The great “Impossible Burger War of 2018” has been ongoing among vegans since earlier this year when Impossible Foods announced that they had tested on animals their new-to-the-market ingredient, soy leghemoglobin. (We will address the logistics of why they did those tests further down in this article because terms get technical and your eyes will glaze over at words like “GRAS designation”, “FDA no questions letter”, and “safety of SLH for consumption.”) Anyway, this new product is said to emulate heme, a naturally occurring iron-containing molecule in blood that carries oxygen. Heme is what has given the Impossible Burger the look, taste, and texture of real meat from an animal, arguably something no other product on the market comes close to.
So here’s where the majority of the argument comes into place. Animal rights activists have a hard stance against conducting tests on animals- and rightly so. It’s common knowledge that animal tests are cruel, archaic, and don’t yield the same results in animals as they do in humans. So you might be asking then, HOW could a vegan support a product that was tested on animals? That’s where we get into the gray area of this situation.
The problem is, nearly every single ingredient that you eat has been tested on animals and many in the not-so-distant past. We’ll use Beyond Meat as an example because many of the arguments focus on their burgers in direct competition with Impossible Burgers. We can’t tell you how many times we’ve heard “well Beyond Meat doesn’t test on animals and their burger is better.”
Beyond Meat states on their website that they have “never tested our products or ingredients on animals. Our scientists are focused on identifying existing plant-based ingredients that emulate the properties of meat. For example, to achieve the beefy red color of our Beyond Burger, they tested hundreds of vegetables and fruit extracts, before settling on a combination of beet powder and annatto.” Guess what? Annatto has been tested on animals. The second ingredient in the list for their burger patties is pea protein isolate- also tested on animals. So, they may not have funded the animal tests, but they’re profiting off of and using ingredients that have undergone animal tests.
In fact, it’s nearly impossible to eat an entirely vegan diet without consuming products that have been tested on animals. For a full list of ingredients with GRAS (Generally Recognized As Safe) designation (tested on animals) click here.
Let’s get one thing straight- we love the Beyond Burger and their products. We eat them all the time and have promoted their products since day 1. However, we also see the benefit of innovation with new foods that will ultimately end animal suffering and the destruction of our environment- like products made with heme might be able to do. Companies like Impossible Foods and Hampton Creek (both with vegan CEOs) are advancing the direction of plant-based foods in a meat-heavy world.
Here’s where it gets a little boring and technical, but stay with us here because the following is very important.
The FDA says that if a company has created a new ingredient, it’s up to that company to determine whether or not it is safe for consumers. Hopefully, you have some red flags waving around your head at this point! In fact, companies don’t ever have to submit data to the FDA about a new ingredient and many of them simply don’t (also terrifying). However, if you want to participate in the FDA’s food safety program (which really, all companies should be required to do- but that’s another topic altogether), the company has to put together a GRAS designation. GRAS is generally a scientific paper that rigorously analyzes available data to determine an ingredient’s safety. Once the company completes their GRAS, they submit that to the FDA. If the FDA approves their GRAS, they receive what’s called a “no questions” letter. This “no questions” letter will ultimately determine the success of your product as it states the FDA has no questions that your product is safe to consume.
You see, major retailers like Walmart, for example, require a company to provide this “no questions” letter in order to sell their product in their stores. The letter is also important to have if you want to sell your product internationally. Many countries look to the FDA to deem products safe for consumption and many won’t distribute a product to consumers in their country without the “no questions” letter.
Seems pretty straightforward.
Impossible Foods attempted to submit their GRAS designation without testing on animals in 2015, but the FDA came back and said Impossible Food’s arguments did “not establish the safety of SLH for consumption, nor did they point to a general recognition of safety.” That’s their submission WITHOUT testing on animals. So, Impossible then conducted animal tests in order to prove to the FDA that heme is safe for consumption.
Impossible didn’t have to submit a GRAS designation at all, but they wanted to ensure that their product was safe for consumption and wanted to provide transparency to the consumer. Under the 1938 Food, Drug and Cosmetic Act and the 1958 Food Additives Amendment, the FDA allows food companies and their hired consultants to internally test and determine a GRAS designation of a potential new additive all on their own. They can start using it without getting approval from the FDA or even notifying the agency. The FDA only steps in after the fact if problems arise.- HOW SCARY IS THAT?! This is why Impossible has been able to sell their burger so far without having FDA approval.
We also want to point out that in order to get the “no questions” letter from the FDA- you must test on animals, even though the FDA doesn’t explicitly come out and say that. There has been NO instance where that letter has been issued for a food ingredient without animal testing data. If there has been- then please let us know down below in the comments.
Bruce Frederich, former PETA VP and head of the Good Food Institute explained it this way “So while some might argue that testing is not legally required, the alternative is that companies may be unable to sell their products to some major U.S. retail outlets and internationally, and it could result in the product not being allowed to be sold at all, thwarting the goal of replacing animals in the food system.”
The good news is, the animal tests were not in vain and in July 2018 Impossible Foods received their “no questions” letter from the FDA and can now distribute their product on every market across the globe. Because that’s what this is all about right? Plant-based food on a global level.
Lest we not forget about the tragedy that unfolded with Hampton Creeks product- Just Mayo, where the FDA issued a recall stating the product was mislabeled, contained undeclared ingredients, and posed salmonella and listeria threats. What we need to remember is the meat and dairy industry will go to great lengths to destroy plant-based meats, cheese, and milk. This is a perfect example of that and it’s no wonder why Impossible Foods chose to go through the FDA approval process in order to avoid a scandal like that with their product. And while we’re on the subject of Hampton Creek, we’d like to point out that their new “Just Scrambled” egg, has an ingredient- mung bean isolate– that they tested on animals, yet there has been radio silence about this from the vegan community.
