Food, nanotechnology and labelling

Nanotechnologies have a wide range of potential food applications. Possibilities range from enhancing the flavour, texture and nutritional quality of processed foods, to the use of sensors to monitor food safety. However, there are significant questions about how risks should be assessed and regulated; how nano ingredients should be labelled; how open the food industry should be about its development of nanomaterials; and the role of public dialogue about whether these promised benefits are needed and the relative value of alternative approaches.

Along with the promise of technological benefits come questions about safety, desirability and unintended consequences. The European Union has addressed some of these questions during 2011.

  • The European Food Standards Agency (EFSA) has published guidelines that acknowledge that there may be specific risks posed by nanomaterials and set out a ‘case-by-case’ approach to risk assessment. You can read the EFSA guidance here.
  • The European Parliament and Commission have agreed rules that require the labelling of any engineered nanomaterials in food. Here is the final version of the new regulation.

However, some significant questions remain, such as:

  • How will the labelling rules be implemented? Will this give consumers the information they need to make informed decisions?
  • Should governments and regulatory agencies require the food industry to be more open about research they are doing on nanotechnologies? This might help regulators stay ‘ahead of the game’ rather than having to catch up with developments. One idea is that there should be a mandatory register of nanomaterials being developed.
  • What role should wider public debate play in informing technology choices made by business and publicly funded research?

We very much hope that this debate about the potential applications of nanotechnologies for food will raise questions about the appropriate regulation and support for this technology. In particular, we hope that this debate will generate research questions to help clarify what steps are needed in order to ensure food technologies are developed and applied in the public interest.

Created by Howard Dickins

Created by Howard Dickins

There is a wide array of potential applications of nanotechnology in the food industry. These applications range from using nano-sized particles to reduce fat content without losing taste, to nano-sensors for continuously monitoring food to detect presence of dangerous bacteria or other contamination. You can find more examples in the UK Food Standard Agency’s Bite magazine.

Please feel free to comment

11 comments:

  1. Henk wrote:

    What is know about how consumers read labels? Does it really help to have labels?

    Datum: 2. December 2011 – 15:11 Uhr - Reply
  2. Marga Jacobs wrote:

    At the seminar on health and environment of nanotechnology applications that we organised during our project on nano-technology, we surveyed our participants to see what follow-up research questions they thought should be addressed. I summarize a number of them below, and hope some students and researchers could do some study on these, even though they are probably not specific to your focus on food products containing nano particles:
    1. Is labelling possible if there is no agreement on the definition of a nano particle?
    2. Who owns the risk? Producer, government, consumers?
    a. Are companies insured for potential health effects of their products?
    b. Should consumers be informed of the presence of nanoparticles in a product?
    c. How sensitive or non- sensitive is it for a company to publish information on the nano particles in its products? What is known about openness of companies?
    d. How does labelling interfere with laws on product liability; does it exclude companies from their responsibility?
    FYI, our organisation commissioned a study on product liability before through the Science Shop in Tilburg, Netherlands, and their Law-Faculty concluded that producers would not be liable for negative effects of nano particles if these effects are unknown (like industry was not liable for asbestos damages -nor for soil pollution- before the mid70s, because in those days negative effects were still unknown). LINK (in Dutch) http://www.tilburguniversity.edu/nl/samenwerken/advies-en-dienstverlening/wetenschapswinkel/onderzoek/afgerond/321stroetenga/
    e. Who has the duty/task to inform people?
    3. Can nano particles use or production be regulated in the environmental permit of a factory or laboratory (waste, uncertainty, etc.)?
    4. Could we ban products with nano particles from the market? What would be the consequences?

    Datum: 18. January 2012 – 19:42 Uhr - Reply
    • Rob wrote:

      Hi Marga,

      Great set of questions - many thanks for passing these on - they raise a lot of interesting issues.

      An important question is who has the duty to inform consumers and the wider public about what nanomaterials are being used in products.

