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Cultivated Meat Snapshot: Recent Federal and State Actions

Food & Consumer Packaged Goods Litigation

Cultivated Meat Snapshot: Recent Federal and State Actions

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At both the federal and state levels, 2025 has seen new developments for cell-cultured meat. Here we provide an overview of cell-cultured meat (also known as cultivated meat) and these recent regulatory developments.

What Is Cell-Cultured Meat?

Cell-cultured meat grows in a controlled environment from cells. Broadly speaking, manufacturers take a sample from a living animal. The selected cells are then placed in a tightly controlled environment that supports their growth. Producers may also add other substances, such as protein growth factors or edible polymer scaffolds, to encourage the sample cells to develop into muscle, fat, and connective tissue. The cells multiply into many billions or trillions of cells, growing into cell-cultured meat.

Federal Regulatory Developments

The regulatory landscape for cultured meat continues to evolve at the federal level. On May 28, 2025, the U.S. Food and Drug Administration (FDA) issued a “no questions” letter to Wildtype, Inc., for its cultured salmon product. This letter indicates that the FDA has no further questions regarding the manufacturer’s safety determination for the product’s intended use before it enters the market. This is the first such letter for cultured salmon and the fourth overall for cultured meat products. Previous “no questions” letters were issued to manufacturers of cultured chicken and pork products. 

State Bans on Cultivated Meat

On June 20, 2025, Texas Governor Greg Abbott signed into law Senate Bill 261 (SB 261), prohibiting the manufacture, processing, possession, distribution, offer for sale, or sale of cell-cultured protein in Texas, effective September 1, 2025. The legislation defines “cell-cultured protein” as a food product derived from harvesting animal cells and artificially replicating those cells in a growth medium to produce tissue.

With this action, Texas becomes the latest state to ban or restrict the sale of cultivated meat. Other states with enacted bans include Alabama, Florida, Indiana, Mississippi, Missouri, Montana, and Nebraska.

State Labeling Requirements

While some states have put outright bans into effect, other states have proposed labeling requirements. Missouri was the first state to take steps to regulate the labeling of cultivated meat products through SB 627, which “prohibits misrepresenting a product as meat that is not derived from harvested production livestock or poultry.” Iowa has enacted similar labeling requirements with SF 2391. On February 18, 2025, the North Carolina general assembly proposed H.B. 134, which would require companies selling cultured meat products to clearly indicate the products’ cell-cultured origins on packaging. 

The regulatory environment for cultured meat products remains dynamic, with significant variation across states and ongoing federal oversight. We will continue to monitor developments in this area.

For further information or specific inquiries, please contact the firm’s Food & Beverage regulatory team.

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TTobin@perkinscoie.com

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EMolineux@perkinscoie.com

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Before proceeding, please note: If you are not a current client of Perkins Coie, please do not include any information in this e-mail that you or someone else considers to be of a confidential or secret nature. Perkins Coie has no duty to keep confidential any of the information you provide. Neither the transmission nor receipt of your information is considered a request for legal advice, securing or retaining a lawyer. An attorney-client relationship with Perkins Coie or any lawyer at Perkins Coie is not established until and unless Perkins Coie agrees to such a relationship as memorialized in a separate writing.

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