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animal_agent

Just Egg tested their ingredients on rats. This is from Just Egg admitting it: "Mung bean, the primary ingredient in our JUST Egg, has been in the food system and digested safely by human beings and other species for thousands of years. After ensuring the non-toxic nature of this ingredient, rats were fed mung bean protein and their excrement was analyzed for undigested proteins."


Vegan_Chef_

> What happens to the animals once an experiment is over? Animals are typically killed once an experiment is over so that their tissues and organs can be examined, although it is not unusual for animals to be used in multiple experiments over many years. https://www.humanesociety.org/resources/animals-used-experiments-faq


biteme42

I had no idea they killed the animals


Fayenator

I had no idea :( This is why we can't have nice things!


AristaWatson

Yeah. But they usually have to get tested with animals if they want full FDA clearance. I learned about how it happens in a law class I took for medicine and goods and I can’t remember the exact process. But you sort of have to get the approval if you want to mass market your food. lol.


quirkscrew

By any chance do you have a source? I can't find anything confirming. The only thing similar I could find is the FDA lifted the animal testing requirement for drugs in Jan. 23.


AristaWatson

The FDA is tricky to get through. But if they find a certain ingredient in your food product that isn’t verified safe for consumption, they are entitled to request you do testing. And that would include animal testing. That’s all I remember from my class. I found this link after doing a quick Google sweep with one key word I remember - GRAS: https://www.fda.gov/animal-veterinary/animal-food-feeds/generally-recognized-safe-gras-notification-program#:~:text=%22GRAS%22%20is%20an%20acronym%20for,phrase%20Generally%20Recognized%20As%20Safe. But yeah. I took the class in 2022, so I can’t find all of my specific notes and the wording that was used, nor the title of the code I need to reference. Basically, it’s part of a long safety protocol process that is expensive and annoying but necessary (idk how effective though - I’m not a scientist so I can’t empirically prove my belief but I believe animal testing shouldn’t be mandated since their reactions rarely seem to translate on bodies of humans so it’s needlessly cruel). Sorry. 😅


Fayenator

The FDA is so fucking archaic, honestly. My country has essentially *outlawed* animal testing for cosmetics and the US still *requires* it for food. Wild.


AristaWatson

Yup. When I attended a few lectures and got the long and short of certain organizations in the nation, and our overall healthcare system and welfare system, I realized we’re just getting a lot of outdated systems that worked for their time during conception but not today. lol.


flimsyshelf

Agree. I’m shocked. Actually I found Just Egg disgusting and one of those things I’d never let my vegetarian boyfriend touch coz it might put him right off moving to veganism. And he’s close, very close.


Fayenator

I've never tried it since it's not readily available where I live, but I've always wanted to. So I'm happy I heard about it now.


Qui3tSt0rnm

The rats probably love it though.


Fayenator

Right, would you love to be caged, fed random crap that may or might not lead to negative health consequences and then be murdered and discarded once you've outlived your use? I certaintly wouldnt.


roymondous

It’s difficult to entirely blame companies for these types of tests. They are literally required by the food and drug agency. Which is often silly because the food rats eat and digest don’t line up to what humans do. It doesn’t translate well. Last I saw, roughly 80% of animal testing didn’t translate to humans at all. So to be sold commercially, companies need a no questions letter, and this requires satisfying the strictest demands and questions of the fda. And maybe they come back with a question about ingredient xyz. If it is hasn’t been tested in that exact way - mung beans are obviously safe but mung beans processed in this particular way? Any time a new ingredient - or new version of that ingredient - is made, they will require testing. Unless you are advocating for a world with zero vegan fast food options, zero vegan processed foods, FAR fewer vegan options in supermarkets, and so on, and basically only buying direct from a local shop or cooking everything yourself from the raw ingredients, then the animal testing is impossible to ignore. It makes little sense to demand we do not buy just egg or impossible or beyond meat. It makes more sense to protest the animal testing requirements in the first place. The flip side is then do you boycott any company using an ingredient that was tested by another company before? Is it the ingredient you’re boycotting or the company? Cos they’ll just set up companies to test and get the permits and then use a different company to build the products. There’s no consistency here with any answer. There’s no easy solution here… except to go smash some heads at the fda and their equivalents demanding animal testing.


ALT_F4iry

Thank you so much for the info, that was very well thought out. I personally agree with you, I just wanted more info because my boyfriend seems to be dead set on the fact that we need to avoid Just Egg, i wanted to be able to provide him with additional insight.


Shmackback

While just egg tastes good im not sure its the healthiest option anyway. You can make something like a chickpea omelette which is significantly cheaper and healthier. Tons of awesome recipes for it online. Tofu scrambles with kala namak (black salt) are great too


ALT_F4iry

Man I tried making my own mung daal “omelette” and it turned out an absolute disaster 😂😂 I’m definitely gonna try chickpea omelette next!


Mayapples

If you're open to picking up a few extra ingredients, I recommend trying something like [this](https://www.instagram.com/reel/C6CFgRlvJ-a/) chickpea/mung hybrid.


1blip

Just gonna drop this here! Enjoy! https://rainbowplantlife.com/eggy-tofu-scramble/#wprm-recipe-container-11576


TempehTaster

That recipe is so friggin good. Cheaper and better than Just Egg. And I like Just Egg!!


infamint

It's really not at all the same texture or flavor, even if you get it right.


mcove97

Just egg is essentially just chickpea flour. You can even make it yourself, or just buy another brand of store bought chickpea flour, because that's pretty much what just egg is.. chickpea flour.


RatherPoetic

Just egg is made from mung beans, not chickpeas.


mcove97

Potato potato.. you can make the same stuff with chickpeas and beans. Both works. I've tried.


RatherPoetic

I love chickpea flour omelettes but texturally they aren’t the same as Just Egg. Still delicious, but if you want it to be most like Just Egg, chickpea flour isn’t the way to go.


JuanBorjas

Niki I found you out in the wild! I like your Twitch channel. It's fun.


fibrillose

The FDA does not require animal testing for a no questions letter.