      The new EU regulations will require foods containing engineered nanoparticles to be labelled - but without extra information and explanation will labels alone be enough to guide consumer choice and public debate?

      In the USA the Project on Emerging Nanotechnologies led the way a few years ago by bringing together information about products making use of nanotechnologies (but this depended on information provided by the manufacture). See: http://www.nanotechproject.org/inventories/consumer/
      In the UK there was an pilot website that was designed to help consumers put information on nanotechnology in context: http://www.nanoandme.org/home/
      Does anyone know of other ideas for providing context, further information, or platforms for discussion that could work in addition to the minimal information contained in a label?

      Datum: 7. February 2012 – 23:39 Uhr - Reply
  3. Hilary Sutcliffe wrote:

    My recent conversations with retailers and food companies in Europe about nano and food show a precautionary approach for the many reasons outlined above. Which is to be applauded. This is mainly because they are so nervous about public reactions, but also because the benefits have to be real and clear.

    Personally speaking, and also in dialogue with retailers, the benefits which are much vaunted, may not really appear much like benefits to many people. ‘More processing of processed food’, big deal. I think when real products start to be discussed with real benefits to people, then the dialogue can become more constructive. At the moment all I see are phrases like ‘nanotechnology is set to transform the food industry’, with no substance. A major UK retailer said to me ‘for goodness sake don’t bring me another nano salt - the benefits are not big enough for me to carry the hassle of it being nano without a lot more work on safety and a real differentiation.’ Similarly more additives, enhancing textures, they don’t look much like real benefits for the consumer, especially given the potential for uncertainties. For example, the much vaunted fat free fat does to the untrained eye look very like many many products on the market already. How much better would the taste be and what would be the downsides (remembering Olestra!?) Even some of the major food research agencies I speak to are hard pushed to come up with anything really transformational to make the nano hassle ‘worth it.’ Except nano silver in packaging, which again has its own potential problems.

    Re labelling, like many others I am in two minds. If it is an ingredient, it should be on the ingredients list like everything else, if it is some form of hazard label then why is it on the market if there are real uncertainties? But I do think that the public deserves more information on nano than is currently available if there are to be products on the market. Our website for the public http://www.nanoandme.org is out of date now as we were unable to generate funds beyond the pilot, but was designed to put the whole debate in context and present independent information, in a helpful way, for the public to make up their own mind.

    Our work at the moment, being launched shortly, focuses on what different stakeholders (the public, investors, retail buyers and ngos) expect of companies, particularly in terms of transparency,engagement and assessment of safety and then considering how best companies can respond. We believe that if companies can be inspired and motivated to be more open and engage better and earlier with the public about these areas we will begin to see more useful products which will really enhance our food, rather than hype from academics and research agencies with little underpinning substance.

    Datum: 8. February 2012 – 10:18 Uhr - Reply
  4. jackstilgoe wrote:

    Labelling is a really interesting issue, from the perspective of someone interested in Responsible Innovation. On one hand, it would seem to be a democratic act, an admission of both uncertainty and humility. It should empower consumers to make decisions that regulators are unable to act upon. But is it an abdication of regulatory responsibility? As a consumer, I do not feel in the slightest bit empowered by a label that informs me about something where my knowledge is vastly inferior to that of regulators themselves. I read it as a policy move to pass the buck onto me.

    Datum: 8. February 2012 – 12:15 Uhr - Reply
  5. Sue Davies wrote:

    The research that we have carried out at Which? around nanotechnologies and food is consistent with attitudes towards other novel food technologies:
    http://www.which.co.uk/about-which/what-we-do/which-policy/science-and-technology/nanotechnology/consumer-attitudes/. People expect to be able to make an informed choice about what they are eating. The requirement within the EU Food Information Regulations recognises this as nano ingredients will have to be indicated in the ingredients list. Labelling is not, however, an excuse for failing to address wider issues around public engagement with nanotechnologies or the need to close regulatory gaps to ensure that there is approval before products go on the market. It should not have to be up to consumers to carry out risk assessments in the supermarket. It is essential, therefore, that the novel foods regulation is also revised to take account of this.

