The!Non(GMO!Project!€¦ · The Non-GMO Project Product Verification Program 6 Renewal Every product must be renewed on an annual basis. The product is re-assessed to make sure that

© Genetic ID (Europe) AG 2012

The Non-‐GMO Project : The North American Experience

with a Non-‐GMO Labeling Prohram

The Non-‐GMO Project


15,000 customers in 102 countries.

Safe, Ethical and Sustainable Food

The Global ID Group family of companies has been providing integrated food safety and food quality services to the global agrifoods industry since 1996.

Headquarters: Fairfield, Iowa Offices: US, UK, Brazil, Germany Licensees: 8 labs in 6 countries

15,000 customers

in 102 countries


Testing Certification Services

GMO

Pathogen

Speciation

Allergen

Authenticity

Non-GMO

BRC and SQF

Ohne Gentechnik

ProTerra

Sustainability

Non-GMO Project

Consulting

Food Labeling

Training

Supply Chain


1996 2000 2006 2007 2016

First lab in NA to use

PCR to test for GMOs

Headquarters: Fairfield, Iowa Licensees: 19 labs in 16 countries

First non-GMO

certification standard

First Tech Admin for the

Non-GMO Project

Verified the 40,000th

NGP product

Two Decades of Experience

First standard

for sustainable

soy


§  No legal labeling requirements

§  USDA Organic prohibits the use of GMOs but….

§  Does not require testing, testing must be paid by the certifier

§  Allows for “adventitious” contamination up to any level

§  Evidence that organic is becoming increasingly contaminated

§  Undocumented, inconsistent and unproven claims §  GMO Free, Non-GMO, Made without Genetic Engineering, etc.

§  No underlying standards (thresholds, testing requirements)

§  No way for retailers or consumers to verify claims

§  No legal definition of “natural” products

Background 2005: State of the Non-GMO Market in the USA


In 2005, a group of small, independent natural foods retailers begins to discuss how they might assure their customers of the non-GMO status of the products they are carrying. They begin to engage other parts of the industry in the discussion, including the larger industry players.

In 2007, after two years of discussions, a consortium of retailers, distributors, manufacturers, and NGOs formed a non-profit, The Non-GMO Project, to develop an independent, third party program to verify the non-GM status of food and personal care products. Board members included:

Whole Foods – the largest retailer of natural foods

UNFI – the leading distributor of natural foods

Nature’s Path, Lundberg, Eden Foods, Organic Valley, etc.

Global ID Group – as technical advisor and program administrator

History


In 2007, the NGP undertakes the standard development process and launches the first public comment period.

In 2008, the Non-GMO Project ratifies the first version of its Standard after two rounds of public comments.

In 2010, the first Non-GMO Project label appears.

In 2012, Whole Foods announces it will require labeling on all products by 2018.

In 2016, Version 13 of the Standard is ratified and FoodChain ID verifies its 40,000th product.

History


2,500 participating brand owners

12,000 suppliers in 102 countries

20,000 verified ingredients

40,000 verified products

$18 billion (est.) in annual sales

1.2 million friends on Facebook

Today


Structure

Technical Administrators

Standard Committee

Independent Retailers Retailer Coops Manufacturers Farmers NGOs

Manufacturers Retailers NGOs (e.g. IFOAM)

Approved Laboratories

FoodChain ID (37 staff) ICS, NSF, SCS SGS (candidate)

ISO 17025 Sampling guidelines Quality Control

Inspectors

Training Approval


Pre

The Non-GMO Project Product Verification

Program

1 Pre-Enrollment Enrollment Submission of Product Data Assessment of Product Data Approval

2 3 4 5 6 Renewal


Pre


Program

1 Pre-Enrollment Interested companies can get an estimate of potential costs and timelines and a pre-assessment as to whether their particular products are likely to be verified successfully.

Companies may choose to reformulate their products and remove non-compliant ingredients before embarking on the verification process.


Pre


Program

2 Enrollment Brand owners choose a Technical Administrator and then enroll their companies and their products. They execute a Participating Company Agreement, or PCA, that outlines each side’s rights and responsibilities such as confidentiality, data ownership, liability, use of the seal, etc.

Larger companies will often submit the PCA to their legal departments and ask for some changes.


Pre


Program

3 Submission of Product Data Brand owners (or co-packers) submit detailed information on each enrolled product including each ingredient and each supplier as well as copies of the product labels appearing on the packaging. Data can be uploaded in bulk in a variety of ways such as Excel spreadsheets, etc.

Brand owners give the TA permission to contact suppliers directly to request the required compliance data.


Pre


Program

A test is a test is a test? A company submits a test result. What are some of the possibilities that the evaluator must examine?

Is the lab an ISO 17025 NGP approved lab? Is it accredited for this specific test? Is this the right test for this sample type? Was it sampled properly?

Senior PVP evaluators must be very knowledgeable about food science and the NGP Standard. It typically takes 2 years to train a senior evaluator.


Pre


Program

5 Approval Once all risk ingredients have been reviewed and found in compliance, the brand owner is informed that the label can now be used on the product.

The brand owner decides if products will be listed publicly on the NGP web site and mobile apps.

Individual suppliers may also decide if they want their participation and verification of specific ingredients to be made public.


Pre


Program

6 Renewal Every product must be renewed on an annual basis. The product is re-assessed to make sure that it has not been reformulated and that neither the suppliers of risk ingredients or their manufacturing facilities have changed.

