The recent controversy over the Harvey lawsuit in the United States organic community stirred a heated debate over the use of non-organic substances and ingredients in organic foods. One major issue not addressed was the fact that many non-organic ingredients provide a pathway for genetic contamination of organic foods. In fact, non-organic ingredients may present more complex GMO challenges to organic food processors than GM pollen drift and seed contamination present to organic farmers. This is the first of a two-part series.
The US National Organic Program (NOP) allows certain non-organic substances and ingredients to comprise up to 5 percent of foods labeled “Organic” and up to 30 percent of foods in the “Made with Organic” category. These substances, which number more than 50, have been approved by the National Organic Standards Board (NOSB).
While many non-organic ingredients on the list, such as minerals, don’t raise GMO concerns, others do. Soy- and corn-based products, such as lecithin and cornstarch, are obvious examples since soy and corn are the most common genetically modified crops.
Not so obvious are vitamins, which are becoming a concern, says Brian Baker, research director, Organic Materials Review Institute (OMRI). “More and more vitamins are coming from genetically modified sources.”
Vitamins E (tocopherols) and C (ascorbic acid) are the most common vitamins raising GMO concerns, since E is derived from soy and C from corn. But according to OMRI, many patents for producing vitamins from GMOs have been granted in the past 10 years. For example, drug and biotechnology companies have received patents to produce Vitamins A (betacarotene), B2 (riboflavin), and C from GM bacteria.
Baker warned the NOP about GMOs and vitamins in a letter, stating, “The NOSB should be aware that a growing number of vitamins are produced using genetically engineered organisms, making it ever more necessary to develop natural and from organically produced and non-synthetic sources.”
Citric acid and enzymes
Citric acid, used widely as a preservative in organic foods, is another problem. Citric acid is commonly derived from a fungus, Aspergillus Niger, which may be GM. The fungus is combined with a substrate made from commodity corn, which could also be GM. However, Baker says only the fungus raises GMO concerns because the corn substrate is removed. “We’re concerned with the source organism itself and not the substrate. A substrate of commodity corn is acceptable.”
Enzymes present a similar challenge because they are often produced from GM microorganisms. Enzymes are used in food processing to convert starch to sugar, clarify fruit juice, or clot milk protein to make cheese. The GM microorganism is removed during food processing.
Baker says cultures used in dairy production, such as lactobacillus, are also increasingly derived from GM sources.
Organic certifiers require that organic food processors use enzymes derived from non-GM microorganisms.
Other non-organic ingredients raising GMO red flags include food flavors and colors and xanthan gum. Baker says many European organic certifiers believe that food flavors are the biggest source of GMO contamination in organic foods. Flavors may contain corn sweeteners from extracts from GM plants. Flavors are often complex, involving different extracts and processes to produce them, which makes determining their GM status difficult.
Verifying that non-organic ingredients are non-GM can be complex and difficult for organic inspectors and certifiers. “We have a huge challenge,” says Stanley Edwards, an organic inspector, based in Idaho. Certifiers ask organic processors for documentation verifying that an ingredient is non-GMO. But Edwards asks, “Is anyone backing up the statement? Is it worth the paper it is written on or not?”
Edwards says non-GMO documentation is “all over the map.” Documentation requirements of organic certifiers also vary from one certifier to another. “Certifiers have to decide how far down the food chain they want to go,” he says. “It gets complicated fast.”
According to Baker, affidavits that simply say an ingredient or substance is non-GM are not sufficient. “OMRI doesn’t think affidavits are enough,” he says. “We require information on the source organism.”
Evaluating GMOs in organic food processing is more complex than in organic farming says Gwendolyn Wyard, processing program reviewer, Oregon Tilth, an organic certifier. “On the farm side it’s pretty straight forward. If a farmer is buying seed, it must not be GM.” Organic certifiers may evaluate non-organic substances differently depending on whether they are agricultural or non-agricultural. For example, bleached lecithin is considered a non-agricultural substance, and one prominent organic certifier requires that it have no detectable GM DNA or proteins. Meanwhile, unbleached lecithin is considered agricultural, and the same certifier requires that it come from identity preserved, non-GM soybeans.
Getting information on the non-GMO status of some non-organic ingredients is challenging because manufacturers regard this information as proprietary. This is especially true with vitamins and flavors. For example, Baker says there may be GM sources of Aspergillus Niger, used to make citric acid, but it may be difficult to get manufacturers to disclose this information.
Several organic certification experts say the NOP rule is a problem because it is vague about the prohibition of excluded methods, such as genetic engineering. Interpretation and enforcement of the rule prohibiting GMOs is left to the certifiers.
“There is a vague discussion of excluded methods in the rule, but how far do we go?” asks Jessica Walden, technical specialist, Quality Assurance International.
“We are in a quandary,” says Edwards. “The government doesn’t say to what extent and how we are supposed to verify (GMOs). We have this requirement saying no genetic engineering, but it doesn’t give details on how to look (for GMOs), there is no NOP guidance on what is acceptable documentation, and no labeling of GM products.”
Another challenge is that advances in genetic engineering are moving quickly. “It’s hard to keep up with what is happening with (GM) enzymes, microorganisms, and new crop plants. It’s hard to know what they are, and what to look for,” says Edwards.
(Next month: Part two of this series looks at how organic certifiers are responding to the challenges of verifying non-organic ingredients for GMOs.)
© Copyright March 2006, The Organic & Non-GMO Report