Final INCA Testimony RE CT HB 6798




FEBRUARY 24, 2015

My name is Nick Gardner, and I am the testifying on behalf of the Infant Nutrition Council of America (INCA).  The INCA is an association of manufacturers and marketers of infant formula and other formulated nutrition products, and our members produce over 95% of the infant formula purchased in the U.S.*  We appreciate the opportunity to testify on House Bill 6798.

The primary focus of the INCA and its member companies is and will always remain the health and welfare of infants and young children.  Infant formula is the most highly regulated food in the world and continues to be the only safe, nutritious and recommended alternative to breast milk.  To that end, we respectfully oppose House Bill 6798, which would require labeling on all infant formulas containing genetically engineered organisms.

While this bill may be intended to inform consumers, requiring a label on infant formulas that contain genetically-engineered ingredients will actually confuse and mislead consumers and may jeopardize the safety of Connecticut’s babies.  The proposed labels are unnecessary, provide no public health benefit and may create alarm among caregivers, potentially leading to the use of unsafe infant feeding methods, like homemade formula, that are not recommended by any medical authority and extremely dangerous to infant health.

As is the case with many other foods, some infant formula ingredients can be derived from widely cultivated genetically-engineered crops.  An extensive body of rigorous national and international scientific evidence supports the safety of these ingredients for use in foods consumed by adults as well as infants and young children.  The U.S. Food and Drug Administration (FDA) has concluded that all genetically-engineered ingredients that are currently permitted for use in foods, including infant formulas, are safe and the same in composition, nutritional value and quality as ingredients not derived through biotechnology.  FDA has thus determined that the labeling of foods containing genetically-engineered ingredients is unnecessary, a position supported by numerous regulatory agencies and health organizations, including the American Medical Association.

Consumer interest for information about genetically engineered ingredients is best addressed through voluntary labeling.  FDA has issued clear and logical guidance on the use of label statements on foods that have not been developed through genetic engineering.  Because federal law requires that labeling must be truthful and not misleading, a manufacturer who claims that a product has not been produced using genetic engineering must be able to substantiate the claim.  FDA does require special labeling when the absence of “material” information on a label may pose a special health or environmental risk, or would mislead consumers based on other statements on the label.  As the use of biotech ingredients is not “material” to the safety of a food, these requirements do not apply when genetically engineered ingredients are used.  On the contrary, misunderstandings, misinformation and unfounded fears of biotechnology, combined with the proposed special labels on infant formula, actually have the potential to mislead consumers and cause harm to infants.

HB 6798 is unnecessary and inappropriate given the law that was already passed in Connecticut.  A comprehensive review of the available scientific research on biotech foods indicates no risk to any age group, including infants, from the consumption of biotech foods and ingredients.  That means there is no compelling health, safety or nutritional rationale that supports the notion of labels to disclose the presence of genetically engineered ingredients only in foods for infants and young children.

HB 6798 may drive some caregivers to use alternative infant feeding options, such as homemade infant formula, which are not recommended by medical authorities and may be extremely dangerous to infant health.  Examples of the use and recommendations to use homemade formula as a means to avoid infant formulas containing biotech ingredients, including numerous online recipes, are evident on social media and other online d boards, and widely available to Connecticut consumers.  These recipes have been evaluated and found to be deficient in key nutrients required by federal authorities.  They also recommend the use of ingredients and processes that could introduce dangerous pathogens, while lacking the safe handling and preparation instructions or guidance on the safe storage of the formula.  The American Academy of Pediatrics, FDA and other health organizations unanimously and strongly recommend against the use of homemade infant formula.  The use of homemade infant formula is dangerous to the health of infants, and is a legitimate unintended consequence of this legislation.

In summary, mandatory labeling on infant formula products containing genetically-engineered ingredients is unnecessary, does not provide any benefit to the health or welfare of consumers, and may result in a number of unintended consequences that threaten infant health.  The legality of mandatory labeling requirements of genetically engineered foods is also questionable, as evidenced by the pending litigation in Vermont, and should give this body pause when considering additional biotech labeling legislation.  Further, organic certifications provide consumers with the option to avoid genetically engineered if desired.  For these reasons, INCA strongly opposes House Bill 6798.


* INCA members are Abbott Nutrition, Mead Johnson Nutrition, Nestlé Infant Nutrition and Perrigo Nutritionals.

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