Political Ecology of GMOs

A Middlebury blog

A Personal Narrative on Understanding Effects of GMO Labeling on Consumer Behavior

Christopher Batson

Positionality Statement:

Christopher Batson is a graduating Neuroscience major at Middlebury College. He grew up in a largely liberal, white, upper-middleclass suburb of Boston, Massachusetts, however he considers the Green Mountains his home. Christopher’s current interests include alternative economies, rural healthcare, meditation and minimalist living. He also enjoys the outdoors, good food and interesting people. Christopher has a particular passion for asking questions and seeking alternative answers to insufficient ones. As of January 2012, Christopher has been a vegetarian, only consuming meat on a few occasions when the meat was locally and organically raised and slaughtered. Christopher also has no formal education in economics. And if given a higher word limit, he would have loved to compare the differences in regulation practices between the United States and the European Union.


I was interested in the economic consequences of labeling foods containing genetically modified organisms (GMOs). To better understand the economics of food labeling, I investigated the changes in consumer behavior that followed the rbST labeling controversy of milk products and the implementation of trans fats labeling in the US. Both cases occurred in the US and were selected to maximize contextual overlap and provide a better idea of how food labeling alters consumer behavior and US markets. Recombinant somatostatin (rbST) is a growth hormone used to increase milk production in dairy cows. It does this by up-regulating growth hormone levels and preventing declines in milk production that normally occur 60 days after a mother cow has given birth. In the 2000s, several states banned the labeling of rbST-free products (Moulton, 2010) largely due to pressure from the Monsanto Company, who produced the artificial hormone and felt the labeling suggested rbST might be harmful to humans (Monsanto, Milk Labeling). Alternatively, trans fat labeling was the result of contemporary literature that linked high levels of dietary trans fats with increased risk of congestive heart failure (Dept. of Health & Human Services, 2003). Originally, I hypothesized that labeling would not affect sales, believing that opposition to GMO labeling was unwarranted and that GMO labeling would not alter the profits of GM seed and food producers, such as the Monsanto and DuPont Companies. Interestingly, my findings were to the contrary.

rbST Labeling

The case of rbST labeling has received little attention in scholarly articles. The first informative article I found came from the Economic Research Service (ERS), a branch of the United States Department of Agriculture (USDA). The findings of this research supported my hypothesis that rbST labeling had no effect on milk sales (Aldrich & Blisard, 1998). The authors found that the introduction of rbST into the dairy industry in 1994 had “no or minimal effects” on milk demand when comparing sales from 1978 to 1996 (Aldrich & Blisard, 1998). However, reading further into their study, I realized Aldrich & Blisard (1998) only analyzed aggregate milk demand—looking at total milk demand rather than the specific sale types, such as organic, rbST-free and those that came from cows treated with rbST. This prompted me to find studies that analyzed milk consumption by type.

My search produced two studies conducted by independent researchers. Both studies demonstrated that voluntary labeling of rbST-free and organic milk increased quantity demand of rbST-free and organic milk (Kanter, et al., 2008; Kiesel, et al., 2005). These findings indicate that rbST-free labeling impacted consumer behavior by prompting consumers to avoid milk from rbST-treated cows and instead purchase rbST-free milk. Recognizing that most consumers cared if their milk came from cows treated with rbST, I questioned whether or not there were differences in rbST and rbST-free milk.

In 1993, the Food and Drug Administration (FDA) approved the use of rbST and later published a product safety information report, wherein they concluded rbST was safe for human consumption (FDA, 1999).[1] Nevertheless they found significantly different levels of insulin-like growth factor 1 (IGF-1) and incidences of mastitis—infected or inflamed udder tissue—in milk from rbST-treated and rbST-free cows (FDA, 1999). Independent research validates these differences.[2] Collier (2000) addressed another concern: farmers must increase antibiotic use in rbST-treated cows to prevent udder infections. Increased antibiotic use promotes the growth of multidrug-resistant bacterial strains, which can translate to increased risk of disease in humans (Alanis, 2005). The FDA is responsible for regulating trace amounts of antibiotic that are still acceptable for human health. However, in 2008 the FDA tested milk from farms that had repeat offenses for selling antibiotic-tainted milk and found 788 violations of 2.6 million cows tested[3] (Neuman, 2011; Hoffelt, 2011). These findings indicate some level of antibiotic contamination exists in milk products from rbST-treated cows and insinuate FDA regulations and enforcement are insufficient to prevent antibiotic contamination. I would argue that these findings validate the consumer shift away from controversial products that could negatively contribute to their health.

