2020 Impossible Foods Application A1186 Soy Leghemoglobin

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Physicians and Scientists for Global Responsibility New Zealand Charitable Trust - make the following recommendations:

(1) Plant-based meat analogue products (PBM) containing the LegH Prep preparation that includes soy leghemoglobin - referred to as LegH Prep - present an altered nutritional and toxicological profile from naturally produced meat and should not be considered a dietary meat substitute.

(2) FSANZ should suspend any approval pending the receipt and review of data needed for a genuine safety assessment. 90-day rodent feeding studies of LegH Prep are required to be supplied.
Approval should be delayed to take account of the European Food Safety Authority (EFSA) conclusion on the risk assessment of SLH as LegH Prep (the genetically modified product undergoing risk assessment), we recommend that any additional requirements following by the EFSA conclusion and implemented as policy by the European Commission - to (i) (ii) and (iii) are correspondingly implemented in New Zealand as policy and/or regulation relating to SLH.

(3) If the European Commission do not recommend that LegH Prep is authorised, that New Zealand observe the rationale given and follow the precedent set by the European Commission

(4) In addition and not withstanding the European decision, PSGR recommends that all commercial products containing genetically modified soy leghemoglobin (SLH) produced from genetically modified
yeast Pichia pastoris, and referred to as LegH Prep - include the following labelling:

i. Not a dietary substitute for meat protein

In addition to including the following legally required statements:

ii. Genetically Modified
iii. Contains soy

(5) It is critical that the population does not interpret that this soy-based ultra-processed product is equivalent to naturally produced meat protein. The finished imitation meat products contain a mixture of ingredients that place the products in an uncertain as well as distinctly different food product category than naturally grown animal meat. The processed food product that is sold to consumers should not be regarded as a meat substitute and must be identified as such. We stress that long-term dietary studies, equivalent to the human lifetime, are required of the formulated product intended for consumption and that in particular, the estrogenic potential of soy should be evaluated at all life-stages.

(6) Lacking long term dietary studies this product cannot be generally regarded as safe (GRAS).

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