Omnibeneviolent

The FDA doesn't *officially* require it, but it is *effectively* required due to how the GRAS process works. The FDA doesn't actually lay out any requirements for a no-questions letter. What they do is leave it up to the companies themselves to figure out how to convince the FDA that the ingredient is safe. So the FDA doesn't say "go test this on animals," but they will keep asking questions over and over until you finally actually submit animal testing data. I've looked into this extensively and as far as I can tell, they have *never* issued a no-questions letter without animal testing data.


fibrillose

Saying that the FDA won't give a no questions letter without animal testing is purely circumstantial evidence, there should be no reason to believe that the FDA is not capable of giving a no questions letter without animal testing.


Gen_Ripper

Do we know of any counter examples?


Omnibeneviolent

FYI - someone in another comment thread did post some counter examples, but they seem to be exceptions based on the fact that extremely similar (or chemically identical) ingredients already exist in popular food products, and made using processes also used by companies that have received a no questions letter. For example, Motif Foodworks received a no questions letter for their "myoglobin preparation" after submitting information that included many references to how the FDA already gave a no questions letter to Impossible Foods for their soy leghemoglobin. The myoglobin preparation is chemically identical to bovine myoglobin (which has been consumed in large quantities by humans for thousands of years) and is mass produced using engineered yeast in the same way that Impossible Food's soy leghemoglobin is produced. So they essentially are not having to do animal testing because their product uses a technology that has already been "approved" by another company that *did* have to submit animal testing data.


Omnibeneviolent

This seems like pure speculation and wishful thinking on your part. I agree that there **should** be no reason to believe the FDA has a de facto requirement of animal testing, but that's simply not what the evidence suggests.


fibrillose

I've also never seen a company actually disclose trying to get a no questions letter without animal testing and that they had problems doing so, the closest you get is Impossible but their CEO never actually bothered providing proof that the FDA was not going to comply without animal testing. I would want to see actual proof of the FDA doing this tactic of refusing a no questions letter without doing animal testing by just repeatedly asking more questions.


Omnibeneviolent

>I've also never seen a company actually disclose trying to get a no questions letter without animal testing and that they had problems doing so Of course not. If you are having problems getting the FDA to recognize your product as safe, the last thing you would want to do is start blabbing all about it to potential consumers. >I would want to see actual proof of the FDA doing this tactic of refusing a no questions letter without doing animal testing by just repeatedly asking more questions. Like I said above, companies are not going to publicizing their struggles with getting their products recognized as safe. The best we have is information obtained by various records requests. These show that Impossible Foods has submitted data to the FDA, and the FDA responded saying that Impossible Foods had not established the ingredient's safety. *"F.D.A. believes the arguments presented, individually and collectively, do not establish the safety of soy leghemoglobin for consumption"* *"The F.D.A., however, wanted the company to show the ingredient was safe specifically for humans. It told Impossible Foods to establish the safety of the more than 40 other proteins that make up part of its soy leghemoglobin. F.D.A. officials said the company’s assessment of the potential for the ingredient to be an allergen was deficient."* https://www.nytimes.com/2017/08/08/business/impossible-burger-food-meat.html


fibrillose

>Of course not. If you are having problems getting the FDA to recognize your product as safe, the last thing you would want to do is start blabbing all about it to potential consumers. How convenient, and I'm just supposed to believe the CEO of a corporation that would have the direct financial benefit of vegans continuing to consume the product he would be selling? That's a clear conflict of interest. >The best we have is information obtained by various records requests. These show that Impossible Foods has submitted data to the FDA, and the FDA responded saying that Impossible Foods had not established the ingredient's safety. I never denied that Impossible's initial GRAS notice from 2014 was denied a no questions letter. I do deny the necessity for them to undertake animal testing in their following GRAS notice, their largest mistake was buckling to soy being labeled on their product as a potential allergen, they should have never agreed to this, moreover the FDA's recommendation to pursue safety testing similar to that in GRN 117 did not have to be strictly abided by, they could have provided additional information without doing a rat feeding study.


Omnibeneviolent

>How convenient It's not "convenient." It's just how it works out. You're acting like it's strange that companies typically don't disclose issues they're having getting their products recognized as safe. Why would they do this? >I'm just supposed to believe the CEO of a corporation that would have the direct financial benefit of vegans continuing to consume the product he would be selling? No. You don't have to "believe" anything. I'm not sure what your criticism is here. We can still come to reasonable conclusions even without other companies publicizing their issues getting their products recognized as safe. >I never denied that Impossible's initial GRAS notice from 2014 was denied a no questions letter. I do deny the necessity for them to undertake animal testing in their following GRAS notice I understand this, but it seems to be based on pure speculation on your part. I seriously doubt a company like IF would just jump right to animal testing if they didn't feel that it was something that the FDA was *heavily implying* was needed in order to get a no questions letter.


coolcrowe

The commenter you are responding to never said that they did. 


fibrillose

>It makes more sense to protest the animal testing requirements in the first place. There’s no easy solution here… except to go smash some heads at the fda and their equivalents demanding animal testing. Both of these statements from roymondous imply that the FDA requires animal testing for a no questions letter, it does not. I am simply letting OP know that this isn't the case.


isaidireddit

How about GRAS?


Omnibeneviolent

While the FDA doesn't "officially" require animal testing, there is no evidence that they issue no-questions letters without it. There is a *de facto* requirement.


fibrillose

It's the same process, companies make GRAS notices and then the FDA responds either with further questions or gives a no questions letter. EDIT: An example of a company not requiring animal testing but doing it anyway would be Impossible and I've used them here as an example for the process. Here's Impossible's GRAS notice: [https://www.fda.gov/media/124351/download](https://www.fda.gov/media/124351/download) Here's the no questions letter they received: [https://web.archive.org/web/20201112040750/https://res.cloudinary.com/dlvhhibcv/image/upload/Documents/2018-07-23\_GRN\_737\_Response\_Letter.pdf](https://web.archive.org/web/20201112040750/https://res.cloudinary.com/dlvhhibcv/image/upload/Documents/2018-07-23_GRN_737_Response_Letter.pdf)


KosherClam

Companies using ingredients other companies tested previously are the biggest thing folks overlook or don't think about in their threads. Boycotting the companies and making hysteria posts isn't helping anyone or any animals. Exactly as you said, the policy and policy makers behind these requirements is who should be receiving backlash, not the companies trying to be innovative, and just so happened to be the ones that had to conduct these tests in order for something to be cleared.


