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I MPACTS OF M ANDATORY GE F OOD L ABELING :

A Q UASI -N ATURAL E XPERIMENT

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C OLIN A. C ARTER AND K. A LEKS S CHAEFER

In July 2016, Vermont became the first U.S. state to require mandatory labeling of foods containing
genetically engineered (GE) ingredients. The introduction of the Vermont law serves as a quasi-
natural experiment on the economic effects of mandatory GE labeling. We investigate the market re-
sponse in the U.S. sugar market. Almost all beet sugar is GE, while cane sugar is GE-free. Prior to
2016, cane and beet sugar were regarded as homogenous. However, in mid 2016, refined cane sugar
began selling at a premium over refined beet sugar. We find the mandatory labeling initiative gener-
ated about a 13% price discount for beet sugar and a premium of about 1% for cane. Food manufac-
turers’ concerns over mandatory labeling caused them to switch inputs. This resulted in a
redistribution of welfare in the U.S. sugar industry.

Key words: GMO labeling, Vermont Act 120, National Bioengineered Food Disclosure Standard,
sugar market.
JEL codes: Q13, Q18.

“Many food companies have decided engineered (GE) ingredients is one such exam-
to label their products as non-GMO. ple of this phenomenon.1
And because practically all sugar In May 2014, Vermont became the first
beets in the U.S. are genetically mod- (and only) U.S. state to pass mandatory label-
ified, those food products are now ing rules for GE foods sold for consumption
using sugar derived from sugar at home.2 The law (Act 120) took effect on
cane. . .” July 1, 2016, but was nullified by federal legis-
Dan Charles, National Public lation later that month. Penalties and require-
Radio (May 12, 2016) ments under the Vermont law were harsh.
Consumers could sue for violations of the la-
Legislation is not made in a vacuum. Markets beling requirements “without needing to
evolve even as policy debate transpires, and demonstrate any specific damage occurred as
markets anticipate policy changes. Once a pol-
a result of the alleged violation,” (Bovay
icy outcome becomes sufficiently likely, pro-
and Alston 2018). Manufacturers of improp-
ducers adjust to minimize costs and maximize
benefits. But these adjustments can be costly to erly labeled products sold in Vermont would
reverse even if the policy outcome never comes be fined $1,000 per day, per product.
to pass or is later quashed. Segmentation of the About two weeks after the Vermont law
U.S. sugar market in response to mandatory la- took effect, U.S. Congress responded with
beling legislation for food containing genetically the National Bioengineered Food Disclosure
Standard (NBFDS), which pre-empts state-

1
GE technology is defined here as in Van Eenennaam
Colin A. Carter is a distinguished professor of the Department of et al. (2014): “Genetic engineering (GE) can be defined as the
Agricultural and Resource Economics, University of California, manipulation of an organism’s genes by introducing, eliminating,
Davis and the Giannini Foundation of Agricultural Economics, or rearranging specific genes using the methods of modern mo-
Davis. K. Aleks Schaefer is a lecturer of the Royal Veterinary lecular biology, particularly those techniques referred to as re-
College, University of London, UK. The authors would like to combinant deoxyribonucleic acid (rDNA) techniques.”
2
thank editor Timothy Richards and three anonymous referees Exempted from labeling requirements were alcohol, food
for comments that greatly improved the article, and Michael J. served in restaurants, ready-to-eat foods, foods derived from ani-
McConnell for his help in obtaining the U.S. sugar price data. mals raised with GE feed, and foods manufactured with GE
Correspondence may be sent to: aschaefer@rvc.ac.uk. processing aids, such as enzymes (Bovay and Alston 2018).

Amer. J. Agr. Econ. 0(0): 1–16; doi: 10.1093/ajae/aay066


C The Author(s) 2018. Published by Oxford University Press on behalf of the Agricultural and Applied Economics
V
Association. All rights reserved. For permissions, please email: journals.permissions@oup.com
2 August 2018 Amer. J. Agr. Econ.

level labeling initiatives and imposes federal products; thus, understanding the effects of
disclosure requirements for some GE- labeling laws on the sugar market has broad
containing foods but allows that the disclo- relevance across a wide range of consumer

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sure need not be explicit on the product label products. Sugar also has two distinct GE and
(Charles 2016).3 On May 4, 2018, the USDA non-GE production methods. In the United
released a set of proposed requirements un- States, sugar is produced from both sugar-
der the NBFDS, including a statement on the cane and sugarbeets. Sugarcane stalks are
consequences for non-compliance and mech- milled to produce raw sugar. Raw cane sugar
anisms for enforcement (Federal is then sent to a refining facility to be trans-
Register 2018). These rules have not been fi- formed into refined sugar. Sugbarbeets, in
nalized and are currently subject to public contrast, have no raw stage; they are proc-
comment. essed from beet to refined sugar in one con-
In spite of the widespread use of food labels tinuous process. The U.S. market share for
worldwide (Carter and Gruère 2003a; Gruère, beet (cane) sugar is approximately 58%
Carter, and Farzin 2009; Kiesel, McCluskey, (42%). Almost all U.S. sugarbeet production
and Villas-Boas 2011; Vigani is GE, while cane sugar is GE-free. However,
and Olper 2013; Van Eenennaam et al. 2014), sugar derived from beets is chemically identi-
empirical evidence of market impact is scant. cal to sugar derived from cane (Klein,
Existing research focuses entirely at the retail Altenbuchner, and Mattes 1998).
level. Kiesel, McCluskey, and Villas- Finally, regulations in the U.S. sugar mar-
Boas (2011) review literature that uses market- ket create a relatively clean setting in which
level and natural experiments to examine the to identify the impacts of labeling require-
effects of nutritional label requirements on ments. U.S. cane and beet growers receive
consumer behavior. Teisl, Bockstael, annual marketing allotments (i.e., production
and Levy (2001) employ an experiment to quotas) and all imports are subject to tariff-
study the welfare effects of the provision of rate quotas or volumetric restrictions.
nutrition information on supermarket shelves Imported sugar accounts for about 25% of
to highlight whether the food product was the U.S. supply, and all imports are cane
low or reduced in fat, cholesterol, sodium, sugar.
and calories. Berning, Chouinard, Since early 2016, refined cane sugar has
and McCluskey (2010) and Kiesel and Villas- traded at an unusual price premium of up to
Boas (2013) conduct field experiments to ex- 7.9¢ per lb. (27%) over refined beet sugar.
amine the effects of nutrition labels on the Figure 1 shows refined cane and beet prices
sales of microwave popcorn. Some research from January 2008 to December 2017. Prices
has also used scanner data to evaluate historically moved in a close one-to-one rela-
consumers’ purchasing decisions in the con- tionship. From January 2008 to December
text of GE labeling rules (Marks, 2015, the maximum difference between cane
Kalaitzandonakes, and Vickner 2004; and beet prices was just 2¢ per lb.
Chang 2006). Gruère (2006) incorporates the be- We ask two questions related to the rela-
havior of food manufacturers by comparing the tionship between GE labeling laws and mar-
fraction of food products labeled with informa- ket segmentation in the U.S. sugar industry.
tion regarding the use of GE inputs in Canada The first question is one of attribution—can
(where GE labeling is voluntary) and France the divergence in U.S. cane and beet prices
(where GE labeling is mandatory). be attributed to input reformulation in re-
We analyze the effects of GE food labeling sponse to the Vermont labeling initiative? A
laws and associated product reformulation on structural break analysis reveals that the
the relative prices of GE and non-GE food breakdown in the relationship between cane
ingredients. Our analysis focuses on the U.S. and beet prices occurred in the May–July
refined sugar market, an interesting case for 2016 period. July 2016 is the month
several reasons. Most importantly, sugar is a Vermont’s mandatory labeling law took ef-
key ingredient in many processed food fect. Historical price relationships before and
after July 2016 reveal that the locus of the
break was at the refiner level and the shock
3
Food manufacturers can use a text statement, a symbol, or was confined to the U.S. market. It seems
the words “scan here for more food information” accompanied clear that food manufacturers responded to
by a QR code that can be read by a smartphone. Small manufac-
turers may print a website URL or phone number that customers the Vermont legislation by changing their in-
can call for more information (Federal Register 2018). put mix.
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 3

