Miljø- og Fødevareudvalget 2024-25
MOF Alm.del Bilag 359
Offentligt
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Briefing Document for European Policymakers: Do Not Authorise the Impossible Burger
Introduction
The ‘Impossible Burger’, composed of a genetically modified (GMO) meat substitute, would be
the first GMO foods authorised in the European Union for many years. Despite its claims of
sustainability and safety, the product relies on untested GMO technology, lacks rigorous safety
assessments, and promotes a false narrative of environmental benefits. Healthier alternatives
for sustainable diets already exist for consumers in the EU which do not depend on highly
processed foods such as genetically modified substances.
We urge EU policymakers to:
1.
Reject the marketing and authorisation
of the Impossible Burger in the European
Union.
2.
Prioritise proven, sustainable alternatives
such as agroecological farming and locally
adapted plant-based diets.
3.
Strengthen transparency and safety standards
for GMO products to protect public
health and the environment.
The Impossible Burger is not a solution to the climate crisis or food security—it is a partially
tested product that conflicts with the EU’s commitment to the precautionary principle and
sustainable food systems.
What is the Impossible Burger, and why should it not be authorised in the EU?
The Impossible Burger is a lab-made meat substitute designed to mimic the taste, texture, and
appearance of real meat. Its key ingredient, soy leghemoglobin (LegH Prep), is produced using
genetically modified yeast. This product is classified as both a GMO food and a food additive
under EU regulations
1
. The burger and its assessment by the European Food Safety Authority
EU regulation on GMO 1829/2003 and on food additive under regulation 1331/2008:
https://food.ec.europa.eu/horizontal-topics/committees/paff-committees/novel-food-and-toxicological-safety_en
and https://food.ec.europa.eu/horizontal-topics/committees/paff-committees/genetically-modified-food-and-
feed-and-environmental-risk_en
1
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(EFSA)
2
fails to comply with Precautionary Principle and General EU Food law
3
: The EU’s Food
law and the precautionary principle mandates that only safe products can be marketed in the
Union. The Impossible Burger fails to meet these standards.
Authorising this product is unnecessary and would set a dangerous precedent for untested
GMO foods in the EU.
How is the Impossible Burger made?
The Impossible Burger’s "bleeding" effect comes from a molecule called "heme," which is
produced by inserting soybean root DNA into genetically modified yeast. This process created
46 unexpected proteins, none of which were fully tested for safety
4
.
Main gaps in the safety assessment
The safety assessment of the Impossible Burger is riddled with gaps and flaws:
1.
Not sufficiently Untested for Human Consumption:
The key ingredient, LegH Prep, has
no history of safe use in food. Animal studies have shown adverse health effects,
including anemia, kidney issues, and blood clotting problems
5
. These findings were
dismissed without valid scientific justification.
2.
Unknown Contaminants:
LegH Prep contains 35% unidentified and untested proteins
from the GM yeast, raising serious safety concerns
6
.
3.
Misleading Safety Data:
Safety assessments were conducted using an older, less refined
strain of GM yeast, not the one intended for commercial use
7
. This undermines the
validity of the safety conclusions by the European Food Safety Authority claims.
8
2
https://www.efsa.europa.eu/en/efsajournal/pub/9060
https://eur-lex.europa.eu/eli/reg/2002/178/oj/eng
https://theecologist.org/2017/aug/15/does-impossible-burger-feed-our-desire-avoid-necessary-choices
3
4
5
https://food.ec.europa.eu/document/download/d2f34894-49f0-4c05-aa20-
4365f47bd135_en?filename=gmo_pub-cons_comments_2024-9060_en.pdf
https://food.ec.europa.eu/document/download/d2f34894-49f0-4c05-aa20-
4365f47bd135_en?filename=gmo_pub-cons_comments_2024-9060_en.pdf
6
7
8
https://www.efsa.europa.eu/en/efsajournal/pub/9060
https://gmwatch.org/files/Comments-on-EFSA-opinions-on-soy-leghemoglobin-12-12-24b.pdf
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5.
Use of Wrong Strain:
Safety data was based on an outdated strain of GM yeast, not the
one used in the final product. This makes the safety claims unreliable.
6.
Unidentified Contaminants:
The GM yeast process resulted in 46 unexpected proteins,
none of which were fully identified or tested for safety.
7.
Lack of Long-Term Studies:
No long-term studies have been conducted to assess the
potential health impacts of consuming this novel GMO product.
4.
Inadequate Animal Testing:
Studies on rats fed LegH Prep revealed unexplained weight
changes, signs of toxicity, and organ damage
9
. These results were ignored in the EFSA’s
evaluation.
These gaps highlight the need for a more rigorous and transparent safety assessment process.
False claims about water reduction and GHG Emission reduction
Impossible Foods claims that their burger reduces water use and greenhouse gas (GHG)
emissions compared to conventional beef. However, these claims are misleading:
1.
Industrial Agriculture Reliance:
The production of GM soy and yeast relies on resource-
intensive industrial farming, which contributes to deforestation, biodiversity loss, and
high water use
10
.
2.
Lifecycle Analysis Gap:
The company’s lifecycle assessments fail to account for the full
environmental impact of GM crop cultivation, including pesticide use and soil
degradation.
11
3.
Greenwashing:
The burger’s marketing distracts from the real solutions to climate
change, such as reducing meat consumption and supporting agroecological farming.
9
https://www.cambridge.org/core/journals/environmental-conservation/article/abs/soybean-cultivation-as-
a-threat-to-the-environment-in-brazil/191311DBCD27A85DBF0782E989956867
10
11
https://gmoscience.org/2019/06/25/rat-feeding-studies-suggest-the-impossible-burger-may-not-be-safe-to-eat/
https://assets.ctfassets.net/hhv516v5f7sj/4exF7Ex74UoYku640WSF3t/cc213b148ee80fa2d8062e430012ec56/I
mpossible_foods_comparative_LCA.pdf
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4.
Environmental Risks:
The production of GM yeast and soy for the burger relies on
industrial agriculture, which increases pesticide use
12
and risks contaminating non-GMO
crops
13
.
The Impossible Burger is not a sustainable alternative—it perpetuates the same industrial
practices that harm the environment.
Better alternatives for healthy and locally adapted diets
Instead of promoting untested GMO products like the Impossible Burger, the EU should invest
in proven, sustainable solutions:
1.
Agroecological Farming:
Support farming practices that enhance biodiversity, soil
health, and climate resilience.
2.
Locally Adapted Diets:
Promote diets based on fresh, seasonal, and locally grown plant-
based foods, such as lentils, chickpeas, beans, and whole grains.
3.
Minimally Processed Foods:
Encourage the consumption of minimally processed plant-
based proteins like tofu, tempeh, and seitan, which are healthier and more sustainable
than ultra-processed GMO products.
4.
Policy Measures:
Use the EU Common Agricultural Policy (CAP) to incentivise the
production of protein crops for human consumption and make healthy, sustainable food
more accessible and affordable
14
.
These alternatives align with the EU’s Farm to Fork Strategy and Green Deal objectives, offering
real solutions for a sustainable food system.
Conclusion
The Impossible Burger represents a step backward for food safety, environmental sustainability,
and public health. By saying NO to the Impossible Burger, the EU can protect its citizens,
environment, and food sovereignty while paving the way for truly sustainable solutions.
12
13
14
https://enveurope.springeropen.com/articles/10.1186/2190-4715-24-24
https://www.nature.com/articles/35107068
https://www.beuc.eu/sites/default/files/publications/BEUC-X-2025-001_Unwrapping_veggie_burgers.pdf