Author: Brandon Nauman, Associate Managing Director, Food and Agriculture division.
A growing number of consumers are making the choice to avoid GMOs. Non-GMO Project Verified is one of the fastest growing labels in food industry history, providing transparency around the issue of GMOs used in food production. Although many people don’t realize it, the label extends well beyond food to include products as wide-ranging as personal care products and cosmetics, dietary supplements, health-care products, cleaning products, product packaging, agricultural fibers and textiles, and more. Whether you’re an agricultural producer, a product manufacturer, a retailer answering customer questions, or a consumer, it’s important to know what’s involved in Non-GMO Project verification.
Quick Background on the Standard The Non-GMO Project Standard was developed by a voluntary, multi-stakeholder industry task group about a decade ago, and is regularly updated with ongoing public and stakeholder comment. It includes guidelines for testing of high GMO risk inputs, supply chain traceability, product segregation, product formulation, labeling and quality assurance. A copy of the standard can be downloaded here.
Getting Started To get going, you’ll need to supply basic information for each product you want evaluated, including the list of all ingredients in the product formulation and information on the facilities involved in production. A close working relationship with your suppliers will facilitate obtaining the important ingredient and processing information needed to assess GMO risk. As suppliers are rightly protective of their proprietary formulations, a qualified third-party verifier such as SCS can work directly with your suppliers to obtain direct disclosures of the information needed to assess risk under strict confidentiality protections.
Evaluating and Reducing Risk There are three levels of risks:
- Non-risk inputs are not agriculturally (or aquaculturally) derived. For example, salt or sea salt is a mineral with no agricultural component. Iodized salt, by contrast, is fortified with iodine, which does introduce a GMO risk.
- Low-risk inputs are inputs for which GMO versions have not been commercialized and have no incidence of contamination. The auditor evaluates all inputs to ensure that production and handling methods are conducive to maintaining this low-risk status.
- High-risk inputs are those derived from agricultural or aquaculture commodities for which GMO varieties are commercially produced. Examples include various commodity staples and specialty crops, as well as animal and dairy products due to prevalence of GMOs in animal feed.
Evaluation of high-risk inputs is the central focus of the verification audit. Compliance is carefully monitored for each high-risk input from procurement through the finished product manufacturing. In addition, the Non-GMO Project Standard requires that applicants use Non-GMO Project Verified forms of high-risk inputs when they are available. This simplifies the production and evaluation process, because the inputs have already been vetted, approved and reclassified as low-risk. If verified forms of high-risk inputs are not available, compliance is demonstrated on how those inputs are formulated in a finished product.
Genetic testing kicks in when high-risk inputs like corn or soy constitute 5% or more of the finished product formulation. (This includes polymerase chain reaction, or PCR, testing from approved labs, based on a defined sampling plan.) For minor ingredients under the 5% cut-off, compliance can be demonstrated through a Non-GMO Project verified certificate, GMO testing and sampling, or by being a product of system designed to avoid GMOs in the first place, as in the case of Organic Certification or equivalent identity preservation (IP) certification. Micro ingredients (<0.5% by formulation) generally require some form of documentation, but some exemptions are permitted.
Documentation Required for the AuditIn addition to submitting a Program Application, which contains basic applicant and product information, an applicant supplies the following information:
- The Ingredient Declaration identifying GMO status of ingredients and their components at the mono-input level.
- The Facility Profile provides facility and processing details, including disclosure of inputs handled at the facility and steps taken to mitigate GMO risks. Facility owners document and disclose their traceability, identity preservation and segregation systems. Contract manufacturer (“co-processor) systems are evaluated as well.
- The Traceability and Quality Management Profile details the applicant’s quality and identity preservation system, and helps in evaluating ongoing compliance. Each lot of each input must be traced forward through production into the lots of finished goods, and vice-versa. Monitoring occurs at critical control points throughout the production process.
- The Package Information Profile tracks all product packaging and containers. Product labels, brands, different package sizes and types used, UPC codes, SKUs, countries where the product is sold, and use of the program logo are reviewed.
Non-GMO Project Verification Audit, Audit Report and Certificate of Compliance A detailed audit of the product, its inputs and the production system is conducted. After the audit is completed, a summary report is produced. The product will earn a certificate of compliance if no areas of non-compliance are found. On the other hand, if non-compliances are found, they are detailed in the audit report, along with the unmet requirements, and the timeframe for resolution. In some cases, formulations will need to be revised, or alternative input sources may be required. Upon submission of a corrective action plan and acceptable evidence of implementation, a certificate of compliance is issued.
Maintaining Non-GMO Project Verified Status Between audit cycles, participants are required to monitor their own production systems to ensure ongoing compliance with the Non-GMO Project Standard requirements, and notify their auditor of any changes in process or ingredients and monitor traceability, segregation, testing at critical points.
For more details, check out our webinar on Non-GMO Project Verification here. And stay tuned for upcoming product and process-specific webinars that dive into the Standard’s requirements pertaining to selected types of production systems and operations.
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