Trans Fats Labeling

In July 2003, the FDA amended its food nutritional labels, requiring “trans fatty acids” to be labeled independently from “saturated” and “unsaturated” fats (Dept. of Health & Human Services, 2003). Starting in 2004, the ERS found a substantial increase in the release of new products claiming to contain no trans fats, this trend continued through 2009 (Rahkovsky, et al., 2012).[4] A similar study found that trans fat levels in new products dropped 73% between 2005 and 2010 (Rahkovsky, 2012). These trends align with retail sales that demonstrated increased success rates for products that have a “no trans fat” claim as compared to those that do not (Rahkovsky, et al., 2012). I noted similar trends in the edible oil industry, where US consumption of edible oils containing trans fats (hydrogenated soybean and palm oils) decreased from 32 pounds per capita in 2004 to 15 pounds per capita in 2010 (List, 2013). These results suggest that, as with rbST labeling, the labeling of trans fats altered consumer behavior and reduced consumption of products containing the controversial fats. Labeling influenced a change in consumer behavior, likely through a change in consumer perception.

When consumers were provided information on the negative health effects of trans fats consumption, the consumers’ perception of risk for heart disease increased when viewing products labeled as containing trans fats (Kozup, et al., 2006). Conversely, when trans fats were not labeled on an item containing trans fats, the consumer did not perceive increased risk for the item (Kozup, et al., 2006). These observations indicate that an informed consumer will alter their behavior and avoid a product that is labeled as containing something they perceive to be detrimental to their health.

Implications and Future Directions

Both case studies demonstrate clear trends that the proposed labeling of GMO-containing products will likely result in decreased sales, as the labeling of rbST- and trans fat- containing products prompted consumers to avoid these items and instead select those that did not contain rbST or trans fats (Kanter, et al., 2008; Kiesel, et al., 2005; Rahkovsky, et al., 2012). In light of these case studies, I began to understand the concern expressed by biotech companies, such as Monsanto and DuPont, that use genetic engineering to produce their food products (Monsanto, Labeling; Monsanto, Milk Labeling). Labeling would likely negatively impact consumer perception of GMO-containing products and subsequently hurt these products’ sales.

Already talk of GMO-labeling has brought attention to the potential risks of GMO-containing products, however these risks might be exaggerated by social hype (Frewer, et al., 2002). Independent research indicates that these perceived risks may be justified by biological differences between conventional and GMO-containing foods (de Vendomois, et al., 2009, Séralini, et al., 2012). If these differences were demonstrated to produce long-term health effects at the same level as congestive heart disease, as in the case of trans fats, I would assume it the responsibility of the FDA to require the labeling of such foodstuffs. I found it interesting that the FDA approved trans fats labeling, but not rbST labeling, despite testing that demonstrated significant differences between rbST and rbST-free milk products (Table 1; FDA, 1999), which according to the FDA constitutes the labeling of both as separate foods (FDA, 1992). Because labeling has such a large impact on consumer behavior (Kanter, et al., 2008; Kiesel, et al., 2005; Rahkovsky, et al., 2012), label regulators, like the FDA, play a large role in determining consumer behavior and food product success. Curiously, the FDA only gives agency to the consumer when selecting a diet with regard to trans fats, but not yet with regard to genetic modification, despite the administration’s policy, which appears to promote a consumer’s “right to know”.[5]

In the rbST-labeling case, consumer demand for labeling overwhelmed the FDA inaction to separately label milk from rbST-free and rbST-treated cows. Consumer opposition was initially so great towards rbST-containing milk products that large retailers like Wal-mart, Kroger, and Dean Foods demanded all of their fluid milk products be rbST-free (Kanter, et al., 2008; Wolf, et al., 2011). More recently, bans on rbST labeling were deemed unconstitutional by a number of district courts on the grounds that the bans violated freedom of speech (Rodriguez, 2011; Moulton, 2010). These decisions acknowledge consumer opposition, but also affect the distribution of profits amongst agro-businesses and how dairy farmers choose to raise their animals.[6] This series of events demonstrates the power of consumer opinion and behavior and suggests a role for voluntary labeling; avoiding formal regulatory agencies that may fail to provide sufficient criteria and enforcement for defining and labeling GMO products. This conclusion may implicate lobbyist activities and private negotiations as the source of inaction by the FDA for labeling rbST-containing products (Pollan, 2012), as consumer opinion appears in support of the measure. The overall impact of consumer behavior on validating rbST-labeling indicates how activists in favor of GMO-labeling might proceed.