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Figure 1. U.S. refined sugarcane and sugarbeet prices
Note: U.S. refined beet and cane prices are obtained from tables 5 and 5a of the ERS Sugar & Sweeteners Report. Table 5 is available online at https://www.
ers.usda.gov/data-products/sugar-and-sweeteners-yearbook-tables.aspx; Last accessed August 6, 2018. table 5a is not online, but is available from ERS upon
request. Underlying data are the simple average of the lower end of the range of quotations from Milling & Baking News for days in each month

The second question is one of impact—if sorting mechanism for consumers (Crespi
labeling requirements caused the price diver- and Marette 2003; Fulton and
gence, what would refined sugar prices have Giannakas 2004) and as a signal about the
been in the absence of such legislation? relative safety of GE foods (Artuso
Using a standard regime-switching regression 2003; Lusk and Rozan 2008). The consumer
model, we find that the Vermont law induced impacts and potential price differences be-
a break in the price relationship between tween GE and non-GE ingredients also affect
U.S. and world sugar prices. This price pre- manufacturers’ input and supply decisions
mium has persisted under the NBFDS. (Carter and Gruère 2003b).
Relative to what prices would have been in
the absence of legislation—GE labeling Firm-Level Decision
requirements generated an average premium
for cane sugar of approximately 1% and a The introduction of the Vermont law forced
discount for beet sugar of around 13%. In the manufacturers to make a binary choice: (a)
12-month period immediately following the maintain current product formulation and la-
July 2016 legislation, mandatory GE labeling bel or (b) switch to non-GE inputs to avoid
requirements generated a $40 million wind- labeling. The profit-maximizing strategy is a
fall for U.S. cane refiners and cost U.S. beet function of the share of consumers willing to
processors approximately $400 million. buy GE-labeled foods, the cost of switching
from GE- to non-GE inputs, and the cost of
compliance with the labeling policy (Carter
Economics of GE Food Labeling Laws & and Gruère 2003b). Consumers may interpret
Input Mix a mandatory label as a warning that GE foods
pose a food safety threat or are of poor qual-
Economists have studied the drivers and in- ity. If so, some consumers previously unwill-
ternational differences in GE labeling ing to pay a premium for non-GE may pay to
requirements (Carter and Gruère 2003a; avoid GE as a result of the policy. Moreover,
Gruère, Carter, and Farzin 2009; Vigani for most food products reformulation to-
and Olper 2013; McCluskey, Wesseler, wards non-GE inputs is unlikely to have a
and Winfree 2018) and the impact of manda- substantial effect on the final food price. GE
tory labels on consumer and producer behav- ingredients are typically used in highly proc-
ior. From the consumer perspective, essed products and represent a small share of
mandatory GE labels function both as a the food dollar (Cowan 2010). These factors
4 August 2018 Amer. J. Agr. Econ.

push the food manufacturer to convert to the decision to reformulate away from GE
non-GE inputs to avoid labeling. ingredients and towards non-GE ingredients
A similar choice exists for retailers sends a message of quality upgrading to

