February 6, 2013
“Substantial equivalence,” is an approach that seeks to approve the use and consumption of GM food based upon the idea that it is “substantially equivalent” to its traditional counterpart, thus, GM proponents claim, it is safe to consume and requires no extra labeling. This approach to GM food is easily dismantled and I encourage the reader to access my article on the subject in order to understand the weaknesses and dangers of using the substantial equivalence model for GM food in any context.
The concept of substantial equivalence is unfortunately the theory of labeling requirements adopted by Codex. It is also very similar to the criteria used in the United States and Canada. As to be expected in such pro-GM countries as the United States, the GM labeling requirements are even less restrictive than those of Codex.
For the most part, labeling of GM foods in the United States and Canada is completely voluntary. This voluntary labeling scheme based on the concept of substantial equivalence is both a prime example of the weakness of both standards, as well as a dark omen as to the direction of Codex guidelines as they continue to be developed.
The FDA does not require GM foods to be labeled unless they meet one of four rather severe criteria. Even then, the labeling refers only to the issue at hand, not the process from which the food was created. The criteria for labeling are as follows:
1.) If a bioengineered food is significantly different from its traditional counterpart such that the common or usual name no longer adequately describes the new food.
2.) If an issue exists for the food or a constituent of the food regarding how the food is used or consequences of its use, a statement must be made on the label to describe the issue.
3.) If a bioengineered food has a significantly different nutritional property, its label must reflect the difference.
4.) If a new food includes an allergen that consumers would not expect to be present based on the name of the food, the presence of that allergen must be disclosed on the label.
So, as these recommendations suggest, a GM food must only be labeled when it is so different from its “conventional counterpart” that it cannot even be considered the same food, is the cause of reactions or consequences that the natural version of it would not have caused, has a “significant” difference in nutritional composition, or if it introduces an allergen that would not otherwise have been present.
It should be noted, like the Codex guidelines for substantial equivalence mentioned earlier, that “significant” difference in nutritional composition is not clearly defined. So what some may consider to be truly significant might not even be considered worthy of any concern by the FDA, and certainly not by the manufacturing company.
Also, as mentioned earlier, there is no discussion of whether or not the inclusion of allergens to a food includes those less common allergies or just the most popular such as peanuts. Yet even meeting these criteria does not necessarily draw the label of “genetically modified” - merely a labeling of the potential side effects of consuming these foods.
Only when one of these four criteria has been met must companies label their products in a manner that may suggest genetic modification and, even then, only in a subtle manner. In all other instances, however, the labeling is completely voluntary.
Just as disconcerting as voluntary labeling is the fact that the alleged “safety testing” is not even conducted by the FDA or any other regulatory agency, but by the food producers themselves. The FDA merely takes for granted the truth of whatever is provided them by industry. That is, if anything is provided to them at all.
As stated in the federal register as far back as 1992, the FDA says,
FDA has traditionally encouraged producers of new food ingredients to consult with FDA when there is a question about an ingredient’s regulatory status, and firms routinely do so, even though such consultation is not legally required.It is certainly concerning to know that, at best, firms are encouraged to consult with the FDA but are not required to do so. Interestingly enough, this is not the position taken in regards to proven safe and effective natural and herbal supplements.
Adding to absurdity of the voluntary labeling policy held by the FDA, the regulatory agency works on the premise that GM foods are safe to begin with and that there is no difference between GM food and natural food.
In the 1992 FDA Federal Register, the agency makes the claim,
In most cases, the substances expected to become components of food as a result of genetic modification of a plant will be the same as or substantially similar to substances commonly found in food, such as proteins, fats and oils, and carbohydrates.Notice the similar terminology of “substantially similar” as compared with the “substantial equivalence” of Codex. This adds even more credibility to the idea that the Codex model of GM food regulation is based on that used by the pro-GM FDA. Not only that, although the difference between the wording might seem unimportant to some, the term “similar” is even more open-ended than the Codex “equivalent.”