    Datum: 8. February 2012 – 14:16 Uhr - Reply
  6. Rob Reid wrote:

    I think the comments made by Jack and Sue are very important in this debate. Arguably there has been a lack of engagement between industry and consumers on what nanotechnologies are , what benefits they could bring and where there are uncertainties over their impact on health and the environment. As a result I believe that to begin labelling products without addressing this knowledge gap will result in consumer confusion rather than empowerment. Any moves to label products must therefore be fully backed up by clear, accessible and easily understood information for consumers. Ensuring that this information is provided in an unbiased and balanced way could be another challenge altogether!

    Datum: 9. February 2012 – 13:03 Uhr - Reply
    • Dane Comerford wrote:

      Some great points brought forward. There are various lessons connected to consumer goods packaging that we could try and digest. They range from tobacco and alcohol to shampoo and that infamous McDonald’s cup of coffee that wasn’t labelled as ‘hot’. Whereas we all acknowledge smoking is not a healthy activity, is still happens, and while coffee should be hot, it could scald you. Regulatory product labelling can be seen as an industry get-out card, but it does indeed inform the consumer of what they might be, well, consuming.

      There can be a barrage of information on a packet stating its contents ‘contains a source of’ vitamin D (good for calcium absorption and bone growth) or maybe it ‘contains a source of’ sulphites (not so good for people with asthma.) Use By dates and BBEs, colour wheels, GDAs or RDAs, and nutrition labels on the front of packaging all tell the consumer - at the point of sale - what this stuff is. The vegetarian or weight-conscious might take a careful look and do some mental arithmetic, but for the most part, these codes are possibly overlooked, but they’re there if we need them.

      The issue around Sodium Laureth Sulfate (SLES), a common ingredient in the bathroom cabinet is much more subtle: packaging will label SLES as a surfactant ingredient in toothpaste, shampoo or washing-up liquid and leave it there. People who are concerned about the irritant effects or potential liver problems avoid it, much in a similar way to those people who choose to buy non-bio washing powder. There are also reports that SLES is commonly contaminated with low levels of dioxane, a probable carcinogen, but dioxane is unlikely to be listed on account that it is present in small quantities and is an unintended ingredient. It’s here where the nanomaterial discussion is at: what are the unintended consequences of an unintended ingredient? I wonder what we can learn from product information history and how consumers interpret and use that information.

      Datum: 10. February 2012 – 13:44 Uhr - Reply
  7. hassanain wrote:

    risks of treating food with nanotechnology:
    1.it may interferes with the normal metabolism of certain food,because we know that some
    of food when degraded by our enzymes some of its compounds will be a precursor for other
    metabolic reactions, so my question is has the engineered food the same nutritional value as
    the normal food or not?

    2.could enzymes recognize the active sites in food composition?
    3.carcinogenicity is a big question,and nanotechnology will treat or be a man-made carcinogenic?

    Hassanain
    IRAQ-BAGHDAD

    Datum: 23. March 2012 – 13:28 Uhr - Reply
    • Rob Doubleday wrote:

      Hassanain,

      These are good questions. To some extent they are covered by the ‘case-by-case’ approach taken by the European Food Safety Authority Risk assessment guidance (www.efsa.europa.eu/en/efsajournal/doc/2140.pdf - and see discussion here: http://www.food.gov.uk/safereating/nano/).

      An excellent recent report by the Food Ethics Council says that risk assessment is not enough because “risk-based approach can obscure how ethical issues fit into decision making, (like animal welfare, social implications environmental impacts, consumer choice)”. You can read more about the report here: http://www.foodethicscouncil.org/node/668

      Rob
      University of Cambridge

      Datum: 19. April 2012 – 10:37 Uhr - Reply

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