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Abstract

Meat grown outside an animal is no longer simply science fiction, and the market is poised for introduction of a variety of so-called cell-based meat products. Commercializing these products will require a clear regulatory path forward. In this Article, we explore that legal pathway. We introduce the concepts of cellular agriculture and cell-based meat, including the science, the state and history of the industry, and the general regulatory background, in which the USDA and FDA are the major players. Further, we explore in particular regulatory aspects of food safety and labeling in the context of cell-based meat. Overall, we contend that there is a viable pathway forward for cultivated meat companies under the current regulatory scheme. But a nontrivial degree of uncertainty remains, and regulators would do well to be proactive in issuing guidance in this space. Moreover, cell-based meat remains vulnerable to legal challenges.

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