NAMMEX petitions the FDA to provide clearer guidance on Mushroom Product Labeling

Mycelial-Network Betwixt the Logo

There was a Citizen Petition filed from North American Reishi Ltd doing business as NAMMEX.

The Docket number is FDA-2023-P-2340, here is a link to it, and here is a link to the comments and this is a hyperlink to more attachments and documents regarding the petition. Many comments agree with the petition. Some other organizations have written articles about the matter.

Companies are falsely advertising mushroom products by selling myceliated grains in the form of substrate but labeled as ‘mushroom’. -Meaning some companies are selling high starch coco coir or some other substrate with Mycelium and little or no actual mushroom (fruiting body). Companies are batching together these myceliated grains and selling them with the perceived notion of being the fruiting body itself.

The petition can be accurately summed up by the following comment;

“Mushrooms and mycelia are two totally different things. It’s like apples and branches of an apple tree. Clear labeling differentiating them is essential for consumer information.”

-Chris Kilham

An easy way to test for myceliated grain was mentioned in a comment;

“Simple DIY testing using a drop of iodine and adding this to a solution with the supplement in question is already sufficient to prove this statement. If the dissolved supplement contains a lot of starch, the solution will turn blue/black,”

Comment from FDA-2023-P-2340-0021

There are also other concerns with Mushroom food and drug labeling. It’s not clear which part of the mushroom or fungi is being used, hence the petition to have companies clarify and use specific and precise wording.

Petitioner requests that FDA revise and re-issue the above-referenced CPG to clarify that
“mushroom” and “mycelium” are two separate, distinct parts of fungi and that FDA no longer
considers the term “mushroom mycelium” to accurately describe any fungal ingredient listed in
food labeling.

-From the Petition

It is clearly evident that different parts of the mushroom, the mycelium, mycelia body, etc, are morphologically different and have different bioactive components. If someone is looking for a particular health benefit, due to this obscurity, the desired effect may not occur or may be diminished. This results in a consumer wariness or ‘buyer beware’ and may foster a general distrust in sourcing of mushroom products.

Essentially, are companies properly labeling their products and selling mushrooms when they say they are? Or are they selling Myceliated Grains -potentially as a cost reductive measure? Here’s a picture to illustrate an example;

Image by simonproulx from Pixabay

Here’s another picture from a quick google search;

These pictures lead to a great clarification article by Real Mushrooms’
Skye Chilton
, who also works with NAMMEX

It is good to note that Mushroom and Mycelium have different bioactive properties and that they are both beneficial in different capacities. It’s just a matter of whether the consumer is getting what they expect to purchase based on labeling requirements. Meaning that the Mycelium isn’t inherently bad. It’s just a matter of labeling. Whether a user wants the benefits of the Mycelium, the Mushroom, or both, should be communicated clearly on product labeling.

(For instance, Lion’s Mane Mycelium have Erinacines which provide many benefits, and these are typically not found in the Fruiting body.)

The other issue is that Myceliated grains might have a lot of, well, grains. Resulting in the customer having little to no mycelium, and potentially a lot of starchy grains.

In other words,

Imagine if a butcher was selling meat and called everything steak. You don’t know if you’re getting ribeye, sirloin, Beef liver, or a flank cut.

That’s the same thing here but with mushrooms, and the difference in result or effects is very very measurable.

The Petition also cites how Plant based products have to delineate separate parts of the plant used for the product, i.e. stem, flower, root, etc.

This petition is asking for such rigor and clarification to be provided to include Mushrooms as well.

A Call To Action;

If you have some insights or expertise, please feel free to comment on the Docket. You do not have to be a US citizen to comment. If you are a consumer or some way related to production or resale or distribution, etc. of Fungal products, then your voice is valid and welcome.

And there are a lot of comments ranging from Mycologists, Food Chemists, Health Care Practitioners, Naturopaths, small businesses, wholesalers, etc. that agree. Some businesses like Firstpersongroup, NaturPro Scientific, Lost Empire Herbs, NS 360 Inc., Natural Stacks, ARMC Holdings, Inc., Four Sigmatic, and have taken a stand.

Also, if you run a business or anything, please do comment, it’s free clout and it’s a way to get your name and company out there to stand by a measure/petition that would help the industry. Even if you disagree with this measure, your points and valued opinions would still be welcomed. To Comment, you have to click on a specific document to comment under, see further instructions below;

Comments are submitted on individual documents in a docket. By clicking on the tab for “Browse Documents”, you can access document-specific comments and submit your own comments. By clicking on the tab for “Browse All Comments”, you can have consolidated access to all comments for the docket from one location. In some instances, agencies do not publicly post all comments received. You can only access those comments that are posted to by the agencies. The number of accessible comments, therefore, may be lower than the total number of comments listed in the card below.

Click this link, and then look for the comment button;

Hopefully I’ve made commenting easier for you

As of writing, I’ve read all 15 comments to generate this article with some value as well as my personal desire and call to action for those interested.

Comments are open, be respectful, courteous, and cordial

But most of all, provide value. These are comment letters that get read. It’s not a voting system. Present valuable insights and information that persuade.

To Recap,

NAMMEX is petitioning to have FDA reconsider such a marketing practice and possibly usher in guidance or regulations. There are some companies are selling you that left over white mass of myceliated brick instead of the actual mushroom and falsely labeling it as Mushroom. How much? Who knows. Hopefully this Petition gets traction to have better consumer protections.

Hope you were able to get connected and feel the pulse of the Mycelial Network. Comment or message if there needs to be any clarification.

P.S. I find it quite interesting as an US citizen on how we Americans put Sugar and high starches in everything. Even our mushroom products and dietary supplements. It’s quite the running ‘joke’ if you will within our nutritional sciences.

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