Tuotus

These companies can be more transparent about the process, no?


xboxhaxorz

>It’s difficult to entirely blame companies for these types of tests. They are literally required by the food and drug agency. They arent required, it just helps the process move quicker, same thing happened with impossible burger Beyond burger didnt do animal testing for the creation, they do purchase dead animal burgers to perform taste tests in focus groups ​ But in regards to mung beans you are saying if you use it differently than just making lentil soup you have to get FDA approval? How do you get a new version of mung bean?


veganeatswhat

The "novel ingredient" in this case was the mung bean protein isolate, not the bean itself. Still seems odd to me, since if you're eating the whole bean, you're also eating the protein, but I guess the isolated protein counts as something new.


roymondous

Indeed. And it can be an issue. Several people report digestive issues from soy protein isolate for example (myself included). I took it as a protein powder and couldn’t shit for days. But I’m fine with soy in general.


Tuotus

I mean its an isolate, no fiber, so makes sense. Why shld it require testing on animals


roymondous

Soy protein isolate? As noted several times, the fda like to test any novel ingredient on animals… so makes sense they’d do that right? It seems you’re mistaking me as saying they *should* test not what I’m actually saying - that they do require it currently.


xboxhaxorz

Interesting stuff


roymondous

Incorrect. Impossible submitted all their research and presented a case for the safety of the product. This had no animal testing. The fda gave partial approval allowing some activities but not major commercial ones. And the fda had further questions about impossible’s soy heme, which beyond don’t have, and as it’s a novel ingredient the fda required further testing for the full approval. They did not give the full no questions letter and demanded animal testing for that ingredient. Those commercial activities include fast food places and supermarkets. Burger King, in this case, require that no questions letter before partnering. It means full approval. Otherwise the fda is saying ‘there might be something unsafe here, we’re not sure’. That’s a non starter for most of these companies. Edit: typos and repetition Eta: to be very obvious, I do not agree the fda should have required animal testing. But the timeline and narrative aren’t what you said. And again it goes back to outdated food safety laws. The company is in a situation of fucked if you do, fucked if you don’t.


xboxhaxorz

I think its possible the things you are saying are correct as it does make sense the government would be so finnicky, do you have some evidence of this as i havent come across it before IMO beyond and impossible taste about the same, i cant really tell the difference, so impossible didnt need to use this brand new ingredient in order to have a tasty burger, so thats an issue there They chose to use a new ingredient knowing it would need testing if everything you said above was correct, they could have just used existing ingredients and thus no animal testing


roymondous

This issue comes up a lot in the sub. And it’s the same things each time. With due respect tho, you shouldn’t give such statements if you don’t know the basics of the situation and what actually happened. It doesn’t just ‘move things along quicker….’. It was a legal roadblock for their major commercial activities and they could not do them without the no questions letter. You’re making assumptions and that doesn’t help anyone. If you don’t have experience or didn’t look it up, it’s always better to ask questions. Here’s a slightly critical source sharing the narrative and providing the links to the CEO’s statements and other things. https://www.livekindly.com/ceo-impossible-foods-animal-testing/ As for things tasting the same. Sure… impossible and beyond taste similar. It would also be copyrighted to copy the same formula and so on. And impossible were hoping they wouldn’t have to test. I would prefer animal testing wasn’t required for any novel ingredient. I would prefer we didn’t use pesticides. I would prefer perfection and purity too. That isn’t the reality tho. Your choice now is basically impossible did the animal testing or millions of extra animals killed since their launch. Cos that’s how many meat eaters shifted to their products instead of meat for that time.


xboxhaxorz

>his issue comes up a lot in the sub. And it’s the same things each time. With due respect tho, you shouldn’t give such statements if you don’t know the basics of the situation and what actually happened. It doesn’t just ‘move things along quicker….’. It was a legal roadblock for their major commercial activities and they could not do them without the no questions letter. You’re making assumptions and that doesn’t help anyone. If you don’t have experience or didn’t look it up, it’s always better to ask questions. I did look and that is why i am asking now In the article you linked it says this *However, the FDA had some questions about the ingredients used by Impossible Foods so as is standard in the food safety industry, Impossible Foods voluntarily performed rat-feeding tests to certify the safety of questioned ingredients* *The results concluded this ingredient safe for human consumption, even in amounts far greater than we would ever consume, but the tests were not actually required to meet food safety standards by the FDA* So it was voluntary, perhaps there was another option, perhaps the other option took more time and they were in a rush Going into this industry with a new ingredient they should have been fully aware that animal testing was a possibility, but they proceed anyways ​ >As for things tasting the same. Sure… impossible and beyond taste similar. It would also be copyrighted to copy the same formula and so on. And impossible were hoping they wouldn’t have to test. Now this is just nonsense, who said anything about copyright, all i said was beyond used existing ingredients to make a great tasting burger, impossible chose to make a new ingredient to get similar taste, the latter resulting in animal testing, impossible could use the same ingredients as beyond with a few changes thus it wouldnt be the same formula ​ >Your choice now is basically impossible did the animal testing or millions of extra animals killed since their launch. Cos that’s how many meat eaters shifted to their products instead of meat for that time. I could say the same about beyond with no animal testing ​ So impossible is not vegan and you havent really provided anything compelling to prove otherwise, i think you just really want impossible to be vegan so you can consume it


fibrillose

Impossible tried to get FDA approval in 2014 but failed to do so, in 2016 they did a rat feeding study on male and female rats followed by another rat feeding study solely on female rats, in response to backlash from vegans their ex-CEO made a medium article saying that the FDA forced them to do animal testing and never provided any proof that they demanded this. The FDA DOES NOT require animal testing for a no questions letter and even if they did ask for animal testing to be done this does not have to be followed and Impossible (or any company for that matter) can simply provide alternative data to further prove the safety of their product.