In a review of the social and political impacts of rbST implementation in the dairy industry, Buttel (2000) concludes that consumer resistance to controversial foods is paramount in pressuring regulators towards labeling. Buttel (2000) recognizes that consumers need more information to inform their purchase decisions, but he cites declining consumer activism as a major hurdle in supplying such pressure to mandate labeling and thus provide the sufficient information. Pollan (2012) argues for consumers to pressure regulators and producers by “voting with their dollars” and supporting food producers that most align with their beliefs. As a consumer who keeps current with food health topics, I question if such activism is adequate to continue to promote GMO- and rbST-free labeled products.

The failure of regulators to uphold their mission, lobbyists and changes in consumer perception are all factors in the discourse surrounding GMO labeling. However, some of these factors (regulators) have more money and influence than others (consumers), which disproportionately represents available knowledge. These observations emphasize that without adequate consumer opposition to GMO food products agro-food firms will continue to dictate regulators’ practices to ensure uninterrupted sales (Buttel, 2000). The shift of large food suppliers towards rbST-free milk following consumer demand further highlights how persistent changes in consumer behavior can lead consumer opposition efforts in the GMO labeling debate.

Visual: Comparison of labeling factors that influenced consumer behavior.

rbST-free Trans Fat
Initial Introduction 1994 2003
Proponents Consumers1 Consumers2
Opponents Monsanto3 N/A
Enforcement Voluntary Mandatory
Source of Label Manufacturer Manufacturer
Source of Legalization District courts4 Federal government
Market Outcome Decrease in sales Decrease in sales
Legal Status Since 20104 Since 2006

1 represented by the Vermont Public Interest Research Group (FDA, 1999)

2 represented by the Center for Science in Public Interest (Department of Health and Human Services, 2003)

3 As indicated on company website, likely because Posilac (the brand name for rbST) was produced by Monsanto Company.

4 though never made into public law, voluntary labeling was upheld in a number of district courts that concluded labeling bans were a violation of the First Amendment (Rodriguez, 2011; Moulton, 2010).


Aldrich, L., Blisard, N. 1998. Consumer Acceptance of Biotechnology, Lessons from the rbST experience.

Agriculture Information Bulletin: Current Issues in Economics of Food Markets 747, 1-5.


Barham, B.L., Foltz, J., Moon, S., Jackson-Smith, D. 2002. rBST use among U.S. Dairy Farmers: a comparative analysis from 6 states. Agricultural and Applied

Economics Association Annual Meeting, “Technology and Productivity in the

U.S. Dairy Industry”, Long Beach, CA, 2002.


Buttel, F.H. 2000. The recombinant BGH controversy in the United States: Toward a

new consumption politics of food? Agriculture and Human Values 17, 5-20.


Chan, J.M., Stampfer, M.J., Giovannucci, E., Gann, P.H., Ma, J., Wilkinson, P., Hennekens, C.H.,

Pollack, M. 1998. Plasma Insulin-like Growth Factor-I and Prostate Cancer Risk: A

Prospective Study. Science 279, 536-566.


Collier, R. 2000. Regulation of rbST in the US. AgBioForum 3, 156-163.


Department of Health and Human Services. 2003. Food Labeling: Trans Fatty Acids

in Nutrition Labeling, Nutrient Content Claims, and Health Claims. Food and

Drug Administration. Federal Register 68, 41434-41506.


De Vendomois, J.S., Roullier, F., Cellier, D., Seralini, G.E. 2009. A comparison of the effects of

three GM corn varieties on mammalian health. International Journal of Biological

Science 10, 706-726.


Food and Drug Administration. 1992. Statement of Policy—Foods Derived from New Plant

Varieties: Guidance to Industry for Foods Derived from New Plant Varieties. FDA

Federal Register 57, 22984.


Food and Drug Administration. 1999. Report on the Food and Drug Administration’s

Review of the Safety of Recombinant Bovine Somatotropin. Food and Drug

Administration. Updated April, 23, 2009. Available 22 Apr 2013 <http://www.fda.gov/AnimalVeterinary/SafetyHealth/



Frewer, L.J., Miles, S., Marsh, R. 2002. The media and genetically modified foods:

evidence in support of social amplification of risk. Risk Analysis 22, 701-711.


