Legal Culture and Food Culture in Labelling Regulation: An EU/US Comparative Analysis

Abstract This essay analyses several elements of food labelling regulation by comparing European and US models. In particular, food labelling is examined as an outcome of the interaction between legal culture and food culture as well as of the competition between public and private regulators. Indeed, the different functions of labelling (both as an informative and as a marketing tool) and the cultural divergences between the two models compel us to consider the cultural environment in which labelling is regulated and applied. These intricate phenomena are tackled by analysing the most heavily debated issues, such as health claims, Genetically Modified Organisms and Country of Origin Labelling. For each issue, different cultural drivers, as they relate to consumers, businesses and institutions, are compared. Concluding remarks stress divergences and convergences between the two models and propose some insights regarding the use of the notion of culture in global and comparative food law research.