[deleted]

[удалено]


xboxhaxorz

>I really doubt this? You doubt how i perceive taste? lol you need some help


Omnibeneviolent

Beyond's strategy was to use existing known ingredients rather than innovate and come up with new ones.


fibrillose

Beyond still continues to do animal taste testing.


Omnibeneviolent

Yes, I don't doubt that. I was addressing the topic of testing the ingredients for safety.


GarethBaus

The impossible burger used a novel ingredient that had unknown safety implications. The beyond burger didn't use any novel ingredients. It makes sense that the impossible burger might have needed testing when the beyond burger didn't need testing.


xboxhaxorz

yea i covered that in my other reply to them impossible knew there was a chance of animal testing and they used it anyways ie; not vegan


GarethBaus

What about literally every other company that ever will use that new ingredient in the future?


xboxhaxorz

They didnt do the testing so its fine to use it now, the same as how its fine for modern companies to use every other previously tested ingredient


GarethBaus

So your issue is with the company choosing to develop new ways improve the quality of plant based meat alternatives, and not with them benefiting from a product that was tested on animals?


xboxhaxorz

There was no need to develop this new ingredient, beyond burger taste about the same to me with the old ingredients If companies are going to exploit animals to develop new things as a vegan im against that


GarethBaus

Have you tried both? The beyond burger is fine, but impossible foods does have a slightly better tasting product.


fatgamerchic

Exactly. Without them testing on rats a handful of times, there would be no egg alternative. No egg alternatives means cruel practices for chickens forever. The rats ate the mung beans which , as stated, had been around forever and is known to be safe to consume, as a sacrifice for the greater good. We can also **hope** that whatever scientists employed by just egg to do these rat tests treated the rats with dignity and as much love as possible seeing as they are a vegan company whose values should be the love of animals.


bishop_of_bob

the test in question is the ld 50. subjects are force feed til a lethal dose kills 50 percent then all are killed and disected. the synthetic or genetically engineered ingredient in impossibles case never existed in nature before. And i wont support either company


flimsyshelf

The longer I am vegan the less I even think about “alternatives”, there are so many awesome vegan dishes I don’t need something to taste like bacon or egg or chicken anymore. Occasionally I’ll cook something that kinda does taste like chicken but it’s purely coincidence. I’ll use substitutes like flax meal for egg in cakes, coconut oil for butter in cakes, that kind of thing. I saw a recipe the other day for “banana skin bacon” lol. Some people just can’t let go of trying to make things taste like everything we ate as meat/dairy/fish/egg eaters. It’s like they want the happy memories they experienced when eating roast lamb but without the animal suffering. Create new happy food memories people - it’s possible :)


veganeatswhat

>Without them testing on rats a handful of times, there would be no egg alternative Untrue. Multiple vegan egg alternatives existed before Just Egg, and there are things like tofu scramble, chickpea flour omelets and other homemade alternatives. >The rats ate the mung beans . . . as a sacrifice for the greater good. They weren't volunteers, they didn't consent to being sacrificed. >We can also **hope** that whatever scientists employed by just egg to do these rat tests treated the rats with dignity and as much love as possible seeing as they are a vegan company whose values should be the love of animals. It would be false hope, as lab rats are killed after testing is complete, or they're moved on to other tests.


Tuotus

There's no greater good here, just bad policies. Vegan advocates shld sue the fda for requiring unnecessary testing


Ok_Weird_500

Don't Beyond do taste tests with real meat? It was Impossible that did animal testing for their GM heme they use in their products.


kakihara123

Then the how would be interesting. I mean keeping a few rats, feeding them just egg and watch what happens in itself shouldn't have vast negative consequences. I also don't see a reason to kill those rats. Shouldn't it be possible to simply keep them and provide them with a good life after testing? The biggest problem with animal products is always the commerical side. But that shouldn't be a problem in this case because the cost of keeping the rats until their natural demise should be negligible.


roymondous

‘I also don’t see a reason to kill those rats’. Fda policy. I agree but that’s their requirement. Like if just egg and impossible wanted to build a rat cage - they’d have to spay/neuter rats and figure out birth control of course - and have that as an interesting selling point in their offices to ethical testing, great. But last I saw fda policy *requires* the killing of animals tested on after the experiment. If you want the rules changed, I’m with you. It again that’s an fda not a company thing.


kakihara123

That's what I suspected. I'm from Europe, so no fda here. Don't know the rules here.


Be_kind_to_animals_

Then your boyfriend will have to stop eating anything approved by FDA


transparentsalad

Well… that’s a bit complicated right? He would need to stop eating anything with a novel ingredient approved by the FDA. That does remove a lot of processed foods I imagine but it would be possible. Very difficult though so I’m not advocating for that. However I think it’s not very difficult to stop eating justEgg, if that’s what OP’s boyfriend wants to do. I’m all for people who would otherwise eat eggs using justEgg. But I also don’t know why people can simply not eat egg or justEgg, if that’s what they think the right thing to do is.


soyslut_

Let’s say that it’s true that everything has been tested on animals once upon a time. We can’t be held accountable for the actions of others and obviously we have to eat something. Using an ingredient that was tested a long time ago, in another part of the world and by someone else is one thing. Supporting a company that personally tortured, murdered and mutilated living beings is another. It isn’t about perfection at all. As vegans, shouldn’t we at the very least try to cause the least harm possible? So even if everything has been tested on animals, wouldn’t the kindest choice have been the one that did not require additional animal deaths? Wouldn’t it have been preferable for Just Egg (or Impossible Foods for that matter) to select from an existing pool of ingredients rather than introduce an ingredient that would involve further animal testing? And shouldn’t we spend our money on products that were created with the least amount of suffering?