Hoffelt, J. 2011. Dairy meat antibiotic violations lead to FDA milk testing investigation. Agri

View, Wisconsin: 15 Dec 2011.


Kanter, C., Messer, K.D., Kaiser, H.M. 2008. Do rBST-Free and Organic Milk Stigmatize

Conventionally Produced Milk? American Agricultural Economics Association Annual

Meeting, Orlando, FL, July 27-29, 2008.


Key, T. 2010. Insulin-like growth factor 1 (IGF1), IGF binding protein 3 (IGFBP3),

and breast cancer risk: pooled individual data analysis of 17 prospective

studies. The Lancet: Oncology 11, 530-542.


Kiesel, K., Bushena, D., Smith, V. 2005. Do voluntary biotechnology labels matter to

the consumer? Evidence from the fluid milk market. American Journal of

Agricultural Economy 87, 378-392.


Kozup, J., Burton, S., Creyer, E.H. 2006. The provision of trans fat information and its

interaction with consumer knowledge. Journal of Consumer Affairs 40, 163-176.


List, G.R. 2013. Effects of nutrition labeling on edible oil processing and

consumption patterns in the US. Lipid Techonology 25, 55-57.


Monsanto. Labeling Food and Ingredients Developed from GM Seed. News & Views.

Company Website, available 6 Apr 2013 < http://www.monsanto.com/



Referenced as “Monsanto, Labeling”


Monsanto. Milk Labeling—Is Monsanto Opposed to Truth in Labeling? News & Views.

Company website, last updated 16 Jul 2009, available 28 Apr 2013

< http://www.monsanto.com/newsviews/Pages/milk-labeling.aspx>.


Referenced as “Monsanto, Milk Labeling”


Monsanto. 2010. Monsanto Response: de Vendomois, et al., 2009. For the record-Science.

Monsanto Scientific Affairs, 1-13: 16 Feb 2010.


Referenced as “Monsanto, Response”


Moulton, L. Labeling milk from cows not treated with rBST: legal in all 50 states as of

September 29th, 2010. The Columbia Science and Technology Law Review 28

Oct 2010.


Neuman, W. 2011. F.D.A. and Dairy Industry Spar Over Testing of Milk. New York Times,

New York: 25 Jan 2011.


Nutrition Labeling and Education Act of 1990. Public Law 101-535. H.R. 3028. S.

1425 (1990).


Pollan, M. Vote for the Dinner Party. New York Times Magazine, New York, New York: 10          Oct



Rahkovsky, I., Martinez, S., Kuchler, F. 2012a. New Food Choices Free of Trans Fats

Better Align U.S. Diets with Health Recommendations. ERS Report Summary,

USDA: Economic Research Service, April 2012.


Rahkovsky, I. 2012. Trans Fats Are Less Common in New Food Products. Amber

Waves, USDA: Economic Research Service. 20 September 2012.


Rodrigues, C. 2011. Recent Developments in Health Law: Ban on Milk Labeling

Violates First Amendment-International Dairy Foods Association vs. Boggs.

Journal of Law, Medicine & Ethics 39, 96-98.


Séralini, G.E., Clair, E., Mesnage, R., Gress, S., Defarge, N., Malatesta, M., Hennequin, D., de

Vendomois, J.S. 2012. Long term toxicity of a Roundup herbicide and a Roundup

tolerant genetically modified maize. Food and Chemical Toxicology 50, 4221-4231.


Wolf, C.A., Tonsor, G.T., Olynk, N.J. 2011. Understanding U.S. Consumer Demand for

Milk Product Attributes. Journal of Agricultural and Resource Economics 36,



Annotated Sources

Buttel, F.H. 2000. The recombinant BGH controversy in the United States: Toward a

new consumption politics of food? Agriculture and Human Values 17, 5-20.


I found this article early on but was unsure of what to make of its conclusions. Because I was looking at consumer behavior, I knew the consumer was important in influencing which products were successful. However, this article in conjunction with Kiesel, et al. (2005) and Kozup, et al. (2006) helped me understand that “regulation” of GM foods could occur outside of regulatory bodies so long as manufactures self-label and that consumer opinion will ultimately be responsible for pushing such companies as Wal-Mart to discontinue controversial items.


Department of Health and Human Services. 2003. Food Labeling: Trans Fatty Acids

in Nutrition Labeling, Nutrient Content Claims, and Health Claims. Food and

Drug Administration. Federal Register 68, 41434-41506.


