there are so many sites and there’s 

a lot of verbiage and some things are hard to 

translate.

70 Study of Electronic or Digital Link Disclosure

- Cindy, speaking about her desire to 

access food information
71

Conclusion

Consumers are navigating a new world of digital engagement. The use of 

electronic and digital links presents novel opportunities and challenges for 

consumers seeking to access information on their food purchases. While there 

are some notable challenges, most consumers would be able to access this 

information given the proper education and tools to do so. 

An ever-changing technological landscape makes it difficult for consumers to 

recognize the proper means of accessing information. Interested consumers 

must understand the ways in which information is available to them, especially 

when that information becomes available through new methods. In working to 

implement the National Bioengineered Disclosure Standard, USDA and interested 

groups can work together to make the bioengineering disclosure properly 

accessible to the American public.
References

72

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74

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46. RIS, “27th Annual Retail Technology Study,” April 2017.

47. Deloitte analysis of average WiFi costs based on store size using Bain’s 

WiFi Cost Estimator. http://www.bain.com/wifi-interactive/default.asp.

48. AT&T, “AT&T Business WiFi Solutions.” https://www.business.att.com/

enterprise/Family/network-services/wifi-solutions/.

49. Century Link, “High Speed Internet for Small Businesses.” https://www.

centurylink.com/small-business/products/business-internet/.

50. Optimum Business, “Optimum Online for Businesses.” https://www.

optimum.com/business/high-speed-internet.

51. Verizon, “Verizon Wireless Internet and Wi-Fi Hotspots.” http://www.

verizon.com/smallbusiness/.

52. Comcast Business, “Business Internet, Small Business Internet Service.” 

https://business.comcast.com/internet/business-internet.

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