19 Feb The Vermont Act 120 – Understanding GMO labeling implications for your business in one straightforward process
As a retailer, have you adopted the wishful thinking strategy of waiting this out and crossing your fingers in the hope that it will go away? And have you now come to the realization that your strategy has been in vain and you need to move with this quickly to ensure you implement the necessary changes in time?
Keep calm! Help is at hand with this easy guide on how to get to grips with understanding the impact, risks and cost implications this ruling poses to your business and private brand products.
Before we get in to the details, let’s take it back a step to ensure we all have the same understanding of the Vermont Act.
The Vermont Act 120 & Consumer Protection Rule 121, was passed in 2015 and comes into force on July 1st 2016.
The Act mandates organizations to make “clear and conspicuous” labeling of genetically engineered (GE) food and prohibits manufacturers from describing GE products as “natural”.
This is about giving consumers transparency of food produced with genetic engineering, enabling them to make informed choices when shopping.
Incorrect labels or claims are liable to fines of $1,000 per day, per product. This includes updating labels of products that do not include GMOs. Every label requires updating in some way.
In an ideal world…
At S4RB we foster long-term, positive and mutually beneficial working relationships between retailers and suppliers. We achieve this through regular communication and engagement which ensures everyone understands and is working towards prioritized goals, allowing us to save retail teams time and obtain the required information with accuracy and speed.
If, however, you do not currently work with your suppliers in this way, then don’t worry because there are short-term high-impact options available to you, allowing you to get the information you need to enable you to understand GMO implications within six weeks.
It’s straightforward, really
From my recent experience of successfully implementing a GMO risk assessment for a client’s private brand portfolio relating to the Vermont Act, I recommend using the TROPICS method to quickly get your suppliers on board and prioritizing your GMO data request:
T is for Timescales
Define the time frames you are working towards, including for the period of time between completing the data collection exercise and July 1st 2016.
NOTE: July 1st is the date whereby relevant packaging needs to be amended and on the shelf. The time to act is now!
R is for Resources
Take time to understand what will be needed to achieve the request, both on the part of your organization and also on the part of the supplier.
O is for Objectives
Ensure you have put in place quantifiable objectives that can be referred back to when you have completed the task. Don’t try and do it all in one step; start with the impact assessment and progress from there.
P is for Perceptions
Does everyone see the issue in the same way? Internal stakeholders? Your suppliers? Your customers?
I is for Interest
Understand who has an interest in making change happen / keeping things the same. Ensure you have plans in place to manage any potential “blockers”.
C is for Control
Who holds the power? You may think it’s you, the retailer, but don’t forget some of your larger suppliers may have a lot of product information on your private labels that you will need to collect from them. How will you manage this if they choose not to provide the information?
If the supplier manufactures private brand products for multiple retailers, the sooner you seize the initiative for your own products, the better.
S is for Source
What is the real driver and where did it come from? In this case it is legislative, but ultimately driven by consumer demand for greater transparency. It is important to communicate this to all involved to ensure commitment to the initiative.
The whole process from request to collation on every product can be as quick as six weeks but is reliant on having:
- A good understanding from the onset what level of information you would like
- Relevant up-to-date supplier information including contact data
- Targeted information and guides to share with your suppliers to minimize questions
- Dedicated resource
- A simple, auditable data collation tool ready to be used from day one
For step-by-step details on the practicalities of assessing your private brand products, read David’s article on how to know which of your private brand products contain GMOs in six weeks or less.
For further information or guidance on how to execute your GMO labeling implications assessment, please email Steven Howell or call +1 866 740 3895.