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Prop 37: Just the facts, please

This week an article has been making the rounds in the press under the auspices of an objective policy assessment. "California's Proposition 37: Effects of Mandatory Labeling of GM food" comes out strongly against Prop 37 — the California Right to Know Genetically Engineered Food Act — by deploying a series of specious arguments and unfounded facts.

Published in Agricultural and Resource Economics Update (ARE) from the Giannini Foundation of Agricultural Economics — which disseminates “research results and expert opinion" from UC Davis and UC Berkeley scholars — the piece is being treated as an authoritative source, and has most recently been described by the Los Angeles Times as a "study." 

Misrepresenting Prop 37

The lead authors, Colin A. Carter and Guillaume P. Gruère, are academics and as such could bring empirically-based analysis to bear in this vexed and important issue. But instead of constructing a convincing argument against Prop 37 from their perspective as agricultural economists, Carter and Gruère make false claims that only confuse an already-muddied debate. For example:

 “…there is no doubt that the measure would remove most of the certified non-GM processed foods from the California market because of the zero tolerance criterion for low levels of unintended material.”

This claim is plainly false, as is made clear in the language of Proposition 37.

Food contaminated with or unintentionally produced with GE food is exempt from labeling, including products with “low levels of unintended material.” If a manufacturer wants to be exempted from labeling, then they must be able to provide documentation indicating the source of food production.

The term “zero tolerance” is misleading, as the only requirement of Prop 37 is that a product be labeled if it was produced with the intentional use of GE seed or food. Carter and Gruère wrongly present the food labeling as tantamount to a ban.

It doesn't take a PhD in agricultural economics…

Perhaps we shouldn't be so surprised at Carter and Gruère's diversion from fact. Each has come out strongly against regulation of GE technology in their past publications. 

In a representative case co-authored by Carter and another colleague, they advocated on behalf of Monsanto's GE spring wheat by claiming that American growers lost out on a big opportunity because of anti-GE consumers. In a "policy" piece that presented no agricultural economics research data, they claimed that:

“American growers, caught in the middle between the anti-technology inclinations of some of their largest customers and the developers of new, innovative wheat varieties, were deprived of substantial benefits when Monsanto opted not to follow through with creating and marketing genetically engineered wheat.”1

The reality is that American wheat farmers fiercely opposed the introduction of GE wheat from the get-go, knowing that it would destroy the economic success of their farms. They were not hapless victims of anti-technology forces, but smart and savvy individuals who came together to defend their right to a livelihood.

As North Dakota wheat farmer Todd Leake stated in a House Subcommittee hearing on GE wheat,

"It did not take a PhD in agricultural economics to realize that we were staring in the face of a potential economic disaster."

Like the GE wheat battle — in which farmers ultimately beat back the big money of Monsanto by speaking up for their own economic interests — the Prop 37 issue is fundamentally about ordinary people pushing back against the pesticide industry and asserting our basic rights as citizens and consumers.

One would think that two agricultural economists might be more attuned to the interests of key actors in our agricultural economy — like those of actual farmers and consumers, for instance. At the very least, they might try reading the language of the proposed policy.


1. Miller, H. I. & Carter, C. A. Genetically engineered wheat, redux. Trends in Biotechnology 28, 1–2 (2010).

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