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(Kalaitzandonakes and Bijman 2003). For ex- consumers—a source of differentiation from
ample, supermarkets like Trader Joe’s, competitors. For a manufacturer who has al-
Whole Foods, and many others seek to differ- ready reformulated to non-GE inputs, the de-
entiate themselves by offering foods per- cision to convert back to GE ingredients
ceived by consumers as higher quality. If sends a message of quality downgrading. The
consumers perceive foods containing GE move would open the manufacturer to loss of
products as lower quality due to a label, market share. The switch back to GE ingre-
retailers may choose not to offer them dients would not necessarily lead to a signifi-
(Carter et al. 2012; Van Eenennaam cant cost saving for many food products. The
et al. 2014). relative silence in the economics literature on
The reformulation decision was not exclu- quality downgrading is telling on this point.
sive to suppliers selling into Vermont. One Additionally, manufacturers considering a
can easily imagine the following circumstan- move back to GE ingredients may face sub-
ces: a food manufacturer labels food in com- stantial political backlash by pressure groups
pliance with one state’s law, but a retailer opposed to GE technology. The uncertainty
(perhaps accidentally) sells the product in with respect to the specific requirements of
Vermont where the label is non-compliant the NBFDS reinforce these points for risk-
with local law. The food manufacturer would averse manufacturers.
thus be liable and subject to penalties under
the Vermont law. Furthermore, economies of Market-Level Outcomes
scale may incentivize the food manufacturer
to use only one input. Most food manufac- To see how markets have responded to po-
turers supply several states out of a single tential mandatory labeling, we turn to the
production facility. So, even if a small share sugar industry. In late 2015 and early 2016,
of the market requires labeling, the product many food manufacturers, including
requirement may change the entire supply Campbell’s Soup, ConAgra, General Mills,
chain. The history of litigation over labeling Hershey, Kellogg’s, and others, announced
rules suggests the cost of adhering to manda- they would switch to sourcing sugar from
tory labeling could be high.4 cane rather than beets (Perez 2016). Several
The passage of the NBFDS is not an eman- explicitly cited the Vermont legislation and
cipation for food manufacturers (or retailers) the absence of a federal labeling bill as the
who already reformulated in light of the primary driver behind this decision
Vermont law. On one hand, the NBFDS is (Meersman 2015; Clayton 2016). Following
not (in the strict sense) a mandatory labeling these announcements, the close historical re-
policy. The limited disclosure requirements lationship between refined cane and beet pri-
may reduce the incentive to reformulate ces began to deteriorate (figure 1).
(Bovay and Alston 2018). On the other hand, This breakdown in the price relationship is
the decision to convert from GE- to non-GE consistent with the theoretical effects of man-
ingredients is not the dual of the decision to datory labeling laws on input markets.
convert back. Once the decision to convert to Figure 2 presents a simple conceptual model
non-GE ingredients is made, it is somewhat of the U.S. sugar market. Segments SBeet and
irreversible. If GE products are perceived as SCane in panels (a) and (b) of figure 2, respec-
being of lesser quality than their non-GE tively, represent the supply schedules for re-
counterparts (regardless of whether this per- fined beet and cane sugar produced
ception is influenced by labeling legislation), domestically. Marketing allotments under the
U.S. sugar program make supply highly in-
elastic at a certain quantity for both products.
4
For example, in 1986, California passed Proposition 65—a Prior to the promulgation of a mandatory
referendum requiring businesses to provide a warning about labeling law, cane and beet sugar were
chemicals contained in their products. Similar to Vermont’s la-
beling law, Proposition 65 contains a provision allowing private
treated as a homogenous commodity. Thus,
citizens to file lawsuits against businesses alleging violations of the total supply of domestically produced re-
warning requirements. Between 2000 and 2016, businesses paid fined sugar in the United States (SSugar) in
over $280 million to settle Proposition 65 cases initiated by pri-
vate citizens (California Office of the Attorney General panel (c) was the horizontal sum of SBeet and
[OAG] 2016). SCane. Schedule DSugar also shown in panel (c)
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 5

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Figure 2. Impact of GE food labeling laws on U.S. sugar market

depicts the residual demand for refined sugar processors is ðPf  PBeet ÞQBeet . The introduc-
(net of TRQ and Mexican imports) by U.S. tion of GE labeling requirements also results
food manufacturers and other sugar users. in a deadweight loss equal to the sum of tri-
Equilibrium occurs where market demand angle k in panel (a) and triangle j in panel
for sugar equals market supply, shown by the (b).
intersection of schedules SSugar and DSugar in
panel (c). In this equilibrium, QSugar units of
sugar were sold, QBeet of which were derived Methodology & Preliminary Analysis
from beets and QCane of which were derived
from cane (where QBeet þ QCane ¼ QSugar ). In this section, we examine whether the theo-
All sugar was sold at price Pf. retical and anecdotal evidence regarding the
Enactment of a mandatory labeling law seg- relationship between GE labeling laws and
mented the demand schedule for refined sugar. U.S. sugar prices is supported by empirics.
A portion of the market, including food manu- We first use a structural break test to deter-
facturers who reformulate towards non-GE, mine whether the timing of the break in cane
was now willing to pay a premium to purchase relative to beet prices is consistent with the
sugar derived from cane. Demand for GE-free legislative and policy timeline. We then use a
cane sugar is depicted as schedule DGEfree in regime-switching regression model to mea-
panel (b). Those who do not reformulate or are sure the historical relationship between U.S.
unwilling to pay a premium for cane will con- and world refined sugar prices prior to the
tinue to source from beet (depicted as schedule observed break. Finally, we compare pre-
DBeet in panel (a)). and post-structural-break prices for refined
Under a mandatory labeling policy, equi- sugar to measure the effects of the labeling
librium occurs when the demand for GE-free legislation. Model robustness and sensitivity
sugar is equal to the supply of cane sugar and are also considered.
the demand for sugar users unwilling to pay a Our data includes monthly observations of
premium aligns with the supply of beet sugar. U.S. raw and refined cane sugar, refined beet
In figure 2, this equilibrium is represented by sugar, and world raw and refined sugar prices
the intersection of schedules DGEfree and from January 2011 to December 2017. The
SCane in panel (b) and the intersection of U.S. raw cane price is the Intercontinental
schedules DBeet and SBeet in panel (a). Exchange (ICE) Sugar No. 16 nearby futures
The law drives a wedge between the price contract.5 The world raw price is the nearby
of non-GE and GE inputs. Processors of non- price for the ICE No. 11 contract.6 There is
GE inputs receive a premium for their prod-
ucts, while processors of GE inputs receive 5
Monthly prices were obtained from table 4 of the ERS Sugar
lower prices. The premium to cane refiners is and Sweeteners Yearbook. “Nearby” refers to the contract with
PCane  Pf and the discount to beet process- the closest settlement date. The ICE No. 16 contract specifies
ors is Pf  PBeet . The policy results in trans- that 112,000 pounds of raw cane sugar be physically delivered to
one of five U.S. refinery ports: New York, Baltimore, Galveston,
fers of economic welfare away from beet New Orleans, or Savannah. Delivery months are January, March,
processors and towards cane refiners. The to- May, July, September, and November.
6
Monthly prices obtained from table 3b of the ERS Sugar and
tal windfall to cane refiners is Sweeteners Yearbook. The No. 11 contract specifies delivery of
ðPCane  Pf ÞQCane . The total loss to beet 112,000 pounds of raw cane sugar in delivery months March,
6 August 2018 Amer. J. Agr. Econ.

