Now more than ever, consumers want detailed information about the food they eat and look to certifications shown on product labels for insights and guidance. One of the most recognized certifications by consumers and retailers is the Non-GMO Project. Companies obtain the Non-GMO Project certification mainly to access new markets, increase sales, and demonstrate their commitment toward developing a more transparent food system.
As a global leader in food and agricultural certifications, SCS Global Services has been a Technical Administrator auditing companies around the world to the Non-GMO Project Standard since 2015. (SCS is also an accredited certifier for various GFSI-level food safety standards, USDA Organic, Fair Trade USA, Rainforest Alliance, SCS Gluten-Free, and sustainability standards.)
A wide variety of products are Non-GMO verified, including seeds, wholesale and retail goods for humans and pets, over-the-counter drugs and homeopathic remedies, animal feed and others. Below we answer the most common questions companies have asked SCS Global Services about Non-GMO Project Verification.
What does the Non-GMO Project Verification process look like from start to finish?
The verification process consists of reviewing the product formulations, ingredients, and the systems and procedures (i.e., traceability, segregation, cleanout, etc.) that the manufacturing facility must adopt to avoid genetically modified organisms (GMO) contamination.
During the review, the auditor assesses the risk status and classification of each ingredient to determine the requirements needed to prove its compliance. For a majority of participants, only desk audits are required. Desk audit means the review of evidence, such as procedures and records, by the auditor without an onsite visit of the manufacturing facility. Onsite inspections are necessary usually only if there is parallel handling of high-risk ingredients.
Once the necessary evidence is collected, the auditor completes the audit report. The audit report is then submitted to a technical reviewer who makes the certification decision. If no non-conformities are listed in the audit report (that is, areas in which the applicant’s product fails to meet required standard), the company receives a Non-GMO Project certificate valid for one year. On the other hand, if non-conformities are included in the audit report, an adequate timeline is granted for the participant to provide evidence that the necessary corrective actions have been implemented. Once it has been confirmed that the corrective actions are sufficient, a certificate is issued. Renewal audits are conducted every year and must be completed prior to the expiration date of the certificate.
With our combined focus on personalized customer service experience and expeditious review, we generally complete audits in under 12 weeks. Additionally, our audits are often bundled with other certification programs including USDA Organic and Gluten-Free.
What are the different GMO risk statuses for ingredients?
The risk status denotes the likelihood that an ingredient is or is derived from a GMO. The Non-GMO Project describes five risk statuses as follows:
- Verified status: Products that are currently Non-GMO Project verified
- High Risk: Organisms and ingredients derived from them for which GM counterparts are widely commercially available (ex. corn, soy, alfalfa, and their derivatives)
- Monitored Risk: Organisms and ingredients derived from them for which GM counterparts are in the research and development stages
- Low Risk: Organisms and ingredients derived from them that are not classified as monitored risk or high risk
- Non Risk: Ingredients that are not derived from biological organisms and are not, therefore, susceptible to genetic modification
What are the ingredient classifications?
Ingredients are classified as major, minor, or micro according to their weight percentage as represented in, or present in, the finished product. Added water and salt are excluded from this calculation.
- Major: 5% or more of the finished product
- Minor: At least 0.5% but less than 5% of the finished product
- Micro: Less than 0.5% of the finished product
How do I demonstrate compliance with high-risk ingredients?
High-risk ingredients are ingredients that are potentially derived from GM commodities that are commercially available. This includes certain commodity crops, their derivatives and animal-derived materials, running the gamut from corn, soybean oil, and beet sugar to milk.
There are multiple pathways to demonstrate the compliance of these types of ingredients. Participants may source ingredients listed on the Non-GMO Project website to produce verified products. If the ingredient is not Non-GMO Project verified, its compliance can be demonstrated via the country of origin of the initial crop used to produce the high-risk ingredient, providing Identity Preservation certificates (applicable only for some minor and micro ingredients), submitting sampling and testing plans or exempting micro-ingredients allowed by the standard.
During the audit process, SCS Global Services auditors provide specific information about all available compliance pathways for each ingredient.
What does the facility review involve?
During a Non-GMO Project audit, the participant must demonstrate that systems to avoid GM contamination are in place in the manufacturing facility. This includes, at the minimum, traceability procedures to ensure that each lot of verified product can be traced back to specific lots of the ingredients used in its production. If the manufacturing facility handles high-risk ingredients out of the scope of the verification or any potential source of GM contamination, segregation procedures to separate compliant from non-compliant materials, as well as cleaning procedures, are reviewed. Records proving that these procedures are in place, as well as staff training on the procedures, are also required.
As mentioned above, onsite inspections are not usually required for most operations. However, if required, the compliance of the systems designed to avoid GM contamination, mentioned above, will be reviewed onsite by the auditor.
Director of Sales & Marketing, Food Labels
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AuthorDavid Morales Vela | Technical and Key Accounts Manager
SCS Global Services To find out more , contact David Morales Vela, or call 510.452.8057.