The technology of DNA barcoding has been around for several years. In short, it is the use of DNA sequence analysis to provide a unique identifier for biological species, whether animal, plant, etc. The idea is that the use of a short, standardized sequence of DNA from a large genome is enough to create an individually unique tag that can be used to trace and to identify biological origin. Traditional taxonomy (e.g., Darwin, the classification of species) relied on the use of morphology (visual, structural analysis of an organism). Modern genetic science has now provided an efficient and precise measurement to speed and systematize species identification using a DNA signal. One use of this technology relates to the integrity of the food supply (potential food fraud) – where claims of origin (what kind of animal, fish or plant?) matter not only for commercial purposes, but for public health. Here’s a report from Oceana on the prevalence of seafood fraud. Estimates are that 84% of the American seafood supply is imported, and studies have shown as much as 70% mislabeling of some popular species. That’s why the recent FDA endorsement of DNA barcoding for the identification of seafood species represents a convergence of the technological promise with the regulatory mechanisms charged with oversight of the food supply. By offering products which have been subject to DNA barcoding verification, suppliers and restaurants will be able to represent that their menu offerings have been genetically verified in this manner. The effort by the FDA to promote voluntary genetic verification of food origin is likely to increase market-based disincentives to mislabel food and deceive consumers.
This development at the FDA also dovetails with a growing attention on the part of the government to what is called “economic adulteration” – the deliberate alteration of food and/or drugs undertaken for economic gain (weighing irregularities, substitution with cheaper ingredients) – this is a theoretical labeling of conduct that naturally arises as a consequence of an increasingly complex supply chain design in modern commerce. Here’s a recent analysis by the Government Accountability Office (GAO) of the problem, where it recommends more focus by the FDA on the circumstances where the public is likely to be deceived regarding product integrity – not because of deliberate sabotage or negligent manufacturing practices, but by conscious, economically-driven rationales. While motive is legally irrelevant to whether a food supplier is engaged in deceptive practices, this theorizing does help by conceptualizing the broad range of actors that might be involved.