Table 1. Augmented Dickey-Fuller Tests for Stationarity


Log Price Series Obs. Test-Statistic P-Value Conclusion

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U.S. Refined (Cane) 83 1.775 0.39 Fail to reject non-stationarity
U.S. Refined (Beet) 83 1.883 0.34 Fail to reject non-stationarity
World Refined 83 1.90 0.33 Fail to reject non-stationarity
World Raw (Cane) 83 2.31 0.29 Fail to reject non-stationarity
Note: All prices are monthly averages and are specified in natural logarithmic form.

no futures market for refined sugar in the Table 2. VECM Cointegration Results (Jan.
United States. We use the average monthly 2011–Dec. 2015)
spot price for refined cane sugar and the aver-
age monthly spot price for refined beet sugar Series Obs. v2 P-Value Conclusion
published by the Milling & Baking Cane; Beet 58 2688.647 0.00 Cointegrated
Magazine.7 The world refined price is the Cane; World 58 6.872 0.01 Cointegrated
nearby price for the ICE No. 5 London Daily Beet; World 58 6.769 0.01 Cointegrated
futures contract for white (i.e., refined) sugar
Note: All prices are monthly averages and are specified in natural logarith-
free-on-board in Europe.8 Deliveries under mic form.
the London No. 5 contract can be either re-
fined beet or cane sugar.
The start date is purposefully chosen as the world market would be fully passed
January 2011 to limit the analysis to the rele- through to the U.S. market (and vice versa).
vant market environment. The volume of A preliminary question is whether U.S. and
Mexican sugar exports to the U.S. increased
world sugar prices move together in this pol-
substantially in fiscal year (FY) 2011 and has
icy environment. To formally test whether
remained high since then (United States
U.S. prices and world prices are cointegrated,
International Trade Commission
we construct a vector-error correction model
[USITC] 2015). This change in export vol-
(Engle and Granger 1987). To verify that re-
umes likely affected the relationship between
fined cane and beet sugar prices were cointe-
U.S. and world prices, on which our regres-
sion analysis hinges. grated prior to the introduction of the
Table 1 presents Augmented Dicky-Fuller mandatory labeling law, we measure the coin-
(ADF) test statistics for monthly U.S. and tegrating relationship between Jan. 2011–
world sugar prices from Jan. 2011 to Dec. Dec. 2015. We remove later periods because
2017 (Dickey and Fuller 1979). The third col- they are potentially affected by the manda-
umn reports the corresponding MacKinnon tory labeling requirements. The analysis indi-
approximate p-value. As shown in table 1, we cates a statistically significant long-run
fail to reject the null hypothesis of non- cointegration relationship between all three
stationarity for all price series. In other price series (results are reported in table 2).
words, U.S. and world sugar prices follow a Prior to the imposition of GE labeling laws,
random walk. U.S. cane and beet refined sugar prices were
Under U.S. sugar policy, all sugar imports cointegrated with each other and each series
are subject to volumetric restrictions and all was cointegrated with world refined prices at
U.S. production is subject to marketing quo- the 99% level of confidence.
tas. In this setting, it is unlikely that shocks to

May, July, and October. Delivery on the No. 11 contract occurs


Structural Break Analysis
at a port in the country of origin free-on-board on the receiver’s
vessel. Delivery can originate in about 30 different countries, in- An important step in our analysis is to deter-
cluding Australia, Brazil, Costa Rica, and South Africa.
7
mine when the breakdown in the cointegrat-
Monthly prices obtained from table 5 and 5a of the ERS
Sugar and Sweeteners Yearbook. Prices are the simple average of ing relationship between monthly U.S.
the lower end of the range of quotations from Milling & Baking refined cane and beet prices occurred. We es-
News for days in each month.
8
Monthly prices obtained from table 2 of the ERS Sugar and
timate the following equation over the entire
Sweeteners Yearbook. sample period:
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 7

Table 3. Structural Break Test


Specification Estimated Break Sup. Wald P-Value Obs.

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Wald Levels Jul-2016 142.97 0.0000 84
Wald Logs Jul-2016 154.91 0.0000 84
L.R. Levels May-2016 119.34 0.0000 84
L.R. Logs May-2016 127.66 0.0000 84
Note: Trimmed sample runs from Feb. 2012–Dec. 2016 (15% trim).

Figure 3. Tests for break in U.S. beet-cane price relationship

ð1Þ Pct ¼ a þ bPbt þ et : in logs. The two tests are generally consistent.
July 2016 is the most likely date for the break
Variable Pct represents the U.S. price for re- in the Wald specification and the second-
fined cane sugar at time t, and Pbt is the corre- most-likely date in the L.R. specification.
sponding U.S. price for refined beet sugar. Similarly, May 2016 is the most likely date for
We consider Supremum Wald and the break in the L.R. specification and the
Likelihood Ratio (L.R.) tests for a structural second-most-likely in the Wald specification.
break at an unknown break date using a sym- Interestingly, the figure shows a substantial in-
metric, 15% sample trim (Quandt 1960; Kim crease in the both the Wald and L.R. statistic
and Siegmund 1989; Andrews 1993). for May 2014—the month the Vermont
We conduct the analysis with variables speci- Labeling Law was passed.
fied in both levels and natural logarithmic These findings strongly support the conclu-
form. sion that the break in sugar prices was the re-
Table 3 reports the results of the structural sult of the GE labeling initiatives. Food
break tests. All tests reject the hypothesis of manufacturers faced with the pending
no structural break with 99.99% confidence. Vermont legislation (and other state laws on
The Wald tests identify July 2016—the month the horizon) initially waited to convert to
the Vermont GE Labeling Law took effect GE-free ingredients in hopes that federal leg-
and the NBFDS was enacted—as the most islation would invalidate mandatory labeling
likely date when the structural break oc- rules. When the Vermont law became immi-
curred. The Likelihood Ratio tests identify nent, food intermediaries reformulated away
the break date two months earlier, in May from GE ingredients (beet sugar) towards
2016. non-GE ingredients (cane sugar), resulting in
Figure 3 plots Wald and L.R. statistics for a price premium for cane and a discount for
each candidate break date for the specification beet.
8 August 2018 Amer. J. Agr. Econ.

