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.