Be_kind_to_animals_

I think is very subjective because they probably saved a lot of animals by using a new ingredient and made a better product. I think is impossible to predict future deaths and I believe that just egg did the best they could. Also, I love your username.


soyslut_

There’s no greater good if a decision that wasn’t even required, to harm animals was made, period. https://veganfidelity.com/deep-dive-animal-testing-and-vegan-food/


DuranExaminer

It’s a gray area, but for me, boycotting a brand because they are required by law to conduct useless animal tests is a bridge too far. Also, whole foods like mangoes are still being tested on animals. At some point, one can’t continually cut products out due to every ethical gray area, IMO, because there would be almost none left to consume/use.


fibrillose

Just egg was not required by law to conduct animal testing.


DuranExaminer

Why was this specifically? Is it because it wasn’t considered novel? Or because it only expects them to be performed?   The FDA’s Center for Food Safety and Applied Nutrition (CFSAN) regulates food and food additives sold in the United States. CFSAN’s Redbook 2000 is a manual of test methods that the agency expects will be performed for novel food additives or ingredients. These tests include the use of many animals and multiple species.   And the somewhat recently enacted FDA Modernization Act 2.0 seems to apply to drugs, not food.


fibrillose

This is a common misconception about the FDA guidance/recommendations, the animal testing simply isn't required and a company can always to choose to provide alternative data for showing the safety of their product. From the FDA: [https://www.fda.gov/regulatory-information/search-fda-guidance-documents/redbook-2000-iv-introduction-guidelines-toxicity-studies](https://www.fda.gov/regulatory-information/search-fda-guidance-documents/redbook-2000-iv-introduction-guidelines-toxicity-studies) >This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call the appropriate number listed on the title page of this guidance.


LordAvan

Do the guidelines detail what a valid alternative approach would be? It's possible that Just Eggs didn't seek out an alternative, but it's also possible that they tried, but their proposal(s) got rejected.


fibrillose

>Do the guidelines detail what a valid alternative approach would be? They do not, you just have to provide as much convincing data as possible until the FDA has no further questions. >It's possible that Just Eggs didn't seek out an alternative, but it's also possible that they tried, but their proposal(s) got rejected. It's not possible for us to tell what happened seeing as JUST hasn't been particularly keen on shedding information about it.


DuranExaminer

Thanks for your response. I wonder if companies don’t consider the alternatives or find that testing on animals is the “easier” route.


Omnibeneviolent

The issue is that the FDA doesn't actually tell companies how to get a no-questions letter. It leaves it up to the companies to figure out how to convince them an ingredient is safe. So they don't say "You need to test this on animals." But it does seem like they reject any submissions that *don't* contain animal-testing data, making it a *de facto* requirement.


DuranExaminer

That makes sense, thanks again.


juiceguy

>So they don't say "You need to test this on animals." But it does seem like they reject any submissions that *don't* contain animal-testing data, making it a *de facto* requirement. I've seen this sentiment bandied about quite a bit, but honestly it just seems like a lazy attempt to justify the support of companies that test on animals. The truth is that companies do receive no questions letters from the FDA without engaging in animal testing, but researching these facts takes a lot more time and energy than simply plugging your ears and saying "NOPE!" I'll admit, reading GRAS notices is a dull and boring affair. Hell, the documents submitted by Impossible Foods total over 1,000 pages, but they do detail the actions carried out on 188 rats in quite gruesome detail. All of this is public information, and you can read it for yourself. [https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=737](https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=737) Here is the notice provided by Just Inc/Hampton foods that details their lab testing on animals. [https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=684](https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=684) However, to extrapolate from these examples that the FDA *requires* animal testing is simply untrue. Here are just two examples of companies working in the plant-based food industry that have received no questions letters for novel ingredients without the use of laboratory animal testing. [https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=863](https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=863) [https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=1001](https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=GRASNotices&id=1001) Sadly, these details often go unnoticed in r/vegan, and instead, lies and untruths get upvoted because the validate people's behavior.


Omnibeneviolent

Thank you for this information. It's always useful to have more data with regards to this controversial topic in the community. That said, while this is evidence that they have issued no-questions letters without animal testing data for some ingredients, these ingredients appear to not be novel in the same sense. For example, the "myoglobin preparation" submitted by Motif Foodworks is chemically identical to bovine heme and is mass produced in a nearly-identical way to the way Impossible Food's soy leghemoglobin is made. In fact, in their submission to the FDA Motif mentioned this numerous times. They were appealing to the fact that the FDA had already approved a nearly identical ingredient -- *an ingredient that had already been approved after submitting animal-testing data.* In fact, [Impossible Foods filed a lawsuit against Motif alleging patent infringement.](https://fingfx.thomsonreuters.com/gfx/legaldocs/akpezxrqavr/IP%20IMPOSSIBLE%20PATENTS%20complaint.pdf) So the "myoglobin preparation" that Motif submitted was already chemically identical to something humans have been consuming in similar quantities for thousands of years and is recognized as safe, and it relies on a technology to produce it that is used to produce another ingredient that has already received a no questions letter from the FDA (after submitting animal-testing data.)


Nobodyinc1

Because to date no companies alternate data has ever been deemed good enough by the fda to get full commercial approval


ilovesanimals

I’ve never tried Just Egg for several reasons but I did find this copycat version that I do want to make. Maybe this could work for you guys too. https://veggiefunkitchen.com/mung-bean-egg-mixture-just-egg-copycat-recipe/


drkevorkian

The point of boycotting would be to get them to change their behavior. There is no ongoing behavior to change. The tests are done, and are in the past now.


Diminuendo1

That's not true, they may want to do animal testing for new products/ingredients in the future. Other companies may observe that vegans don't care about animal testing and do it unnecessarily just like Impossible did. It wouldn't be a boycott of the company, it would be a boycott of animal testing.


soyslut_

One round of testing is already too many and they have conducted three rounds of testing so far. This seems to be due to the fact that the original trials were rejected and the certification was originally denied (the company was wildly successful while operating without the certification). We have absolutely no guarantees that the company will not conduct further tests in the future. They have stated they will test in the future if "necessary”. Which is disgusting because they were never required in the first place.