Table 4. Price Correlation Matrix Pre- and Post-July 2016


U.S. Ref. Cane U.S. Ref. Beet US Raw Cane World Raw Cane

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Pre Post Pre Post Pre Post Pre Post
U.S. Ref. Beet 1.00 0.57
U.S. Raw Cane 0.96 0.12 0.95 0.74
World Raw Cane 0.75 0.65 0.72 0.83 0.72 0.71
World Refined 0.74 0.61 0.71 0.91 0.71 0.76 0.99 0.98
Note: All prices are in natural logarithmic form.

There is still the possibility that the timing post-July 2016 correlations for refined-to-raw
of the GE labeling legislation and the price sugar have important implications for the dis-
divergence could have been coincidental. For tributional impacts of the policy. As noted in
example, the breakdown in the cane-to-beet the introduction, sugarcane is first processed
cointegrating relationship could have been into raw sugar and then sent to refiners for
caused by non-U.S.-centric factors or issues further processing into refined sugar. In con-
unique to the United States but occurring trast, sugar produced from sugarbeets does
elsewhere along the sugar supply chain. To not have a “raw” stage; processing is a single,
conclusively attribute the cane-to-beet price continuous process from beet to refined
break to mandatory labeling requirements, sugar. The fact that the price impact does not
one must consider these alternative explana- appear to have been transmitted to the raw
tions. For clarity and brevity, we focus on the stage of cane production suggests that—over
July 2016 candidate break in the analysis that the period of analysis—any benefits of the
follows. We have conducted a corresponding policy were most captured by cane refiners.
analysis for the May 2016 candidate break. The world market did not experience a diver-
Because the difference involves only two gence in the relationship between raw (cane)
data points from a much larger sample, point sugar prices and the price for refined sugar
estimates between the two breakpoints are (which may be filled with either cane or beet
virtually identical for all analyses that we sugar) in July 2016. As shown in the final two
have conducted. All findings and discussion columns of table 4, the correlation between
that follow are robust to the use of the May world raw and refined sugar prices was 0.99
2016 break date. before July 2016 and 0.98 afterward. The lo-
Table 4 reports the correlation between cus of the shock is the U.S. refined sugar
U.S. and world sugar prices (again in natural market.
logarithmic form) prior to and after July
2016. As shown in column 1, the U.S. refined Price Impact
cane price and the U.S. refined beet price had We now turn to the question of impact—
a correlation of 1.00 prior to July 2016. In what would U.S. refined sugar prices have
other words, a shock to the cane price was been in the absence of GE labeling legisla-
fully transmitted to the beet price, and vice tion? We treat the introduction of Vermont’s
versa. The prices were perfectly co- GE labeling law as a quasi-natural experi-
integrated. However, following the July 2016 ment making use of two findings from the
break, the correlation between the two price previous section to identify impact. First,
series fell to 0.57, indicating a breakdown in U.S. sugar prices were highly correlated with
the relationship. world sugar prices prior to the law taking ef-
Within the U.S. market, the July 2016 fect (rows 3 and 4 of table 4). Second, world
break appears to have been isolated to re- prices were unaffected by the Vermont law
fined sugar. Turning to row 2 of table 4, the (columns 7 and 8 of table 4). Taken together,
correlation between the U.S. refined cane these factors suggest that world sugar prices
price and the U.S. raw cane price fell from constitute an almost-ideal control against
0.96 to -0.12 following the break. The correla- which to assess the effects of the Vermont
tion between U.S. refined beet and U.S. raw law.
cane went from being highly positive (0.95) One method by which to identify the treat-
to highly negative (-0.74). These pre- and ment effects of a mandatory labeling law
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 9

would be an experimental design. Kiesel Table 5. U.S.-World Sugar Price


and Villas-Boas (2013), for example, use a Relationships, Pre- and Post-Vermont GE
difference-in-difference (DD) model to iden- Labeling Law

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tify the effects of mandatory nutrition label- VARIABLES (1) (2)
ing on consumer behavior. However, such an Log U.S. Log U.S.
approach requires strict assumptions. One of Ref. Beet Ref. Cane
these assumptions, known as the parallel Price Price
trends assumption, requires that—in the ab-
Constant (a) 0.96*** 1.01***
sence of treatment—the average outcomes (0.28) (0.26)
for the treated and control groups would GE Law (d) 3.63*** 3.00***
have followed parallel trends over time (0.31) (0.28)
(Abadie 2005). The time-series properties of Pre-Law*World 0.84*** 0.84***
our data and the restrictive U.S. policy envi- Ref. Price (b)
ronment suggest that our setting fails to meet (0.09) (0.08)
this assumption.9 Post-Law*World 0.39*** 0.15***
Ref. Price (c)
Rather than a pure experimental approach,
(0.04) (0.04)
we construct a standard regime-switching Observations 84 84
model to compare the historically observed R-squared 0.56 0.55
relationship between U.S. and world refined
Note: Robust standard errors appear in parentheses; Asterisks indicate the
sugar prices prior to the introduction of the following: *** ¼ p < 0.01, ** ¼ p < 0.05, and * ¼ p < 0.1.
Vermont GE Labeling Law with the ob-
served relationship on and after July 2016. In
contrast to the DD design, the regime-
switching model only requires that U.S. and Results from the regime-switching regres-
world prices were correlated prior to July sion model for beet and cane prices, respec-
2016 and that world prices were unaffected tively, are shown in columns (1) and (2) of
by U.S. labeling requirements. We assess the table 5. Comparing results across columns,
impact of GE food labeling legislation by we see that the coefficient on the
comparing the price series for U.S. refined pre-labeling-law world price is identical for
cane and beet sugar implied by the pre- and U.S. beet and cane prices (0.84) and statisti-
post-legislation coefficient estimates. We esti- cally significant at 99% confidence. This re-
mate the following regime-switching model: sult is as expected: prior to the introduction
of the law, U.S. cane and beet prices tracked
closely with each other and with world prices.
ð2Þ Pt ¼ a þ dkt þ ð1  kt Þbwt þ ckt wt þ et The results in table 5 lend credence to our de-
cision not to use a DD estimation approach.
from Jan. 2011 to Dec. 2017, where P is, alter- Even prior to July 2016, U.S. and world pri-
natively, the U.S. refined cane sugar price and ces did not follow a parallel trend. Wald tests
the U.S. refined beet sugar price. Subscript t reject the restriction that b ¼ 1 for both the
denotes time. Variable w represents the ICE cane and beet equations.
No. 5 white sugar price (i.e., the world refined In both equations, the Vermont law
sugar price). All prices are monthly and are appears to have had two effects on U.S.-
specified in natural logarithmic form. Variable world price relationships. First, it drove a
k is an indicator variable equal to unity in peri- wedge between U.S. and world prices (shown
ods on and after July 2016, and equal to zero by variable “GE Law”), and, second, it re-
otherwise. Parameters a; d; b; c; e are esti- duced the U.S.-world price-cointegrating re-
mated. Alternative models and specifications lationship (shown by variable “Post-
are considered below. Law*World Ref. Price”). Each result is inde-
pendently significant at the 99% level.
These effects are also jointly statistically
9
We note that the synthetic control method does not require significant. Table 6 reports the results of sev-
the parallel trend assumption. Instead, it uses a comparator con-
structed as a weighted average of all available control units
eral post-estimation Wald tests. For both the
(Abadie, Diamond, and Hainmueller 2010). The weights are cho- cane series and the beet series, we reject the
sen to ensure that, prior to the intervention, levels of covariates joint hypothesis that there was no price
and outcomes are similar over time to those of the treated unit.
This method is unnecessary here because we rely on a single— wedge and that the U.S.-world cointegrating
but well-chosen—control: the world sugar price. relationship was unchanged following the
10 August 2018 Amer. J. Agr. Econ.