But how did the FDA come to these conclusions?
The agency admits that there is no premarket testing by the FDA itself; merely relying on industry to voluntarily consult with the FDA only when the industry feels there might be a problem with the product. 
Yet the agency still maintains, through basic assumption, that GM foods are not different from the natural versions. In the same Federal Register it says,
Under this policy, foods, such as fruits, vegetables, grains, and their byproducts, derived from plant varieties developed by the new methods of genetic modification are regulated within the existing framework of the act, FDA’s implementing regulations, and current practice, utilizing an approach identical in principle to that applied to foods developed by traditional plant breeding. The regulatory status of a food, irrespective of the method by which it is developed, is dependent upon objective characteristics of the food and the intended use of the food (or its components). The method by which food is produced or developed may in some cases help to understand the safety or nutritional characteristics of the finished food. However, the key factors in reviewing safety concerns should be the characteristics of the food product, rather than the fact that the new methods are used.The FDA here is claiming that the process of genetic modification, even though it has not evaluated it thoroughly, is not only safe but, for the most part, irrelevant to the question of food safety.
Of course, this is merely manufacturing conclusions out of thin air. The FDA asserts the safety of GM food because there is “substantial equivalence” between the two. However, there is “substantial equivalence” only because the FDA claims that this is the case. There is a massive lack of evidence to support any of these claims.
The FDA also claims that genetic engineering is no different from “traditional plant breeding,” an argument that is often made within the pro-GM community. Such is the belief (or argument) that traditional means of plant breeding such as grafting and cross-pollination are essentially the same as removal and insertion of DNA from one life form to another. In reality, nothing could be further from the truth.
This argument would be akin to claiming that breeding of humans of different ethnic backgrounds is the same as breeding between humans and horses.
Additionally, the question of how the FDA would know this -- since it has not conducted any scientific experiments regarding this claim -- arises yet again. Still, it continues to blend the two very different methods together by defining genetic engineering as the “alteration of the genotype of a plant using any technique, new or traditional.”
Thus, the FDA puts the insertion of a pig gene into a tomato into the same category as natural birth, since genes change and develop with each generation. If there were any doubt as to whether or not this is the FDA’s position their claim that “Most, if not all, cultivated food crops have been genetically modified,” should easily remove it.  This claim is only true if one accepts the FDA’s definition of natural reproduction as genetic engineering.
As in most cases involving the FDA, the biotech food industry, and Codex Alimentarius, the boundaries of logic are not only pushed to the breaking point in order to justify and promote the proliferation of GM food, those boundaries are regularly crossed.
Indeed, these mental gymnastics used create an environment in which toxic GM food is virtually unregulated while healthy organic substances are annihilated by force and regulation are a feat in their own right.
 “Guidance For Industry: Voluntary Labeling Indicating Whether Foods Have or Have Not Been Developed Using Biotengineering: Draft Guidance.” Food and Drug Administration. January 2001. http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/FoodLabelingNutrition/ucm059098.htm
 “Statement of Food Policy – Foods Derived From New Plant Varieties,” FDA Federal Register Vol. 57. 1992. http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/Biotechnology/ucm096095.htm Accessed May 24, 2010.
 Ibid. p. 5.
 Ibid p. 4.
Read other articles by Brandon Turbeville here.
Brandon Turbeville is an author out of Florence, South Carolina. He has a Bachelor's Degree from Francis Marion University and is the author of three books, Codex Alimentarius -- The End of Health Freedom, 7 Real Conspiracies, and Five Sense Solutions and Dispatches From a Dissident. Turbeville has published over 190 articles dealing on a wide variety of subjects including health, economics, government corruption, and civil liberties. Brandon Turbeville's podcast Truth on The Tracks can be found every Monday night 9 pm EST at UCYTV. He is available for radio and TV interviews. Please contact activistpost (at) gmail.com.
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