There exists a category of pro-mandatory GMO labeling arguments that seeks to remove the formidable burden of having to argue against the international scientific consensus on GE food safety by reframing the discussion to purely normative and/or political terms. This differs from many of the common talking points of GE food opponents in that it doesn’t seek to show that there’s anything wrong with the science or safety of GE foods. Instead, the strategy is to argue that objective scientific merit should not be a prerequisite to the implementation of labeling mandates so long as someone desires it.

One common approach to doing so is to cite examples of existing labels whose implementation is not predicated on any scientifically-backed bearing upon health, nutrition, or safety. It’s actually a rather humorous argumentative strategy if you think about it. It basically implicitly concedes that GE labels would be pointless from an objective scientific standpoint, but  argues that that’s okay because we have other pointless labels in society as well. It has even spawned jokes such as this graphic here:

Of course the approach is purely strategic; so don’t be surprised if the person you see using it eventually drops their apparent tacit acceptance of the science when pressed on the matter, at which time they may resort to some variant of common anti-science tropes such as the old “science has wrong before” or “there was a scientific consensus that smoking was safe” canards, which I’ve rebutted here and here respectively. However, the sincerity of the labeling proponent is not a prerequisite to addressing this argument, so let’s grant him or her the benefit of the doubt and focus on the argument itself.

The examples you’ll likely usually see used for this line of argument will tend to be specious, in that the proponents often use voluntary labels (i.e. rBST free, organic, Kosher, Halal, etc.) as arguments for mandatory labeling laws. However, there is one example that a small subset of slightly more sophisticated labeling proponents occasionally use, which I think is worth addressing, and that is Country of Origin Labeling Laws (aka COOL laws). As the name implies, COOL laws are labeling laws which stipulate that retailers are required to include certain information regarding the origin of said food product.

As far as I’m aware, nobody argues that the requirements of COOL laws are grounded in any science-based concern over the safety or nutritional value of the food, yet they exist. So the anti-GMO argumentative strategy here is to use COOL laws as an example to show that we already do pass labeling mandates for things that aren’t relevant in any scientific way, but which some people want for some other reason. If that’s the case, they argue, then “why not GMOs?” However, that line of argument still fails. Here’s why:

From the State’s perspective, if the underlying premises of Country of Origin Labeling laws (COOL laws) were valid (an assumption I’ll address in a moment), then there would be incentives for their implementation; which simply aren’t there for the case of mandatory “GMO” labeling. In the case of COOL laws, the State’s goal was to protect its own economic and cultural interests. In the case of mandatory GMO labeling laws, there is no such incentive because it would incur costs to both consumers and retailers with no corresponding risk reduction due to their well-established safety equivalence with their non-GMO counterparts.

However, COOL laws have subsequently been struck down.

Not only did the underlying premises not play out in the real world as expected, but the WTO also deemed them to violate international law.

In fact, COOL laws should serve as an example of why mandatory “GMO” labeling would be a bad policy. COOL laws cost both consumers and the industry a lot of money for no good reason.

According to the following USDA report to Congress:

USDA estimated first-year costs of $305 million for beef producers, $373 million for beef intermediaries (packers, processors, and wholesalers), and $574 million for retailers of beef. For the pork sector, first-year costs were estimated to be $105 million for producers, $101 million for intermediaries, and $93 million for retailers. Total first-year implementation costs were estimated at $1.3 billion for beef, $300 million for pork, and $2.6 billion for all covered commodities (beef, pork, lamb, goat, chicken, fish, fresh and frozen fruits and vegetables, ginseng, peanuts, pecans, and macadamia nuts).

The USDA also reported that consumers had to pay more as well:


Consumer surplus losses for the 2009 COOL rule were estimated to total $5.98 billion in the beef industry and $1.98 billion in the pork industry over the 10 years at a 5 percent rate of discount. For the 2013 COOL amendments, consumer surplus losses were estimated to total $378 million for beef and $428 million for pork.


This contradicts the  idea (popular among anti-GMO activists) that only large corporations were being adversely affected by such laws (a common assumption among GE food opponents, who tend on average to be motivated largely by anti-corporate sentiments). The fact that they’re being struck down also refutes the use of such laws as examples of labeling mandates not contingent on the pretense of some kind of tangible expected benefit. There were economic incentives that, in the case of GMO food labeling mandates, would exist exclusively for the anti-GMO industries. In the former case, those predicted incentives didn’t even play out as planned.

Moreover, the entire argument is just a red herring, because the truth is that voluntary organic and non-GMO labels are market-incentive driven labels, which already exist, and preclude the presence of genetically engineered foods.

Thus, the ideal would be, that we take an approach with GMOs that perfectly parallels the way we handle Halal and Kosher foods. We permit retailers to use Kosher, Halal and GMO-Free as voluntary labels for marketing purposes, because all three are based on ideological belief systems, rather than any scientifically supported bearing on health. This is fair and reasonable.

  • Credible Hulk
  • Edited by Nandu Nandini

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Dennis Kleid · May 16, 2016 at 8:29 pm

As I’m sure you know, many of the so-called “organic” foods contain GE ingredients. Any mismarking as “organic” has no enforcement, thus, the claim of “organic” on the food is on the “honor” system. A national mandatory label “partially produced with genetic engineering” with penalties, would solve this problem. No more fake “organic”, no more fake “non-GMO” etc. Make this scientist proud! I would love to see ALL foods nationwide labeled “partially produced with genetic engineering” and end this debate.

Mandatory GMO Labeling Opposition: Not just for Shape-Shifting MonSatan Cyborg Super-Shills from the future – The Credible Hulk · May 16, 2016 at 10:35 am

[…] of the product because we already do that anyway. I’ve already addressed that line of argument here, particularly the example of Country of Origin Labeling laws (aka COOL […]

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