How to Navigate Non-GMO Verification

Growing demand by consumers for non-GMO choices coupled with existing and emerging global GMO regulatory requirements and regional non-GMO market initiatives have compelled the global food industry to participate in third-party-verified non-GMO programs at an unprecedented rate.

Europe’s GMO labeling regulations EC 1829 and 1830, in effect for more than 13 years, have been serving as the benchmark for other international labeling regulations and non-GMO initiatives such as Ohne Gentechnik, Nourri Sans OGM and Gentchnik-Frei.

All global non-GMO verification programs have some commonality in compliance requirements such as traceability and segregation. Each verification program can also have significant differences, such as different GMO content tolerance thresholds; authorized or unauthorized GMO events requiring unique GMO testing strategies; ingredient matrix exclusions such as requiring testing of high GMO risk animal feed or fermentation media.

Unless manufacturers are prepared ahead of time for the requirements, participating in and maintaining compliance with a non-GMO verification scheme can be frustrating, especially when pressure to provide non-GMO verified products is at an all-time high. 

10 Steps for a Successful Experience
Here are some steps a manufacturer can take to avoid some of the common challenges to achieving compliance with non-GMO verification programs.

1) Consult with the non-GMO scheme technical administrator (the verifying body) before selecting products for participation. This consultation will be extremely valuable in helping set the stage for success. GMO risk ingredients can be identified and pathways to removing such risk and lowering costs can be implemented. For example, switching from soy oil to sunflower oil may change the GMO risk, resulting in lower program costs. Compliance challenges can be identified upfront as well. For example, products containing animal derivatives such as whey or eggs may be difficult to document for compliance. 

2) Set reasonable expectations for achieving verification, calibrated to the complexity of the product line. Low GMO risk baby food, for example, may take two months or less for product verification. Supplements may take upward of 18 months. Sampling and GMO strategies may need to be developed that are optimal to the supply chain.

3) With complicated and/or large numbers of products in a product line, consider a staged enrollment plan. Start with a few products using the greatest number of shared ingredients. This will ease the severity of the learning curve and lessen the work overload for the quality department.

4) Staged enrollment leads to achieving a staggered timeline in verification of products. Sometimes products within the same line achieve verification at different times. Consumers may ask why all products are not verified at once. Develop a positive public education message that addresses any differences between consumer expectations of having all products verified and the incremental steps being taken to incorporate non-GMO verification. For example, if the manufacturer has always had a non-GMO policy, explain the necessary work in the context of supporting the already existing policy.

5) Invest in education and increased staffing to accommodate the workload. Achieving a non-GMO designation for a product is not a static occurrence. GMO approval and commercialization statuses change. Standards evolve to accommodate shifting regulatory and market environments and GMO testing requirements are updated to accommodate new GMO events. The process for vetting new vendors becomes more rigorous. Vendor changes require the approval of the technical administrator. Production staging to mitigate risk of GMO contamination in manufacturing environments with parallel production and additional inspection requirements may be necessary.

6) If GMO testing is required for high GMO risk ingredients, seek support from a non-GMO scheme-approved, accredited GMO testing laboratory. Different ingredient matrices require different strategies for taking representative samples for analysis. Testing packages differ depending on crop species and GMO events. Certain processed ingredient matrices are not suitable for GMO testing since PCR testing, a DNA-based testing method required by most non-GMO verification programs, requires intact DNA.

For example, the DNA in refined oils is degraded and can’t be tested for GMO content. Instead, sampling and testing may need to be performed at the crude oil stage or even earlier in the supply chain at the level of the pre-crush oil seed. In addition, sample sizes are different for varying ingredient matrices. FoodChain’s sister company, Genetic ID, provides consultation on sampling and testing programs as a part of its customer service platform.

7) Start gathering data from ingredient vendors even before participation. Use a standardized data collection form designed to gather all relevant information, such as the form used by the technical administrator. Relevant data will include disclosure of additives, carriers, enzymes, microorganisms, fermentation media, raw material sources and non-GMO manufacturing processes. Unsupported vendor claims will not demonstrate compliance.

8) As part of a new-vendor vetting process, require the vendor to participate in the non-GMO verification program. Alternatively, ask the technical administrator to pre-evaluate vendor documentation for compliance with the standard.

9) Formulate new products with compliance in mind. Manufacturers that do this can have their finished products verified in very short order. Consult with the technical administrator to pre-evaluate the new formulations for compliance, which will substantially shorten the path to verification. 

10) With complicated product formulations such as supplements, consider joining a working group of industry colleagues to develop non-GMO compliant ingredient sources. For example, the Dietary Supplement Working Group is a collection of manufacturers and their suppliers, working together to develop compliant vitamin sources to be shared by anyone requesting the information.

The New Food Industry
Taking a systematic approach to non-GMO verification isn’t required. Many manufacturers just enroll, gathering data and learning compliance requirements as they go. For manufacturers with little or no GMO risk in their products, reasonable efficiency in success can be the experience. For many manufacturers facing complicated ingredients and high GMO-risk requirements, the process can be time-consuming and surprises are not uncommon.

For example, one manufacturer discovered an ingredient vendor had replaced sugar cane (a low GMO risk) with GMO beet sugar (a high GMO risk). In another example, high fructose corn syrup had replaced cane sugar. In yet another, a vendor had not disclosed the presence of high GMO risk maltodextrin as a carrier. These examples demonstrate how important it is for manufacturers to gather and review vendor documentation. 

Consumer non-GMO choice initiatives, GMO labeling regulations and growth in global non-GMO verification programs are infusing never-before-required transparency into the GMO status of the supply chain. In many ways this is a new paradigm for a New Food Industry, in which each stage of the supply chain is responsible for documenting non-GMO compliance for all the precursor stages. The ultimate efficiency is to have every stage enrolled in reciprocal, equivalent third-party non-GMO verification programs, installing GMO testing where required as early in the supply chain as possible. Then, through GMO risk-mitigating traceability and segregation manufacturing practices throughout the supply chain, it is possible to maintain the non-GMO status of any ingredient or product.

A long-term view of successful entry into the non-GMO market is achievable through steps of incremental transformation, a transformation that includes not only a product’s ingredients but also a manufacturer’s understanding and successful management of the industry’s complex and changing standards. A manufacturer who has taken these action steps toward compliance of the entire food chain will be most intelligently prepared to enter global markets under any non-GMO verification program, therefore taking full advantage of growing international demand for non-GMO options.  

---

Sandra Kepler is CEO of FoodChain Global Advisors, the founding technical consultant and technical administrator of the Non-GMO Project’s product verification program. She has more than 15 years of experience in non-GMO consulting, verification and certification programs. FoodChain is part of the Global ID Group family of companies with a shared mission of providing services to support safe, ethical, sustainable global food production.