AN OPEN LETTER FROM DIVERSE-STAKEHOLDER MUSHROOM COMPANIES ON NAMMEX CITIZEN PETITION TO FDA
Although Fungi Perfecti, LLC, M2 Ingredients Inc., Gourmet Mushrooms, Inc., and Monterey Mushrooms Inc. are competitors, we are unified to emphasize the importance of conveying scientifically accurate information to the public, to FDA, and to other thought leaders in the field. From this standpoint we are responding to the puzzling opinion presented in the recent FDA Citizen Petition submitted by Nammex, and find that their position obfuscates the use of well-established mycological definitions.
In this Citizen Petition, Nammex advocates to eliminate the use of the word ‘mushroom’ in products using mushroom mycelium. Our collective use of ‘mushroom mycelium’ is scientifically accurate, just as the use of ‘mushroom spores’, ‘mushroom fruit bodies’ are descriptively accurate. 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. Below The Mushroom Life Cycle diagram, as it appears in The Mushroom Cultivator by Paul Stamets & Jeff Chilton, depicts clearly-named stages of the mushroom life cycle.