A package might carry a Non-GMO certification, an organic seal, a health claim, a sustainability statement and a date code, all competing for consumer trust. There may be more information available to consumers now, but that does not necessarily mean there is more clarity.
This tension is particularly visible in the renewed attention surrounding bioengineered food labeling. The federal Bioengineered Food Disclosure Standard established a national framework for communicating whether foods meet the regulatory definition of bioengineered, but questions remain about whether regulatory disclosure alone provides the kind of straightforward information consumers are seeking.
As health and wellness claims proliferate, concerns about “health washing” grow, and confusion persists around terms such as “sell by” and “best by,” food labeling increasingly raises a question that goes beyond compliance. Can the industry clearly communicate accurate information in a way that consumers can actually understand?
For the Non-GMO Project, that distinction is central to the concept of food integrity.
“People have a right to know how their food is made,” Megan Westgate, CEO of the Non-GMO Project said. “Increasingly, they want to understand not only what’s in a product, but where ingredients come from, how they’re produced, and what practices and technologies are involved along the way.”
But disclosure and transparency are not necessarily synonymous. Information can be technically available while remaining difficult for a consumer to interpret.
“Real transparency asks more of us: Is the information clear? Is it accessible and accurate? Does it use language people actually understand? And is there something credible behind the claim?” Westgate clarified.
When Disclosure Is Not Enough
The federal Bioengineered Food Disclosure Standard offers a useful case study in the difference between regulatory compliance and consumer understanding. Consumers spent decades calling for GMO labeling before the federal system adopted the term “bioengineered,” creating a distinction between the terminology used by regulators and the language consumers had historically used.
The federal definition also does not encompass everything a consumer might reasonably understand to be the product of genetic engineering.
That distinction could become more consequential as biotechnology evolves. Gene editing and other genetic engineering techniques are changing how foods and ingredients are developed, creating an ongoing challenge for definitions and disclosure systems designed around earlier technologies.
“If our transparency systems, and even our definitions, don’t evolve alongside those technologies, the gap between what consumers want to know and what they’re actually told is going to grow,” Westgate shared.
At the same time, marketplace activity suggests that information about genetic engineering continues to matter to a significant segment of consumers. According to figures provided by the Non-GMO Project, approximately 28% of food and beverage products in the natural marketplace carry the Non-GMO Project Butterfly, while another 20% make some form of non-GMO claim.
The organization views that activity as evidence that consumer interest in the issue remains significant.
“The federal standard tried to establish a baseline, but it was flawed,” Westgate continues. “Even a solid baseline isn’t the same thing as complete transparency. Regulation can establish the floor. It doesn’t have to be the ceiling.”
The Limits of a Label
A certification can communicate an important attribute without communicating every attribute a consumer may associate with it. A Non-GMO certification addresses genetic engineering. Organic certification addresses a separate, though sometimes overlapping, set of production requirements. Neither is intended to communicate a product’s complete nutritional profile, environmental impact, labor practices or degree of processing.
That distinction between the value and scope of a certification is increasingly important as consumers use labels to navigate a complicated food system.
Westgate noted that consumers are increasingly relying on certifications because trusted signals can help them navigate that complexity. At the same time, the industry must be careful not to allow the positive associations surrounding a trusted claim to imply benefits that have not been demonstrated.
“I don’t think the answer to consumer confusion is less information. It’s better-defined claims, rigorous standards, credible verification and better education about what sits behind them,” Westgate confirmed. “When we get that right, labels and certifications can do something incredibly valuable: turn a complex food system into information people can understand, trust and use to make the choices that are right for them.”
The Problem With Persuasion
The distinction between informing and persuading becomes especially important as concerns about “health washing” and other marketing practices grow.
Marketing itself is not inherently problematic. The ethical question is whether the overall presentation of a product creates an impression that extends beyond what an individual claim actually establishes.
“I think the line gets crossed when there’s a meaningful difference between what a claim technically says and what a company knows a consumer is likely to hear,” Westgate disclosed.
That means responsible labeling requires looking beyond whether a statement is technically permissible and considering how a reasonable consumer is likely to interpret the entire package.
“If you’re making a narrow claim, don’t use the rest of the package to imply something much broader,” Westgate elaborated. “If a sustainability claim measures one particular practice, be clear about that.”
The principle applies even when a particular disclosure is not required. Companies can meet the letter of a regulation while still leaving consumers with an incomplete or misleading impression.
“You might win a purchase through ambiguity, but you build a relationship through trust,” Westgate urged. “And over the long term, I think trust is a much more valuable asset.”
Designing Labels Consumers Can Understand
Expiration dates provide another example of the consequences of unclear communication. Consumers may encounter “sell by,” “best by” and “use by” dates without fully understanding the differences, potentially affecting purchasing and disposal decisions.
The underlying lesson extends beyond date labels: information only achieves its intended purpose when consumers can interpret it.
That may require reconsidering how the industry defines transparency itself. Rather than viewing transparency primarily as a regulatory obligation, the Non-GMO Project believes the industry should recognize it as a market demand.
The organization reports more than 63,000 Non-GMO Project Verified products representing more than $50 billion in annual U.S. sales. Organic sales reached $76.6 billion in 2025, according to figures cited by the organization. Those figures suggest that consumers are assigning substantial economic value to specific food attributes and the certifications associated with them.
“A trusted label doesn’t just give someone information at the grocery store. It can create a feedback loop between what shoppers are asking for and what the food system produces,” Westgate shared.
The challenge is ensuring that this feedback loop is built on information consumers can understand rather than marketing impressions they may misinterpret.
“If a meaningful piece of information requires someone to scan a code, understand an unfamiliar regulatory term, know the exemptions in a federal rule, or go home and research what a marketing claim actually means, I don’t think we’ve achieved transparency,” Westgate expanded.
The test, Westgate said, is simple: “Could someone standing in a grocery aisle understand what this product is telling them — and just as importantly, what it isn’t telling them?”
As labeling continues to evolve alongside new technologies, production practices and consumer priorities, that distinction may become increasingly important. Transparency is not simply the presence of information on a package. It is the ability of consumers to understand what that information means, what it does not mean, and whether they can trust what sits behind the claim.
“People shouldn’t need a regulatory glossary to buy groceries,” Westage distilled.
Megan Westgate is the founder and CEO of the Non-GMO Project, North America’s leading third-party food verification organization. For nearly twenty years, she has worked to advance transparency and trust in the food system, helping consumers make informed choices based on clear, consistent standards.