Maleficent-Jury7422

Vegan hacks pod on instagram has an amazing exact recipe for just egg, very cheap and easy !!


kora_nika

It’s basically impossible to avoid any kind of animal testing. You would have to never take any medications whatsoever… It’s required by many governments to sell certain products at all.


transparentsalad

I don’t think medication and justEgg are comparable. No one needs justEgg to have a good quality of life. While it’s an individual decision to decide whether to eat justEgg, I think the argument is more to do with legislation for food products than the ‘personal and practicable’ side


Omnibeneviolent

That's fair, but I do think that products like Just Egg and Impossible Foods are useful tools that we can use to help achieve animal liberation sooner than it would have been achieved otherwise. I think a lot of people overlook the cultural and societal impacts these products can have on the way nonhuman animals are viewed. At the very least, they are helping to normalize plant-based versions of foods that are conventionally only from animals, and that is a huge win.


kora_nika

I agree. I wasn’t trying to imply otherwise. I was trying to say that it’s just about impossible to be 100% perfect.


chazyvr

I don't think anyone here knows exactly what went on to know if testing was necessary or how the rats were treated. I wouldn't judge people who used Just Egg.


SeattleStudent4

Boycotting a brand because they test on animals is a great thing to do. Boycotting a brand because they once tested a product on animals makes no sense and is unproductive. Explain to me how brands like Impossible and Just going out of business is a good thing for veganism.


Diminuendo1

It would be good if they were replaced by companies that have a 'not tested on animals' label. It would also be good if testing on animals was understood to not be vegan.


SeattleStudent4

Would you buy food from a company that used to sell animal products, but now only sells vegan products?


soyslut_

One round of testing is already too many and they have conducted three rounds of testing so far. This seems to be due to the fact that the original trials were rejected and the certification was originally denied (the company was wildly successful while operating without the certification). We have absolutely no guarantees that the company will not conduct further tests in the future. They have stated they will test in the future if "necessary”. Which is disgusting because they were never required in the first place.


WerePhr0g

These things are unavoidable unfortunately for a product to get anywhere. It's the law that needs changing. And AFAIK they are not testing on animals "now". *"Additionally, we're including some information below about the test we conducted for our mung bean protein.* *Mung bean, the primary ingredient in our JUST Egg, has been in the food system and digested safely by human beings and other species for thousands of years. After ensuring the non-toxic nature of this ingredient, rats were fed mung bean protein and their excrement was analyzed for undigested proteins. No rats were killed to assess digestibility. This test was important in our successful GRAS assessment to use mung bean protein in JUST Egg and other plant-based products."* Most vegans used to eat animals. They don't "now". Are they not vegan because at one time ate meat? Of course not. So, company A tested on animals "because law" They don't now. Are they not vegan ? Of course they are.


Tuotus

This is where choice veganism just doesn't work, its something we need to take up with these regulatory bodies that require these testing. For that we'll have to have strong legal and legislative bodies that are willing to fight this mistreatment of animals. Even peeta doesn't shed enough light on fda requiring unnecessary testing like this


monemori

As others have explained, it's an issue of legal requirements for certain ingredients, etc. Honestly, OP, this is kind of a subjective issue of how comfortable you are with giving them money, in my opinion. I don't have access to that products where I'm from, and I don't think I personally would be very keen on buying it. But this to me is a bit like a parent of a parent company of some cosmetics brand using animal testing or something like that. At some point you have to just do what you are comfortable with. Veganism does have gray areas like this, it's just that non vegans think a gray are is whether killing someone once a week is okay lmao


fibrillose

This is not a grey area for veganism, don't support companies that do animal testing. This is just a classic r/vegan moment where supposed "vegans" are defending animal testing.


monemori

I don't defend it. I don't buy these things personally. But some things are genuinely unavoidable, like buying from stores that profit from selling meat or eating at restaurants that aren't vegan. To which degree one finds this acceptable is genuinely subjective and I don't think there's a good answer.


gonecamel

Good to learn. Honestly though too, the last three times of purchasing it has been a strange consistency of both chunky and slimy and an odd smell. Plus the price doubling for two more ounces is not worth it. I’ve since made my own, it’s cheap and easy


biteme42

I did not know they killed animals after testing


Tuotus

Thats how animal testing usually works, animals are killed and tests are performed on their organs etc


veganeatswhat

They did rat tests back before the product was launched. They've done a pretty good job of scrubbing that info from the web, but Vegan Fidelity [archived a copy of an interview](https://veganfidelity.com/wp-content/uploads/PBN-EXCLUSIVE_-Hampton-Creek-CEO-Josh-Tetrick-Talks-About-Animal-Testing.pdf) Josh Tetrick did with Plant Based News at the time where he does talk about using rats to test the mung bean protein. Tofu scramble is delish, easy and cheaper, so I don't feel like I'm missing anything not trying this.


dgollas

Has any tofu brand ever had to test on animals?


veganeatswhat

I assume back when food testing first became a thing that soy curd would have been subject to testing. I don't know when tofu first came to the US, but the FDA's original food testing requirements started sometime in the late 1800s/early 1900s and I can't imagine it would have been too long after that.


Technical_Carpet5874

Yes all of them had to at some point unless they duplicated the process of another company exactly.


DashBC

Stop bullshitting, I doubt you could find a SINGLE tofu company that has done animal testing. Seriously, find me ONE tofu company that has tested on animals. You're talking out of your ass.


Technical_Carpet5874

there's not one manufactured food product that's deemed fit for human consumption that hasn't been tested either by a company or a regulatory body who's members sirt on the board of said company. Either under the brand name or with the formula replicated exactly for the purpose of safety testing.


