Regulatory History

There are no regulations for labeling MSG in the United States. Consumers have no way of knowing if there is processed free glutamic acid (MSG) in processed food, and if there is any, how much or how little there is.

The U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA) regulate the use of food, drugs, and cosmetics in the United States. In their infinite wisdom, they seem to have chosen to work closely with the food and glutamate industries to make certain that processed free glutamic acid (MSG) is, and remains, hidden in food. In their endeavors, the FDA and the USDA have been joined by the U.S. Environmental Protection Agency (EPA), the California Department of Food and Agriculture (CDFA), and the California Department of Pesticide Regulation (CDPR), which appear to be working hard to assure the glutamate industry that MSG will also be used, and remain hidden, in fertilizers, plant growth enhancer, fungicides, and other pesticide products, used on growing crops.

The regulatory history of these agencies vis-a-vis processed free glutamic acid (MSG) is simple and straightforward. The FDA and the USDA require that, in most cases, the names of food ingredients found in food products be identified on the labels of those food products. Processed free glutamic acid (MSG), however, has been classified by the FDA as a constituent of a food ingredient. According to the FDA, processed free glutamic acid (MSG) is not a food ingredient. So there is no requirement that MSG in processed food be listed on product labels.

The EPA, the CDFA, and the CDPR, in their own brands of infinite wisdom, have: 1) chosen to ignore the flagrant violations of Sections 408 (c)(2)(A)(i) and 408 (c)(2)(A)(ii) of the Federal Food, Drug, and Cosmetic Act committed by Emerald BioAgriculture (formerly known as Auxein Corporation) in its applications to the EPA, the CDFA, and the CDPR for approval of use of processed free glutamic acid (MSG) in agricultural products to be sprayed on or otherwise applied as pesticides, fungicides, plant growth enhancers, and/or fertilizers to growing crops; and 2) have approved the use of processed free glutamic acid (MSG) with no restriction on the amount of processed free glutamic acid (MSG) that might be left in or on crops when brought to market. For detail, please refer to Evidence Sufficient to Demonstrate that EPA Exemptions for the Requirement of a Tolerance for Residues of "Glutamic Acid" and "GABA" in or on all Food Commodities, and the Unconditional Registration of AuxiGro WP are Unwarranted.

The FDA

What little regulation there is at the FDA which might be remotely relevant to identifying MSG in processed food is related to: 1) designating a food ingredient as GRAS (generally regarded as safe); 2) assuring the public that (with a few exceptions) the "common or usual names" of all food ingredients in a product will appear on the product's label; and 3) assuring the glutamate industry that the amount of processed free glutamic acid (MSG) in "monosodium glutamate" or any other food ingredient that contains processed free glutamic acid (MSG) will not be disclosed.

1) The history of MSG and the FDA goes back to 1958 and passage of the Food Additives Amendments (Code of Federal Regulations, Title 21) wherein the GRAS (generally regarded as safe) list was established.

Prior to 1958, there had been little or no comment to the FDA on the food ingredient called "monosodium glutamate," so following passage of the Food Additives Amendments, "monosodium glutamate" was grandfathered as GRAS. Grandfathered, yes. But tested for safety, no. The safety of "monosodium glutamate" was not then, and has never been, established.

Historically, beginning in 1969, and every time thereafter that the safety of "monosodium glutamate" has been challenged, the glutamate industry (the glutes) have designed and funded research of so-called "researchers" whose job, it would appear, was to produce one or more studies that would persuade the public that "monosodium glutamate" is "safe," i.e., that "monosodium glutamate" deserves a place on the GRAS list. We have analyzed their studies carefully, and found them, individually, to be badly flawed; and have also found them. taken as a whole, to be flawed to the point of being fraudulent. (See The toxicity/safety of processed free glutamic acid (MSG): A study in suppression of Information.

As this is being written, GRAS status has never been awarded to "monosodium glutamate," although the glutes' claims that "monosodium glutamate" is GRAS go unchallenged by the FDA.

There are two interesting sidebars to this discussion of GRAS. First, it is important to recognize that over the years, the FDA has changed its posture relative to the toxicity/safety of "monosodium glutamate." While the Federal Food, Drug, and Cosmetic Act requires that manufacturers provide the FDA with proof that their products are "safe," the FDA is presently allowing manufacturers to tell the FDA that their products are "safe," and allowing manufacturers to claim that their products are GRAS unless consumers can prove, to the FDA's satisfaction, that an ingredient is toxic.

Second, it is important to recognize that the "monosodium glutamate" that was grandfathered GRAS in 1959 is not the same "monosodium glutamate" readily available today in the United States. In the late 1950s, Ajinomoto, Co., Inc., the world's largest supplier of "monosodium glutamate," began producing "monosodium glutamate" through a process of bacterial fermentation wherein the glutamic acid used in "monosodium glutamate" was secreted from the cell walls of specially selected genetically engineered bacteria. It was not until 1968 that the first recorded report of an adverse reaction to "monosodium glutamate" appeared in the medical literature.

