07 Dec New FDA voluntary labeling guidance for GMOs versus new labeling legislation
Retailers that manage and sell their own brands are at a crossroads regarding GMO labeling. Retailers know their customers want transparency in labeling (to include all products with ingredients that contain GMOs) and more importantly want to give their customers what they want. Retailers are faced with two options: Should they wait for the enactment of mandatory regulations or voluntarily disclose using current guidance policy and/or third party verifiers?
Currently, the US federal government does not require food manufacturers or retailers to put a GMO statement or non-GMO label on food items. While some companies have voluntarily chosen to display a non-GMO sticker to express a commitment to non-GMO, there is no legal obligation to do so. The US Food and Drug Administration (FDA) decision to abstain from initiating a mandatory GMO labeling policy and scheme has been the topic of a heated debate that centers on a consumer’s right to know how food is being produced today.
Voluntary labeling of GMOs
The FDA recently issued guidance for the food industry related to voluntary labeling of products that contain GMOs. From time to time, the FDA provides guidance in lieu of legal regulation to assist food manufacturers and retailers that wish to voluntarily provide information of specific interest to their customers. The FDA guidance for voluntary labeling of GMOs is used as a framework to keep voluntary labeling of GMO information truthful and not misleading. The FDA’s guidance documents do not establish legally enforceable responsibilities. FDA guidance is nothing more than a suggestion or recommendation. The risk here is that mandatory regulations, such as Vermont’s GMO labeling Act 120 and other Acts that will likely follow for other states, will override guidance.
Third-party verification of non-GMO foods
The Non-GMO Project, a non-profit organization, supports voluntary labeling by encouraging food manufacturers and retailers to become non-GMO certified. As the only third-party verifier of non-GMO foods in the United States, the Non-GMO Project seeks to offer consumers an “informed choice about whether or not to consume genetically modified organisms.” Non-GMO manufacturers who volunteer to have their products independently tested by the Project will receive a non-GMO verified seal on the label of that particular product if it complies with specific standards. While a food item does not need to be 100% GMO-free to receive the sticker, it does need to contain less than 0.9% genetically modified ingredients. The Non-GMO Project supplies a comprehensive list of all of its non-GMO verified products on its website so that consumers can find out what non-GMO foods are available. The risk here is that mandatory regulations may override their standards.
Assessing risk and impact
Whether retailers choose to wait for legislation (The Vermont GMO labeling Act 120 is law and product and packaging changes for products on the shelf is required to be complete by July 1st 2016), choose to follow the FDA’s guidance for voluntary labeling of GMOs, or that of a third party verifier, there is a need now to assess the risk and impact on your portfolio of products.
Managing the audit process to determine which products contain GMOs is a daunting task, especially when you have hundreds of suppliers and thousands of products in a typical private label portfolio. The process is time-consuming and resource intense. In addition to sizing the problem and assessing risk, actions that may be required to alter existing labels as well as obtaining certification documents for all foods not produced with genetic engineering.
The time to act is now!
To make sense of the challenges and risk presented to retailers, Solutions for Retail Brands (S4RB) has developed and deployed an assessment solution that guides the retailer and supplier though the journey to assess the impact and risk and therefore understand the changes necessary to achieve legal compliance (such as for Vermont) or inform the decision on voluntary compliance. The solution is fast and efficient and provides answers for every step of the impact assessment process. The assessment includes educating your suppliers on assessing GMO requirements and surveys them to determine the scope of change. We can get you the answers you need to sizing the problem and assessing risk as well as providing options to drive action and closure.
Email Steven Howell for more information or call +1 866 740 3895.