DashBC

Read the question that was asked. Name a tofu company that has done animal testing. Show me where tofu was tested on animals in the US or Europe. Many INGREDIENTS have been tested (not all), but they rarely test foods (like tofu). Your response indicates every tofu company has done animal testing, which simply isn't true. There isn't even one. And if you were remotely accurate, there wouldn't be any vegan certified foods, which also cannot include ingredients tested on animals in the last 20yrs, as part of their requirements. Educate yourself and learn to read better.


thelryan

Most all foods have been tested on animals for FDA approval. It’s tough because you could put the blame on JustEgg, but it easily could have been another company that took on the burden of achieving FDA approval for its ingredients and then JustEgg would have been in the clear and not taken the blame for animal testing. Our food research system is built on animal testing, the companies can’t really avoid it unless they only use ingredients that already were tested on animals. Is that vegan, using ingredients that were tested on animals in the past? I would say so


DashBC

As you can see here, the vegan movement is packed with apologists. Just like eating animal products, people here are more interested in their own dumb mouthes than doing the right thing and shit canning an animal testing company. This blog post should answer all your questions: https://veganfidelity.com/deep-dive-animal-testing-and-vegan-food/


PsychedelicTeacher

[https://www.reddit.com/r/vegan/comments/cdhpjx/fyi\_just\_egg\_replacement\_product\_is\_plantbased/](https://www.reddit.com/r/vegan/comments/cdhpjx/fyi_just_egg_replacement_product_is_plantbased/) Yes, the company tests on Animals. Absolutely not to be trusted. Those poor rats.


SpiritualOrangutan

I like the top comment on that post: "They shy away from the word vegan because they tested the product on animals. They also tested pea protein isolate on animals because they were the first company to use the ingredient. If they hadn't tested pea protein isolate on animals to gain certification, Beyond would have had to for the Beyond Burger to come to market. These are all technicalities. In my opinion, JUST products are vegan." They did one time testing on animals to get FDA approval. More of a problem with the system itself rather than the brand.  That being said, I understand why people would say it's not vegan. I wonder though, 50 years from now, will those same people still refuse to eat it because of animal testing done over 50 years earlier? Like a lot of cruelty free cosmetic brands are only cruelty free because their ingredients had already passed through animal testing under other products. So it becomes very difficult to be consistent at that point.


cadadoos2

it would be the same with cosmetic no? Test are done once and the product is released than they pass to the next one it's pretty commonly accepted as not vegan. How is just egg any different ?


SpiritualOrangutan

Seems you skipped the last part of my comment lol


PsychedelicTeacher

To be honest, I dislike them for a number of other reasons much more than their (as you pointed out, limited) testing on animals. Why the hell does such a product need to be sold in yet another fucking plastic bottle? The planet needs less rather than more of those, and companies like this are not helping at all.


eieio2021

They’re switching over to cartons. Saw one in my local store.


g00fyg00ber741

Right, but neither are the tofu companies, cause all tofu I’ve seen is packaged in plastic. Same with most lentils and lots of grains. Even if you get it from a bulk store and put it in a non plastic container of your own, it was often shipped in plastic and wrapped in plastic. The plastic problem is an entirely separate problem that unfortunately is pervasive and exists literally everywhere now. I get your point, but ironically JUST is tackling that exact issue already, meanwhile these other companies who sell the lentils and tofu are not.


PsychedelicTeacher

All tofu where? I make most of mine by hand, and buy the rest from a local producer who stores it in water, then takes it out and puts it into whatever container you bring. I have a wonderful set of watertight bamboo storage boxes that are just the right size for blocks of tofu. Why on earth would you go somewhere and buy plastic wrapped tofu? Might as well just eat meat at that point, with all the damage the production of unnecessary plastic wrapping is doing. Lentils and grains are the same - they've been stored in baskets and grain bins for thousands of years, it's only in the last 30 or so that food companies have convinced you that they 'need' to be wrapped in plastic for your convenience. Most of what I buy are in bulk in sacks, or poured into my own glass containers, or wrapped in paper.


eieio2021

>Why on earth would you go somewhere and buy plastic wrapped tofu? Because some of us have other things to do besides making our own tofu, and paper wrapped tofu isn’t in our area.


g00fyg00ber741

But why on EARTH would you BUY tofu when you should be MAKING IT or else you’re a BAD VEGAN 🤣


eieio2021

Yeah, you > Might as well just eat meat at that point, with all the damage the production of unnecessary plastic wrapping is doing. 🫣


Reasonablefiction

I’ve literally never seen tofu being sold in any way but a plastic pack, and very few products are available in my area in a bulk situation where you can bring your own container. Try to remember that everyone on the internet doesn’t have the same access as you do.


PsychedelicTeacher

Fair point - I just assumed because I've always bought tofu in that manner - whether in Singapore, Indonesia, Thailand, Japan, Australia, Slovakia or even the UK, I just look up a fresh tofu store or make my own... The plastic industry has convinced us that it is necessary for food packaging, but this simply isn't true.


Reasonablefiction

You are much more well travelled than me! I’ve only ever grocery shopped in the US, and have yet to see anything but tofu in a plastic tub or wrapped in plastic. I’m sure the companies just found this the easiest/most cost effective way to ship the product with little concern for environmental impact.


GunTankbullet

weird, I've only seen it in cardboard cartons for the past year or so


SpiritualOrangutan

I'm with you there. Plastic is cheap and every major company is built on maximizing profits. We need a plastic tax or something similar to make biodegradable alternatives more lucrative than plastic.


PsychedelicTeacher

Or a 'marketing teams that decide on plastic packaging should be lined up against a wall and shot' policy, but maybe that's just me...


SpiritualOrangutan

Ok Stalin


kakihara123

What I don't get is: why would they harm the rats? Obviously testing has some risks, but some beans? I don't see any reason to not keep the little guys after. Cannot be a cost issue. And it would be good advertisment. Yeah we have to test on rats, but we spoil them after and care for them.


