So far, I haven’t seen an argument for labeling of genetically engineered foods that I found persuasive. I reject the idea that consumers have a right to know what they’re eating. And I’ll happily (but perhaps foolishly) defend a lack of transparency. However, I’m not entirely opposed to mandatory labeling of genetically engineered foods. I just don’t think the case for or against mandatory labeling has been made persuasively.

There’s one argument for labeling that I think deserves special mention because I could imagine myself some day finding myself persuaded by it. The argument in question, championed by biotechnology supporters like Mark Lynas, Ramez Naam, and Rachael Ludwick, posits that labels can help genetic engineering gain consumer acceptance by reassuring people that there’s nothing to hide. By allaying consumer fears, the argument goes, GMO labels can prevent consumer rejection of biotech crops with important environmental benefits.

I mentioned in the first post in this series that I don’t like using labels as “a tool for manipulating consumer behavior to bring about consumer acceptance of biotech crops.” I haven’t changed my mind since I wrote that, but I am enough of a pragmatist that some day I might hold my nose and declare my support for labeling to bring about consumer acceptance. But I nonetheless feel compelled to acknowledge the stench.

Here’s what I like about this argument: it justifies labeling on the basis of societal benefits from biotech crops, rather than an ill-defined “right to know” or some polls that indicate that people want GMO labeling. Unlike those consumer-oriented arguments, it identifies some clear benefits that might come from mandatory labeling.

But I’m not convinced that labeling will do very much to increase consumer acceptance of transgenic crops. Naam points out that it’s “extremely hard” to respond to GMO opponents who say things like, “If you’re so proud of your GMOs, why don’t you label them?” Having devoted several posts to explaining why arguments like this one are vacuous, I have to admit that he has a point. It does take a good deal of work to respond to this argument. But I think the relevant issues are worth discussing, even if they are complicated.

That brings me to one reason I’m less than optimistic about the potential of labels to foster consumer acceptance of biotechnology. I think that the public discourse surrounding agricultural biotechnology is broken. Instead of discussing real issues, we talk about bogus health concerns or Indian farmer suicides. Fixing this will require moving beyond sound bites, and I find it hard to believe that dodging an honest conversation about real issues is a good way to start. Will eradicating one anti-GMO talking point really give us a more nuanced conversation?

Moreover, consumer acceptance of genetic engineering shouldn’t be an end in itself but a means for realizing certain benefits of certain genetically engineered crops. For this reason I the various genetically engineered crops should be considered separately. Take the example of glyphosate-resistant crops, such as soybeans and sugar beets. By most accounts, the main benefits of these crops are profits for seed companies and easier weed control for farmers. I think the case for mandatory labeling to protect these benefits is weak. Generally, the goal of government intervention is to protect the common good. There’s no reason farmers and seed companies shouldn’t be allowed to take the risk that consumers will reject their products if only their own interests are at stake.

Of course, the issue is more complicated than that because other interests are at stake. A more important question is whether unlabeled herbicide-resistant crops will lead to broad consumer rejection of genetically engineered crops, including crops in the pipeline with more important benefits like nitrogen-efficient wheat or disease-resistant citrus. Would consumers accept these beneficial crops if they were voluntarily labeled, or will today’s unlabeled crops irreparably damage the genetic engineering “brand”? And how will consumer attitudes in the absence of labels affect future research into transgenics?

Returning to consumer-centric arguments, I think there may be an argument for labeling GMOs which is at least as strong as the argument for some other labels which are currently required (e.g. country of origin labeling). But consumer interest is complicated, and thus far, I haven’t been persuaded that the consumer interest in GMO labeling is particularly strong. Beyond this, I have a few more thoughts, in no particular order:

• If we’re going to mandate labeling, I prefer a less informative label which just states that a product may contain genetically engineered ingredients. Some biotechnology supporters have expressed a preference for labels with more information, such as which trait has been inserted into a crop. I agree that this would be more informative for consumers, but I don’t see that as a good reason to require farmers to separate, say, pest-resistant corn from herbicide-tolerant corn which would almost certainly increase food prices¹.
• I don’t support compelling prominent placement of GMO label language. I’m not saying that manufacturers should be allowed to hide the information in tiny print, but there’s no good reason to require a GMO label to be positioned so conspicuously that everybody will see it, whether or not they want to. Prominent placement of label language, such as the front-of-package label required by Washington’s recently defeated I-522, conveys not just the literal meaning of the label but also the idea that that information is important. It would therefore be misleading to require GMO labeling on the front of a package while relegating information with clear health implications (e.g. nutritional information) to the back of packages.
• While I don’t think genetic engineering is an ethical issue, many justifications for labeling have an ethical component. I am very wary of addressing ethical problems with mandatory labels. Since “ethical” alternatives usually cost more, people with lower incomes will be less likely to be able to afford them. The result is that the label serves the dual purpose of warning more affluent consumers away and making lower income consumers feel bad about buying the only food they can afford. I don’t mind voluntary labels, but at the regulatory level I don’t think labeling is the right tool for addressing ethical problems.
• No doubt many labeling proponents want to get rid of genetic engineering entirely, but this is a bad reason to oppose labeling.
• However bad a GMO labeling initiative may be, it does look bad to have industry throwing money into defeating it. And it will no doubt look even worse to have food producers suing to overturn an initiative that succeeds.
• People who want to know whether their food has been produced with genetic engineering can choose to buy food from producers who will give them that information. However, this doesn’t really work as an argument against mandatory labeling. One could make the same observation about any number of pieces of information which are already required, e.g. ingredient information.
• Anti-labeling campaigns have overstated the cost of labeling by assuming that food products will be reformulated to avoid the use of GMOs. Pro-labeling campaigns have understated the cost of labeling by ignoring any costs resulting from changes to supply-chain management, focusing solely on the cost of changing the label.

In the framework of my own values, I don’t think the case for GMO labeling is compelling, but this isn’t merely because science says that genetically engineered foods are safe to eat. Insofar as labeling serves to protect consumer interests, it’s reasonable to let public opinion play some role in the decision. People should have a say in deciding what their own interests are. I don’t support mandatory labeling because I haven’t seen the evidence that very many people want it. That said, there’s no denying that some consumers take an interest in mandatory labeling, and there is room for disagreement on the question of how strong consumer interest should be to justify mandatory labeling.

This is the last in a seven part series on compulsory labeling of foods containing products of genetic engineering.

1. Something is missing from the GMO labeling debate
2. GMO labeling and consumer choice
3. You don’t have a right to know what you’re eating
4. In defense of opacity
5. How strong is support for GMO labeling?
6. Why mandate labeling?
7. I don’t know whether GMO labeling should be required

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1. I should emphasize that I’m not categorically opposed to increases in food prices. I’m in favor of fines for agricultural pollution, for instance, because that addresses a concrete problem. I don’t think the same is true of more informative food labels.↩