Table 6. Post-Estimation Wald Tests


U.S. Ref. Beet Price U.S. Ref. Cane Price

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Null Hypothesis Wald Statistic P-Value Wald Statistic P-Value
d¼0 134.43 0.000 113.65 0.000
c¼b 137.02 0.000 68.23 0.000
d¼0, c¼b 155.33 0.000 121.35 0.000

Figure 4. Counterfactual price forecast


Note: Confidence intervals for GE-law-regime price series are constructed using the Bayesian Bootstrap method with 1,000 draws from the posterior distribu-
tion for each parameter estimate from columns (1) and (2) of table 5.

introduction of the law (i.e., d ¼ 0; c ¼ b). structural break using the pre- and post-
Similarly, for each equation, we reject with structural-break coefficient estimates from ta-
99% confidence the hypothesis that the U.S.- ble 5. The counterfactual estimate (CF) for
world cointegrating relationship was the what U.S. refined sugar prices would have
same prior to and following the introduction been had the Vermont Law not taken effect
of the Vermont Law (i.e., d ¼ b). ^  wt . Post-regime
is calculated as CFt ¼ ^a þ b
These findings are entirely consistent with beet and cane prices are calculated as
the theoretical effects of mandatory GE label- ^ t ¼ ^a þ ^d þ ^c  wt .10
P
ing. First, the law induces a price premium (or Constructed CF and Post-law-regime price
discount) for non-GE (GE) products relative to series are shown in logs in figure 4 and sum-
what the price would have been in the absence marized in levels in table 7. Our estimation
of the legislation. Second, GE and non-GE suggests that, in the absence of GE labeling
products are no longer interchangeable in legislation, the average U.S. refined sugar
regions that are de facto subjects to labeling price would have been approximately
requirements. Thus, such laws reduce integra-
tion with external markets that continue to treat
the GE and non-GE products as homogenous. 10
Note that we have actual observations for “post-regime”
The total impact of the Vermont labeling beet and cane prices. We use our predicted estimates instead of
law on U.S. refined sugar prices is the aggre- actual prices to isolate the impact of Vermont law. A variety of
gate effect from the two forces discussed demand and supply factors not related to the Vermont law can
impact U.S. and world prices in any given month. By focusing on
above. We estimate this impact for the 12- the average relationship over time, we eliminate (or at least sub-
month period immediately following the stantially reduce) the biases created by these extraneous factors.
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 11

Table 7. Impact of GE food Labeling Laws and other import restrictions for international
on U.S. Sugar Prices suppliers. These supply constraints drive U.S.
prices above world prices, and—even in light

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Refined Average Price: Impact of
Price Series
of falling prices—the domestic market is
July 16–Dec. 17 Labeling Laws much more attractive than the export market.
(¢ per lb.) (% Change) Moreover, marketing allotments reduce the
incentive to store excess sugar because sugar
U.S. Cane 35.38 1.0 stored today must compete with future pro-
(3.49) duction to meet quota restrictions.
U.S. Beet 30.54 21.7 Figure 5 compares monthly domestic deliv-
(1.26) eries from July 2016–June 2017 (the 12-
Counterfactual 35.03
(3.49) month period after the structural break) with
the domestic deliveries for the same months
Note: Standard deviation appears in parentheses. in the previous year. As one would expect
given the supply constraints under the U.S.
sugar program, there appears to be no appre-
ciable difference in domestic cane deliveries
35.38¢ per lb. Over the same period, we de- in the 2016/17 period relative to the 2015/16
rive an “actual” post-regime average price of period (in panel (b) of figure 5). On the other
35.03¢ per lb. for cane sugar and 30.54¢ per hand, beet deliveries in panel (a) of figure 5
lb. for beet sugar. A comparison of counter- appear to have expanded in the 2016/17 pe-
factual and post-regime prices suggests that riod relative to 2015/16. The increase in do-
the legislation reduced beet prices by approx- mestic deliveries is due—at least in part—to
imately 12.8% over the period and raised favorable weather conditions and higher-
cane prices by 1.0%. than-expected yields (USDA ERS 2017).
However, if (counter to expectations) some
portion of the expansion in beet deliveries is
Implications for Producer Welfare the result of the breakdown in the co-
integrating price relationship, implications
We now turn to a discussion of the implica- are twofold.
tions for producer welfare. To evaluate the First, the use of observed domestic deliveries
revenue impacts of mandatory labeling initia- to calculate gross receipts represents a lower
tives on U.S. cane refiners and beet process- bound for the estimated costs of GE labeling
ors (shown in figure 2 as ðPCane  Pf ÞQCane laws on U.S. beet processors. Second, and per-
and ðPf  PBeet ÞQBeet , respectively), we calcu- haps more importantly, the extent to which the
late gross receipts as the product of observed cane-to-beet price wedge is permanent is an
domestic deliveries and actual versus coun- open question. If U.S. beet processors, faced
terfactual prices.11 with falling beet prices, chose to increase deliv-
Note that this welfare measure may mis- eries as opposed to increasing temporary stor-
state welfare impacts if sugar processors age, it may imply that beet processors regard
responded to changes in sugar prices by the price wedge as permanent.
adjusting marketings. For example, one could Post-Vermont regime and counterfactual
imagine that, in light of falling domestic beet monthly gross receipts for U.S. cane and beet
prices, U.S. beet processors may have processors are reported in table 8. Over the
responded by shifting away from the domes- 12-month period after the Vermont GE la-
tic market towards markets abroad, increased beling law took effect, mandatory labeling
storage volumes, or deliveries for non-human requirements have cost U.S. beet processors
approximately $435 million. Yet the premium
consumption (e.g., ethanol refineries).
created for non-GE food ingredients has not
Aspects of the U.S. sugar program makes
resulted in a symmetric windfall. The U.S.
such adjustments extremely unlikely. The
cane sector gained only about $40 million as
USDA administers marketing allotments a result of the law. Note also the finding
(i.e., production quotas) to U.S. processors above that the raw-to-refined price relation-
ship broke down after July 2016. This sug-
11
gests that the $40 million likely was received
Data on domestic cane and beet deliveries by U.S. process-
ors are obtained from table 19 of the ERS Sugar and Sweeteners by cane refiners, and was not passed on to
Yearbook. growers in the form of higher cane prices.
12 August 2018 Amer. J. Agr. Econ.