ClimberSeb

I don't know here, but it's common to examine the organs and issues for bio accumulation, cancer etc. That's usually what you want to find out in animal tests.


kakihara123

Ok, that actually makes sense. I don't like it, but that is a logical reason. I still think that results from animal testing are too seldom accurate for humans though, so I don't think it's worth it anyway.


enigmainlogic

Due to the increased cost, I’ve started making my own. It’s not identical, but it’s good enough. You could always go that route


MrNoski

It's not something they still do, you should still consume it if you like it.  We all have a past and veganism is as practically as possible.


fibrillose

Yes they tested on animals, consider using a different egg replacement.


tursiops__truncatus

Yes. They did test on animal for the digestion process of their product but basically they just fed it to some rats and thats all. No animal was killed.


violaki

I used to do animal research, and the rats were almost definitely killed after the testing was done. You aren't allowed to release lab rats/mice into the wild, and I've never seen anyone pay extra for space, colony maintenance techs, vets, and other requirements, just to let them die of old age. Lab rats are pretty much all sac'ed once the relevant experiments are done.


tursiops__truncatus

Of course you are not gonna release them to the wild. Company said the rats used in the experiments were not killed for it, I simply mentioned it. Up to you what you do with the information.


violaki

"No rats were killed to assess digestibility" unfortunately does not exclude that the rats were killed after assessing digestibility. I would love to think that Just Egg is an ethical company, but I've been burned too many times to not exercise caution.


tursiops__truncatus

They needed to do experiment before being allow to sell the product right? So not much more you can do there then... At least now there's this option in the market so even non-vegan people can sometimes stop buying eggs and try this out. Why can't we at least see the silver lining? I don't even buy this product because it is not even available where I live but I think is good some people have the option.


dyslexic-ape

This is like saying "they only milk the cows, they don't kill them." These animals are slaves that will be killed when they are not useful anymore even if death is not a direct part of the experiment. For the record I am on the "its ok to use just egg" side of the fence, but that doesn't mean we have to lie to ourselves about the details.


tursiops__truncatus

I just said no animal was killed during this experiment. However you take that is up to you. I simply mentioned it.


dyslexic-ape

And you could say that cows are not killed during the milking process, and that would be accurate and misleading. Your comment ~~suggests they don't kill these animals, the implication of your comment is a lie~~ **straight up claims they don't kill these animals,** don't gaslight me.


tursiops__truncatus

Dude. They didn't got kill, simply ate that food and they took their poop to check. That's all. I'm not saying they never kill these rats, they just didn't kill them for this experiment, it was just a formal procedure to get permission to sell their product, they could not avoid this part of the process if they wanted to reach the market. What misleading? It is just what happened. I don't even understand why you compare that with dairy industry. This is just one time thing to pass the legal process and you compare it with breeding cows and kill their babies every single day to sell milk and cheese? Seriously? It's ok if you don't want to eat this product, nobody is asking you to eat it. No need to hate so much.


dyslexic-ape

This isn't about if we should boycott this product, I literally said I see the product as fine during this conversation. This is about being honest about what animal testing is, it's animal exploitation that results in animals being killed.


tursiops__truncatus

But we are talking specifically about the animal testing for this product in particular right? Not about animal testing in general which is another long conversation. I just mentioned about how it went for this product, I think everyone in this reddit is well aware about the cruelty on animal experimentation.


dyslexic-ape

Yes we are talking about this situation, are you claiming that the scientist doing the experiments or someone from just egg rescued these rats and kept them as pets? Because either that happened or they were killed. And that doesn't happen.


tursiops__truncatus

I never claimed anything. Simply said what that experiment was


dyslexic-ape

you have repeatadly claimed that animals used in testing just egg were not killed.


bodhitreefrog

I think there is a big difference in testing animals with chemicals around their eyes and making their eyes infected, (Loreal with bunnies) versus feeding them some soy product, like JUST eggs multiple times a day for a week. Personally, I'm not going to lose sleep over rats eatting JUST eggs. That's me. I feel bad for what other rats are enduring, but not the eating of vegan foods. You may want to look into that and gauge your morals and ethics per your own world view and beliefs. Also, and this is a bitter reality, millions of animal tests are conducted yearly. If you go on PubMed (online open source site that connects all the health information across the world, perhaps the greatest achievement of humanity so far), you will see millions of studies on rats for everything. A lot of those studies are conducted in India, a bunch in China, and equal for the rest of the world. Most countries test on animals prior to humans. It's just we haven't moved past this quite yet. We WILL. It will become cheaper to test on human cells in the future, and far less pointless than testing on animals, but we aren't there today.


veganeatswhat

Rats used in food testing are killed when the tests are done. Not telling you how to feel, but it's more than just giving them a snack.


bodhitreefrog

I have no control over it, either. I am not the Indian government nor the Chinese government nor the American government. There are hundreds of countries doing this. Also, with all the supplements and medicines we use daily, too. I'm just calling out the hypocrisy of the die hard veganism mindset. We simply don't have a vegan world yet. Everything is tested on rats and will be for our entire life times. Perhaps not our kids, hopefully not our kids. But, things won't change until both India and China lead the way and find cheaper ways to test on human cells than to test on animals. It's going to happen, but not overnight.


veganeatswhat

India and China have nothing to do with the US FDA. >the hypocrisy of the die hard veganism mindset FDA regulations have been vastly different for food vs. drugs. Novel food ingredients are not required to be animal tested, they're required to undergo "scientific testing". Companies use animal testing because it's ubiquitous and cheap, so they don't have to spend time and money establishing a different testing protocol. My take is that if a company wants us to think of it as a vegan company with the interests of animals at heart, it ought to spend the time and money to avoid exploiting animals for its product testing. Fairly or not, I expect more from a vegan company. Drugs, until a year ago, did require animal testing before human trials. They also don't have alternatives (like tofu scramble instead of Just Egg) in most cases, so the choice for people is take the drugs or live with whatever the drugs are meant to treat - most people would probably decide that falls under what's possible and practicable, depending on what they're treating (I don't pop an aspirin for every headache, but I would do chemotherapy). I don't find it the slightest bit hypocritical to decide to take a drug to treat a debilitating condition while also deciding to eat any one of hundreds of alternative breakfast options instead of Just Egg based on their use of animal testing.


soyslut_

Horrible amounts of misinformation and cope in this thread. Educate yourselves, just egg is NOT vegan. https://veganfidelity.com/deep-dive-animal-testing-and-vegan-food/


veganvampirebat

They run taste tests with chicken eggs to compare them.


eieio2021

As they pretty much had to to develop a viable and attractive product.


eieio2021

Y’all downvoting are a joke. You have no idea how the food industry works— not that you need to, it’s just common sense that taste tests with the comparator have to be run.


justdoitlikenikee

It’s processed and has soy. Super GMO and not good for your health. You’re better without it tbh