According to the letter, the position presented by Nammex “obfuscates the use well-established mycological definitions.”
The leaders of Fungi Perfecti LLC, M2 Ingredients Inc., Gourmet Mushrooms Inc., and Monterey Mushrooms Inc. have signed an open letter criticizing a recent Citizen Petition filed by Nammex. According to the letter, the position presented by Nammex “obfuscates the use well-established mycological definitions.”
Nammex makes the case in its Citizen Petition that a product should not be labeled as containing “mushroom” if it is made from mushroom mycelium, and should instead be identified by their specific fungal parts. Nor is the term “mushroom mycelium” an accurate description of fungal ingredients, argues Nammex, because they are two separate and distinct parts of the fungi. The parties in the open letter dispute Nammex’s position, calling it “puzzling.”
“Our collective use of ‘mushroom mycelium’ is scientifically accurate, just as the use of ‘mushroom spores’, ‘mushroom fruit bodies’ are descriptively accurate,” states the letter. “The word ‘mushroom’ describes the organism itself, whereas terms like ‘mycelium’ and ‘fruit body’ refer to distinct parts of the mushroom organism. This is perfectly parallel to saying ‘plant roots’, ‘plant seeds/spores’, and ‘plant flowers’. Both sets of terminologies describe the parts of the organism. To propose the elimination of the word ‘mushroom’ (again, the name of the organism), results in confusion; for example, ‘mycelium’ on its own would not distinguish mold mycelium from mushroom mycelium.”
Where they do agree with Nammex is the label disclosure of “fungal part/growth stage” of mushroom ingredients. The letter cites guidance from the American Herbal Products Association (AHPA; Silver Spring, MD). The letter goes on to criticize Nammex for recommending a “questionable” method for the detection of beta glucans which is known to provide disparate results and has not been validated by the Association of Official Agricultural Chemists. Additionally, the letter states that beta glucans in mushrooms are just one beneficial compound which alone do not indicate biological activity.
“As experts, we continue to be concerned by confusion seeded by Nammex of widely-accepted and settled terminology, and are moved to write so that industry policies will be grounded in scientific accuracy,” the letter concludes. “This is critical for clear and sound regulations. We advocate for truth and scientific accuracy in labeling. In our opinion, Nammex’s proposals do neither. We do not have any issues with mushroom fruit bodies. We utilize this life stage as well. We find mushroom mycelium has added benefits as demonstrated by scientific research.”