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B

Figure 5. Domestic cane and beet deliveries


Note: Domestic cane and beet deliveries obtained from ERS Sugar and Sweeteners Yearbook table 19.

Table 8. U.S. Sugar Industry Gross Receipts (GE Law vs. No Law Scenario)
Gross Receipts, July ‘16–June ‘17
Deliveries GE Law No Law Difference
(1,000 STRV) (Million Dollars)
Beet 5,188 $2,961.56 $3,396.97 $435.40
Cane 6,187 $4,091.25 $4,050.77 $40.48
Note: Gross receipts are obtained by multiplying GE Law & No Law prices by domestic deliveries (1.07 raw-to-refined conversion rate).

The substantial imbalance between the the deadweight loss of GE labeling require-
losses to beet processors and the gains to ments. Losses to beet processors are in part
cane refiners is only partically connected to offset by a gain to food manufacturers
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 13

Table 9. Robustness: Alternative Controls and Confounding Factors


VARIABLES (1) (2) (3) (4)

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Log U.S. Log U.S. Ref. Log U.S. Ref. Log U.S. Ref.
Ref. Beet Price Cane Price Beet Price Cane Price
GE Law 2.890*** 2.453*** 4.286*** 3.691***
(0.288) (0.247) (0.410) (0.362)
Pre-Law*World Price 0.733*** 0.723*** 1.101*** 1.107***
(0.082) (0.076) (0.137) (0.122)
Post-Law*World Price 0.335*** 0.148*** 0.388*** 0.148***
(0.052) (0.034) (0.044) (0.037)
ADCVD 0.196** 0.207***
(0.078) (0.068)
Constant 1.473*** 1.526*** 0.113 0.114
(0.243) (0.228) (0.449) (0.399)
Observations 84 84 84 84
R-squared 0.572 0.565 0.613 0.624
Note: Robust standard errors appear in parentheses. Asterisks indicate the following: *** ¼ p < 0.01, ** ¼ p < 0.05, and * ¼ p < 0.1.

purchasing beet sugar. Likewise, the gain to are almost perfectly correlated over the sam-
cane refiners is offset in part by a loss to food ple period (table 4).
manufacturers purchasing cane sugar. Lower Next, we consider confounding factors.
costs to GE products may also be passed Beginning in January 2011, Mexican sugar
through to consumers in the form of exports to the U.S. increased substantially.
lower food prices. The magnitude of these This surge in imports gave rise to antidump-
offsets—and in turn the deadweight loss—is ing and countervailing duty (ADCVD) pro-
dependent on the elasticities of demand in ceedings, which, in December 2015,
each market. culminated in volumetric and price restric-
tions on Mexican sugar exports to the United
States (USITC 2015). Carter, Saitone,
and Schaefer (2017) find that these restric-
Robustness and Sensitivity
tions impacted the U.S.-world price relation-
ship. We control for this by including an
In this section, we use alternative specifica- indicator variable in the regime-switching
tions to examine the robustness of our model. model equal to unity for all time periods after
We consider the inclusion of alternative and December 2015 (and zero otherwise). The
additional controls, the possible existence of world price is again the world refined price.
confounding factors, and the implications of Estimation results for this specification are
our time-series data. The percentage impact reported in columns (3) and (4) of table 9.
of Vermont labeling requirements on U.S. re- Coefficient estimates imply the Vermont law
fined sugar prices implied by these alternative reduced beet prices by 16% and increased
specifications ranges from 1% to 13% for cane prices by 13%.
cane and 10% to 16% for beet. Another potential estimation issue relates
Columns (1) and (2) of table 9 present the to the time-series properties of our data.
results from re-estimating the regime- Spurious correlation caused by non-
switching model shown in equation 2 using stationarity in our data could lead to incor-
the world raw price as the control variable rect inference. The risk of spurious correla-
rather than the world refined price. tion is low in this setting because of the
Consistent with the findings in table 5, the commodity nature of sugar—market prices
Vermont law drives a wedge between U.S. move together. However, for the sake of ro-
and world prices and reduces the level of in- bustness, we correct for non-stationarity via
tegration between the two markets. These first-difference estimation.
results imply a price impact that is nearly Results from re-estimating equation (2) in
identical to that discussed above for both first differences are reported in columns (1)
cane and beet prices. This is not surprising and (2) of table 10, respectively, for beet and
because world raw and refined sugar prices cane prices. First-differencing substantially
14 August 2018 Amer. J. Agr. Econ.

