Scholarly debate over the transformative potential of neoliberal, market-based, food movement strategies historically contrasts those who value their potential to reform the food-system from the inside against those who argue that their use concedes the primacy of the market, creates citizen-consumers, and undermines overall movement goals. While narrow case studies have provided important amendments, the legacy of such strategies requires impacts to be evaluated both contextually and more broadly than the specific activism. This study thus conceptualizes the ‘case’ of U.S. biotechnology market activism expansively, drawing on interviews with 25 activists from diverse organizations to investigate the legacy of two food-labeling movement strategies (one public and mandatory, one private and voluntary). The results support that the legacy of market strategies extends more broadly than the immediate initiative. They also confirm that the consequences of such neoliberalized strategies are most productively assessed contextually and applied, rather than categorically—as most clearly illustrated by the counterintuitive results of the failed mandatory labeling effort. Of the two market strategies, voluntary labeling demonstrated the most problematic relationship to broader movement goals of food system transformation, in part because of the greater potential for overlapping credence claims and in part due to the risks of niche market logic.