GMA is the world's largest association of food, beverage and consumer product companies. The organization applies legal, scientific and political expertise from its member companies to vital food, nutrition and public policy issues affecting the industry. One such issue, which we are addressing today, is modern food biotechnology.

Under discussion today are the regulatory frameworks for biotechnology and consumer involvement in related issues. Much of the discussion has focused on the labeling regulations of food and ingredients derived through biotechnology. But I thought I might step back and briefly look at food regulations and why we label foods.

US food laws were derived from English statutory and common laws where the concerns about deception and adulteration were initially addressed. Adulteration of food became a problem in the 18th Century. Bakers were accused of adding alum, lime, chalk and bone ash to reduce ingredient costs or give the appearance of higher quality. Ordinances were established throughout cities in the United Kingdom to require bakers to have their own seals and undergo monthly examinations for weight and quality. Deception in bread preparation was prohibited and each loaf of bread was marked in order to identify the baker.

This was somewhat the beginning of regulated labeling for food products.

So why do we label today? For many of the same reasons.to provide consumers with accurate and reliable information to enable them to make informed choices in the marketplace.

Also, labels are needed to provide important health or safety information to consumers as in the case of allergic individuals.

Now let's focus on labeling in the U.S. for foods derived from biotechnology. Because we have so much variety and choice in the foods available in the United States, we rely on the Food and Drug Administration's labeling system to help ensure our food is safe to eat, as well as provide us with guidance on nutrition and safety. Without this science-based guidance, it would be next to impossible to make sensible food choices. In fact, a recent survey released by Vice President Gore's National Partnership for Reinventing Government showed that most shoppers trust FDA to ensure food safety in the future.

But the recent debate surrounding food biotechnology has some consumer groups pushing for mandatory labeling on foods developed or containing ingredients derived through biotechnology. Why? Because they believe consumers have a right to know what is in their food. We agree, but the answer may not lie in mandatory labeling.

Under FDA's existing policy for biotech foods, labeling is required when there is a significant compositional change in the product, when the food is nutritionally different from its traditional counterpart, or when a potential allergen has been introduced. Every food product on a grocery store shelf must meet the law's requirements for safety and labeling. But federal regulation has wisely never required that food labels describe the plant development process by which food is produced.

The FDA has the right to seize a product from the market if the product is deemed unsafe or misbranded. Safety risks or concerns must be addressed before any product is introduced into the marketplace.

Mandatory affirmative labeling of biotechnology ingredients may have the unintended and unfortunate consequence of misleading consumers into thinking that biotech products are unsafe in some way or have different health effects. This could lead to the kind of consumer confusion that food labels are designed to avoid.

The existing FDA labeling policy allows for voluntary labeling statements that are truthful and not misleading, providing a comprehensive framework for consumer protection and choice.

Some consumers prefer organic foods others may want to purchase foods that are not produced through biotechnology. Manufacturers should be able to satisfy these preferences and deliver products and information that best satisfy consumer choice.

Manufacturers want to communicate information about the benefits of food biotechnology. There are sources of information that are far better and more comprehensive than food labels readily available to consumers. Through focus groups and telephone surveys, consumers have indicated, "it would be better for food manufacturers, governments, health professionals and others to provide more details through brochures, websites and toll-free numbers."

We support the right of manufacturers to make claims for their products, including claims about products made without the use of biotechnology. It is important that such claims do not mislead consumers about the composition, safety, or quality of the labeled product or falsely imply that other products are less safe. We are recommending that the U.S. Food and Drug Administration (FDA) develop criteria for claim accuracy and substantiation in relation to voluntary labeling of 'non-biotech' foods or food ingredients."

On issues of safety, the FDA, the U.S. Department of Agriculture and the Environmental Protection Agency have regulatory jurisdiction over biotechnology.

The issues of safety has been thoroughly addressed, not just in the United States by these organizations, but by several, including:

World Health Organization Food and Agriculture Organization OECD The National Institute of Health The American Medical Association The American Dietetic Association

More than 1,500 scientists, including two Nobel Prize winners, have endorsed this technology as safe, environmentally-friendly and a useful tool to help feed the developing world.

As we move along in this brand new century, it is crucial that we enter a dialogue on food biotechnology that is rooted on a firm foundation of factual information and sound scientific data. This foundation is important so we may engage in thoughtful and civil dialogue with many of the questions and concerns raised by people from around the world.

• Alliance for Better Foods - Benefits of Food Biotechnology