I am writing in response to the Editorial in the December issue entitled “Label without a cause,”1 which contained factual errors. The statement “Perhaps Vermont's legislators should consider 'may contain' labels for radioisotopes, mercury, cadmium, bird feces, microbial poisons and explosives—ingredients that are present in all foods, albeit at undetectable levels” is wrong on two counts. First, it is obviously not possible to know whether these contaminants are present in food if they are, as you state, 'undetectable'. Second, with cadmium, we do know that it is present in easily detectable levels in non-organic food2, as it occurs in significant levels in mined phosphate fertilizers, in particular from Morocco, the source of most phosphate used in non-organic farming in the European Union and also imported into the USA. A recent global meta-analysis found that overall organic food contains at least 50% less cadmium than non-organic food2.

You also mislead your readers about the levels of genetically modified (GM) organism contamination allowed in non-GM food in the European Union when you claim “in ever-so-stringent Europe, legal technicalities mean that “GM-free” foods can still contain up to 0.9% of GM-derived ingredients.” In fact, the European Union (EU; Brussels) labeling law requires zero GM for food not labeled as GM (the lowest reliably detectable level is assumed to be 0.1%, so 'zero' is below that). There is an allowance for exceptional circumstances—accidental contamination or technically unavoidable contamination—where up to 0.9% GM is allowed before the product must be labeled as GM. This is for one-off, unforeseeable events. Otherwise anything above 0.1% GM must be labeled as GM.

You claim that GM labelling would be costly, but an independent review of published studies for the US Consumers' Union by ECONorthwest3 found that the median cost of labelling in these studies was $2.30 per person per year.

In any event, for those of us living in areas of the world where transparency in food production systems is considered a basic right of citizens, attempts by some in the United States to defend a right of chemical companies and food businesses not to tell their citizens what they are selling them seems bizarre. Free markets clearly cannot work fairly in conditions of secrecy reminiscent of totalitarian states, secrecy that in this case you apparently demand should be enforced by the state in the form of a federal law.