2) The FDA requires that every ingredient used in food be assigned a name (a "common or usual name"), and that with some (often significant) exceptions, every ingredient used in a food product must be listed on the label of that product.

"Monosodium glutamate" is the name of an ingredient that contains 79% processed free glutamic acid (MSG), with the balance made up of salt, moisture, and up to 1 per cent contaminants. When an ingredient contains 79% processed free glutamic acid (MSG), and the balance is made up of salt, moisture, and up to 1 per cent contaminants, the product must be called "monosodium glutamate," and the product must be labeled as such. "Apple" is the common or usual name of a food ingredient. When a product contains "apple," and/or "monosodium glutamate" the words "apple" and/or "monosodium glutamate" must appear in the list of the product's ingredients.

MSG-containing ingredients have names like "autolyzed yeast extract," "sodium caseinate," and "hydrolyzed pea protein." These names have often been carefully chosen by flavor-enhancer manufacturers to serve as "clean labels," i.e., names that would give the consumer no clue to the fact that they contained processed free glutamic acid (MSG). Historically, the FDA has tended to ignore the fact that any MSG in any processed food, regardless of the ingredient name of the food that contains it, can cause MSG adverse reactions; and the FDA, ignoring any challenge to the safety of other MSG-containing ingredients, has focused largely on perpetuating the fiction that "monosodium glutamate" is "safe." It is for that reason that only ingredient labeling regulations relevant to "monosodium glutamate" are discussed here. It is important to remember that although there are many MSG-containing ingredients, "monosodium glutamate" is the only food ingredient with a name that gives consumers even a clue to the fact that it contains MSG.

One might argue that consumers could learn the names of the seemingly infinite number of MSG-containing ingredients on the market at any given time. But even that wouldn't protect consumers from hidden processed free glutamic acid (MSG) because current FDA regulations allow that certain products such as "stock" and "broth" can be used as ingredients in products without listing/naming the ingredients contained in the "stock" or "broth." Thus, "stock" or "broth" that contain "hydrolyzed soy protein," "autolyzed yeast," and "sodium caseinate," for example, could be used in "mushroom soup" and labeled "stock" or "broth" without mentioning the three sources of processed free glutamic acid (MSG): "hydrolyzed soy protein," "autolyzed yeast," and "sodium caseinate."

Current FDA regulations, ordered by the Congress, also allow certain MSG-containing ingredients to be included under the label descriptors "flavor(s)", "flavoring(s)", "natural flavor(s)", and "natural flavoring(s)" without disclosure of the processed free glutamic acid (MSG) in them, or even mention of the ingredients' names.

Finally, processed free glutamic acid (MSG) can be produced during processing. For example, certain enzymes combined with protein will create processed free glutamic acid (MSG) during product processing. Under present FDA regulations, "enzymes" would be listed as ingredients with no indication that during processing enzymes would create processed free glutamic acid (MSG). Certain processes, such as ultrapasteurization, can similarly produce processed free glutamic acid.

That every food ingredient must be listed by its "common or usual name" on the label of a product that contains it, provides the consumer with little or no information about the presence, absence, or amount of processed MSG that might be in a product.

3) It is clear to those of us who have followed the work of the glutes and their agents, that they find it imperative that information about the amount of processed free glutamic acid (MSG) in food ingredients not be available to consumers. We know, and they know, that the processed free glutamic acid (MSG) in "monosodium glutamate" and other MSG-containing products is toxic to those who ingest amounts that exceed their MSG tolerance levels. If MSG, and the amount of MSG in every ingredient was listed on the label of every product that contained MSG, a consumer who suspected that he or she might be reacting adversely to the MSG in a product could determine how much, if any, MSG there was in the potentially offending product. Then, by simply sampling products that contained various amounts of MSG, a consumer could determine whether or not MSG, or certain amounts of MSG, were triggering reactions. If MSG were identified on labels of processed food, no glutamate industry propaganda testifying to the "safety" of MSG would be effective.

Most fundamental to the hiding of processed free glutamic acid (MSG) in food is the FDA's decree that processed free glutamic acid (MSG) is not a food ingredient, and does, therefore, not need to be identified on labels of processed food. According to the FDA, processed free glutamic acid (MSG) is a constituent of an ingredient. When "autolyzed yeast," for example, is made in a food processing plant, the protein in the yeast that is being autolyzed will be broken apart into its constituent amino acids, one of which will invariably be glutamic acid (processed free glutamic acid) i.e., MSG. When "autolyzed yeast" is used as a food ingredient in a larger product, the "autolyzed yeast" will be listed on the label of that larger product, but there will be no mention of the fact that the "autolyzed yeast" contains such things as aspartic acid and MSG. According to the FDA, since processed free glutamic acid (MSG) is not a food ingredient, processed free glutamic acid (MSG) does not have to be listed on the labels of the products that contain it.