In addition, in any given year, new ingredients may be categorized as having GMO risk (e.g. flax, apples, etc.) or the Standard itself may be revised (e.g. synthetic biology).


Pre


Program Costs


Pre


Program Costs


Key Technical Issues

Thresholds and Testing

Current threshold for labeling for food in the EU is .1% for non-adventitious and .9% for adventitious. EU standard does not address feed, enzymes or processing aids.

NGP has a .9% threshold for food, regardless of whether it is adventitious. Incompatible with EU.

NGP requires regular testing for all high risk ingredients. Requires PCR in most cases.

Approves and oversees qualified laboratories.



Feed

Current threshold for the NGP is 5%, which was recently relaxed after several years of industry pushback. NGP also recently relaxed the period prior to slaughter.

Difficult issues for dairy cooperatives whose members may buy feed from a broad and varying range of suppliers.



Minor and Micro Ingredients

Minor: between .5% and 5% of dry weight - if IP or organic, testing not required by NGP Micro: less than .5%, up to 10 micros that are GMO allowed by the NGP



Enzymes, Fermentation and Processing Aids

May not be detectable in the final product. May or may not be produced through genetic engineering.



New Genetic Engineering Technologies

Synthetic Biology: Already in many foods. NGP recently modified its Standard to disallow.

CRSPR – CAS9: Does not add foreign DNA to the genome. Removes DNA.

RNAi: Does not add foreign DNA, but rather alters the functioning of existing DNA. We may not have the techniques developed to test for all these new technologies.


Key Market Issues

Organic versus Non-GMO Verified

Approximately 40% of NGP verified products are organic.

In USDA organic, genetic engineering is a “prohibited method.”

The USDA organic standard is a process-based, not testing- based standard.

In the U.S., much greater chance of contamination.

The organic standard does not require testing and does not specify a threshold for contamination.

Should organic products be a part of a European non-GMO labeling program?


Key Market Issues

Labeling No Risk Products

Should products without any GM risk ingredients be able to get verified and carry a label?

After much debate, the NGP concluded “Yes” for the following reasons:

Consumers may not know which ingredients have GMO risk.

Products without risk today, may have risk ingredients in the future.

If a program is successful, consumers will conclude that products not carrying the label have GMOs in them.

No risk products are very easy and inexpensive to verify.


Key Market Issues

Confidentiality

Brand owners consider their formulations to be extremely valuable and sensitive information. They also consider their sources of supply to be highly proprietary.

Likewise, co-packers or manufacturers that serve brand owners, equally strive to keep their formulations and suppliers secret.

Companies also do not want the public or their buyers to know if they have failed to get a product verified.

Without strict assurances of confidentiality, companies will not participate.


Key Market Issues

Confidentiality

Ideally, there should be separation between the Standard holder and the Technical Administrators.

Strict security measures must be enforced by the Standard holder over the TAs.

Employees must be educated, especially those with access to confidential data.

In the case of computerized systems, they must be held to the highest levels of enterprise-class security and must be tested regularly. Servers must be hosted in hardened server farms with proper redundancy.


Key Market Issues

Scope

Food: Organic, no risk, etc.

Supplements: Complex, high numbers of ingredients, enzymes, processing aids, excipients, binders, etc.

Personal Care: Not food, but ingredients may be absorbed through the skin.

Restaurants: Usually upon request by the restaurant. Need consistent sourcing. Packaging, dinnerware, etc.


The Critical Role of Software

SupplyTrak at FoodChain ID

All clients use the proprietary SupplyTrak Supply Chain Compliance Platform.

2,500 brand owners,12,000 suppliers, 40,000 products, and 20,000 ingredients. Averaging 500 users per day.

SupplyTrak has over 30 man-years of development effort over 9 years.

Cloud-based, software-as-a-service with over 200 functions specific to the NGP.

Allows for automated upload of client data.


The Critical Role of Software

SupplyTrak at FoodChain ID

The PVP simply could not be administered without SupplyTrak.

Over 1 million elements of data housed by the program.

Product evaluators rely on it to manage their assessment workload.

Makes the process of inputting and updating data efficient for clients.

Fast, secure, reliable.


Impacts

When the NGP began, research indicated that 10% of mainstream consumers looked for products without GMOs. Today, the number is 48%. The NGP has helped to change the dialog in the US on the issue.

Without the NGP, it is possible that sources of key non-GMO ingredients would have disappeared.

The supply chain is being re-engineered. Major suppliers are entering the market for non-GMO ingredients.

Consumer have a label they can trust and they have responded with their pocketbooks.


Opportunities

There will be many opportunities for Europe and North America to work together such as harmonization of standards and reciprocity.

Reciprocity would allow suppliers verified in one program to be automatically verified in the other, significantly increasing efficiency and decreasing costs for all.

Working together to evaluate the impact of new technologies and to develop joint policies.

Importers and exporters on both sides of the ocean would benefit from a more unified approach.


Thank You!

Download the Non-GMO Project

Standard at:

nongmoproject.org


The Global ID Group Family of Companies

Kenneth Ross [email protected] 641-209-4503

Documents

The!Non(GMO!Project!€¦ · The Non-GMO Project Product Verification Program 6 Renewal Every product must be renewed on an annual basis. The product is re-assessed to make sure that