We’ll also argue that the development of lab-grown meat, a development that even PETA has been advocating for and investing in, uses animal cells and will be tested on animals if they want to receive their “no questions” letter from the FDA. If PETA can see the need to use animals to ultimately create a more compassionate world free from animal suffering and environmental devastation, then why can’t everyone come to that same conclusion?
So, the issue isn’t black and white and that no matter how “ethical” we might think we are as vegans, we have to remember the end goal is to end animal suffering and the destruction of our environment. With innovative products from Impossible Foods and Hampton Creek, we are one step closer to that end goal. We should be focusing our anger towards the FDA, urging them to accept non-animal tested methods in order to receive a “no questions” letter, not attacking the companies who are just following the regulations put in place by the FDA.
THANK YOU for this important, enlightening article. “Burgergate” (remember Watergate?) has consumed too many vegans who don’t grasp the world we live in enough to realize that the fault lies with the FDA for allowing animal testing. I’ve shared this article and will keep it for future reference.
Thank you for letting us know how you feel about the article! We will continue to put out additional information as we learn more through our research.
I’m concerned with how the animal testing went (obviously the final product went well) but did any animals actually get harmed or die in these tests? Also, could they have tested on humans instead?
188 rats were used in the tests. They were fed the burger and at the end of the tests, were killed. The FDA has never approved GRAS standing for an ingredient without animal testing. Impossible first submitted their research without the animal testing and they were denied. We need to redirect our focus to the FDA because they’re requiring outdated animal testing methods. And no, they do not allow for testing on humans.
So it’s pretty obvious that Impossible is directly responsible for killing 188 animals. That is just plain not acceptable. Simple enough?
That’s the whole point, it’s not simple at all. They’ve saved countless animals and will continue to do so as people get more on board with veganism. They were following the law and it’s shown to have paid off.
[…] leads us to the controversy surrounding the Impossible Burger, which started the uproar across the vegan community for creating a new plant-based ingredient, soy […]
The procedure is complex; the ethics are simple: don’t kill animals. It doesn’t matter how you obfuscate the situation with claims of complexity and speculative positive outcomes, the fact is, they had a choice and chose killing those poor rats.
They chose to make a product that would eliminate the suffering of millions of cows and help save our planet. Unfortunately, our laws still dictate archaic animal testing methods in order to sell a product in grocery stores and internationally. It is not simple. They sacrificed a few to save millions. It’s the most realistic “meat” product on the market right now and the sheer fact that it’s in one of the biggest fast-food chains means everything they had to do was worth it. If you read the article, you’d know that nearly every single food item that you eat has been tested on animals. Our focus should be towards the FDA who requires the testing in the first place.
They chose to make a product that would eliminate the suffering of millions of cows and help save our planet. Unfortunately, our laws still dictate archaic animal testing methods in order to sell a product in grocery stores and internationally. It is not simple. They sacrificed a few to save millions. It’s the most realistic “meat” product on the market right now and the sheer fact that it’s in one of the biggest fast-food chains means everything they had to do was worth it. If you read the article, you’d know that nearly every single food item that you eat has been tested on animals. Our focus should be on the FDA who requires the testing in the first place.
No, they chose to make THEIR product, which they have added to a string of meat analogues that goes back . . . well, the Chinese had tofu 2,000 years ago. I understand your point and I’m not going to argue with you any more, especially about the Government (after all, didn’t THEY sacrifice a few to save millions by firebombing Dresden?). I’m sticking with my original point — in my opinion, Impossible Foods made an unethical decision, regardless of the reasoning behind it.
We NEED new products!!!! Until the Impossible burger, nothing on the market even came close to mimicking meat. We have not turned the world vegan with the products that we already have. We should be encouraging companies to innovate and use food technology in order to get the world to go vegan. No one is impressed with a tofu scramble, but the mung bean protein used in JUST food’s egg, is a GREAT step in the right direction. Mung beans have been used for centuries, but our FDA requires new products to be tested on animals. It’s a necessary evil in the fight to end animal suffering. I’d recommend reading this article: https://veganvoyagers.com/2019/04/a-new-era-of-veganism-and-the-importance-of-innovation-in-food-technology/
Bill – what would you rather happen? Have hundreds of animals killed OR have millions of them killed? Given the laws, you have to choose one. Which one is it? Given your argument – seems like you’re choosing the later which clearly contradicts your morals.
Just because in modern society it is almost impossible to survive without consuming things that have previously been tested on animals, does not mean one should use that as an excuse to continue the trend. Beyond burger use previously tested ingredients, and so could impossible burger have done. I don’t agree that it was worth those animals lives for the sake of us having yet another burger to choose from when as you rightly say there are hundreds of pre-tested ingredients. We should not be supporting companies who continue to do so moving forward.
Only using the ingredients that are available to us means that we have created a product that has turned the world vegan…. which we have not. If we can’t innovate in our food and create new ingredients that will help to make people stop eating animals, then we’re failing the animals. We’ll direct you to this follow up article: https://veganvoyagers.com/2019/04/a-new-era-of-veganism-and-the-importance-of-innovation-in-food-technology/
So when the next company comes out with a vegan product that uses heme that was produced by Impossible, I fully expect you to lay into them with the same fervor you have against Impossible. But given your statement about Beyond, my guess is you will champion that new product as “the next big thing” to happen to veganism even though it wouldn’t have been possible without Impossible’s decisions.