Table 10. Robustness: First-Difference Estimation


(1) (2) (3) (4)

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Log U.S. Log U.S. Log U.S. Log U.S.
VARIABLES Beet Price Cane Price Beet Price Cane Price
GE Law 0.020*** 0.017*** 0.022*** 0.017***
(0.006) (0.006) (0.005) (0.008)
Pre-Law*World Price 0.015 0.146*** 0.019 0.147**
(0.047) (0.049) (0.005) (0.058)
Post-Law*World Price 0.003 0.141*** 0.007 0.143**
(0.47) (0.049) (0.052) (0.056)
ADCVD 0.002 0.001
(0.008) (0.008)
Constant 0.009* 0.007 0.009 0.007
(0.005) (0.005) (0.007) (0.007)
Observations 83 83 83 83
R-squared 0.06 0.08 0.06 0.08
Note: Robust standard errors appear in parentheses. Asterisks indicate the following: *** ¼ p < 0.01, ** ¼ p < 0.05, and * ¼ p < 0.1.

reduces the precision of our estimates, but harsh penalties for food manufacturers found
findings are unchanged in substance. Turning to be in violation of labeling requirements.
first to column (1), the GE law drives a 2% Congress responded soon after the Vermont
(positive) wedge between U.S. beet and law took effect with the successful promulga-
world refined prices. Coefficients on first- tion of the National Bioengineered Food
differenced world prices are insignificant. Disclosure Standard (NBFDS). The NBFDS
The point estimate falls from 0.015 to 0.003. nullifies all state-level attempts to establish
Combining the two effects implies a 10% re- mandatory labeling rules, and instead
duction in U.S. refined beet prices as a result imposes disclosure requirements at the fede-
of the Vermont Law. Cane results in column ral level. Many aspects of the NBFDS are
(2) show a 1.7% increase in Cane prices as a currently subject to public comment and re-
result of the Labeling Law. Coefficients on main to be finalized.
world refined prices are significant at 99% In the period surrounding the implementa-
both before and after the imposition of the tion of Vermont Act 120, commodity markets
law, but the post-law coefficient is not signifi- responded. In this research, we investigate
cantly different from the pre-law coefficient. the response in the U.S. sugar market. In
In columns (3) and (4), we add the indicator mid-2016, refined cane sugar began selling at
variable that controls for the imposition of a substantial premium over refined beet
the U.S.-Mexico ADCVD suspension agree- sugar. Our analysis supports the explanation
ments. Results are similar to those in columns that the divergence in U.S. prices for refined
(1) and (2) and imply a 9.8% reduction in cane and beet sugar was the result of
beet prices and a small ( 1%) increase in Vermont’s mandatory GE labeling. The di-
cane prices as a result of the law. vergence occurred on or around July 2016—
the month the Vermont Act took effect.
Counterfactual price estimates generated
Conclusion by a regression model suggest that GE food
labeling initiatives generated a small pre-
In the United States, a push for mandatory mium for cane sugar and a price discount for
labeling of GE foods began in Oregon, beet sugar of approximately 13% relative to
California, and Washington and rippled what prices would have been in the absence
through at least one-half of all U.S. states. In of such legislation. An open question is
many ways, Vermont Act 120, which passed whether the new cane-to-beet price wedge is
in May 2014 and took effect in July 2016, was permanent or, alternatively, whether prices
the culmination of those efforts. The law re- will converge again once the U.S. Food and
quired that (with a few exemptions) foods Drug Administration (FDA) has offered final
containing GE ingredients sold for home con- guidance on NBFDS compliance. Increased
sumption be labeled. The law also established domestic deliveries by U.S. beet processors in
Carter and Schaefer Impacts of Mandatory GE Food Labeling: A Quasi-Natural Experiment 15

the face of falling beet prices suggests that Journal of the Econometric Society 61
growers believe the price wedge may be per- (4): 821–56.
manent. Implications extend beyond the U.S. Artuso, A. 2003. Risk Perceptions,

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sugar industry to other ingredients containing Endogenous Demand and Regulation of
GE. Agricultural Biotechnology. Food Policy
We stress that our estimates are only a par- 28 (2): 131–45.
tial measure of the welfare effects of the Berning, J.P., H.H. Chouinard, and J.J.
Vermont law. Our results should also be McCluskey. 2010. Do Positive Nutrition
regarded as short-run estimates of the pro- Shelf Labels Affect Consumer Behavior?
ducer welfare impacts. We do not consider Findings from a Field Experiment with
downstream or long-run implications of the Scanner Data. American Journal of
legislation. In the future, producers may Agricultural Economics 93 (2): 364–69.
lobby for changes to quota allotments or Bovay, J., and J.M. Alston. 2018. GMO Food
other aspects of U.S. sugar policy to mitigate Labels in the United States: Economic
the impacts of labeling policies. New technol- Implications of the New Law. Food
ogies, such as the GE sugarcane varieties cur- Policy 78: 14–25.
rently being tested in Brazil (Mano 2017), Carter, C.A., and G.P. Gruère. 2003a.
may also alter future returns to GE versus International Approaches to the
non-GE foods in the United States and Labeling of Genetically Modified Foods.
abroad. Choices 18 (2): 1–4.
Finally, to understand the full effects of the ———. 2003b. Mandatory Labeling of
legislation, one would need to formally incor- Genetically Modified Foods: Does It
porate the consumer benefits (or costs) of the Really Provide Consumer Choice?
policy. However, we believe the consumer- AgBioForum 6 (1&2): 68–70.
level effects are likely to be small—at least in Carter, C.A., G.P. Gruère, P. McLaughlin,
the short run–in the current context. We cite and M. MacLachlan. 2012. California’s
two primary reasons for this belief: First, be- Proposition 37: Effects of Mandatory
cause sugar prices represent a small share of Labeling of GM Food. ARE Update 15
the final food dollar for processed foods, a (6): 3–8.
change in the relative prices of GE and non- Carter, C.A., T.L. Saitone, and K.A.
GE ingredients is unlikely to have a substan- Schaefer. 2017. Managed Trade: The
tial effect on food prices. Second, the results U.S.-Mexico Sugar Suspension
documented here are unlikely to result in Agreements. Working Paper.
substantial information to the consumer. At Chang, X. 2006. Labeling policy and impact on
the retail level, the regime change is not one consumer’s purchasing behavior in China:
from the absence of labels to the presence of A case study of vegetable oils in Nanjing.
labels. Prior to the implementation of the InInternational Food Policy Research
Vermont law, products featuring GE-free Institute (IFPRI) and Research and
and organic labels were readily available. Information Systems for Developing
Countries (RIS), Economic Consideration
of Biosafety and Biotechnology
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