This document outlines in great detail the number of factors that were involved in deciding how trans fat labeling would occur. Notably, it includes the reasons for and against the labeling and the health warning. While providing a lot of relevant information, I also found the document interesting as it helped shed light on how the FDA views consumers and what level of responsibility they believe a consumer should have in information and choice. Surprisingly, the FDA seems very open to an informed consumer, despite how that may translate in policy.


Food and Drug Administration. 1999. Report on the Food and Drug Administration’s

Review of the Safety of Recombinant Bovine Somatotropin. Food and Drug

Administration. Updated 23 Apr 2009. Available 22 Apr 2013 <http://www.fda.gov



This source was largely helpful in understanding the differences between fluid milk produced by rbST-treated cows and by conventionally raised cows. The document also raised my awareness to the other actors involved in the rbST-implementation dispute, such as the health care industry. At the end of the report, the FDA states they had no hand in actually researching the differences between milk types rather they reviewed submitted research. This prompted me to look into independent literature that would hopefully have more impartial conclusions or, at the very least, original data that was not produced by the company seeking drug approval.


Kiesel, K., Bushena, D., Smith, V. 2005. Do voluntary biotechnology labels matter to

the consumer? Evidence from the fluid milk market. American Journal of

Agricultural Economy 87, 378-392.


Kiesel, et al. (2005) examined in great detail what Aldrich & Blisard (1998) failed to: how specific milk-type consumption changed as a result of rbST labeling. Thus, this article was paramount in understanding the consumer’s behavioral changes following the introduction of rbST products into the marketplace and the subsequent labeling of rbST-free products. This used the same data as the Aldrich & Blisard (1998) however Kiesel, et al. (2005) controlled for differences in milk type. Additionally, this article reinforced my support for independent research, as these authors demonstrated that labeling does matter, which reinforces GM producers’ decisions to support the ban against food labeling practices, despite not being directly invested in the outcome of the controversy.


Kozup, J., Burton, S., Creyer, E.H. 2006. The provision of trans fat information and its

interaction with consumer knowledge. Journal of Consumer Affairs 40, 163-176.


I appreciated the Kozup, et al. (2006) article as it reminded me that there is more to the consumer’s decision than just labeling. Kozup, et al. (2006) examined how labeling interacts with what consumers believe based on past or newly presented information. These findings reinforced for me the importance of impartial information presentation so that the consumer can best decide what he/she wants to purchase. I also found the fact that consumers changed their preferences following only one information presentation to be a bit alarming and certainly noteworthy for producers, regulators and advocacy groups.

Full list of the Political Ecology of GMOs annotated sources from all papers


[1] It is noteworthy that the data for this analysis was provided by the Monsanto Company, the developer of the commercial form of rbST, Posilac (FDA, 1999).

[2] Concerns from many groups, including the Vermont Public Interest Research Group, questioned the safety of rbST in milk for infants and children; particularly as IGF-1 is naturally found in humans and increased levels of the hormone could have adverse effects on human development (FDA, 1999). Several studies demonstrated correlations between higher blood IGF-1 levels in humans and increased risk of prostate and breast cancer (Chan, et al., 1998; Key, 2010). The FDA dismissed these findings on the grounds that one would need to consume at least 1.5L of milk per day to observe said increases in blood IGF-1 concentrations; increases that were only “minute” in nature and that would dilute into the naturally produced IGF-1 in circulation (FDA, 1999).

[3] However, it was not differentiated as to whether or not these 788 violations were from rbST-treated or rbST-free cows (Neuman, 2011).

[4] 2009 was the last year of available data. As well, I use the words “claiming” and “report” as manufactures are responsible for their own labeling (Public Law 101-535), thus unless tested by the USDA under the suspicion of a violation, there is no third-party verification of nutrition reports.

[5] In the FDA’s report on Trans Fat, the administration explained their reasoning for the new label, “consumption of trans fat results in consequences to the consumer. Consumers may increase or decrease their risk of [congestive heart disease] based on the level of trans fat in their diets…consumers must know—and the agency believes in material information that the reasonable consumer should know…” (Dept. of Health & Human Services, 2003). This wording closely matches the language used by many pro-GMO labeling groups that advocate for an informed consumer, such as the California “Right to Know” campaign (carighttoknow.org).

[6] In 1998, it was estimated that 30% of dairy farmers treated their cows with rbST (Alrich & Blisard, 1998); this value is a USDA registration estimate. This value declined to around 13% in 2002; this estimate is based on data collected from 6 US states (Barham, et al., 2002).

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