Organic certifiers try to address GMOs in non-organic ingredients

Due to a lack of guidance from US National Organic Program (NOP), organic certifiers have developed their own methods to address GMO challenges posed by non-organic ingredients. Oregon Tilth Certified Organic and CCOF developed flowcharts or “decision trees” to evaluate the GM status of ingredients. Quality Assurance International (QAI) developed a GMO Declaration that it asks clients to submit to verify the non-GMO status of ingredients.

Oregon Tilth’s decision tree
Oregon Tilth’s decision tree aims to address “the lack of clarity (in the NOP rules) with regard to how far back you go to evaluate the use of GMOs,” says Gwendolyn Wyard, Oregon Tilth’s processing program reviewer.

Wyard developed the decision tree based on similar decision trees developed by Organic Materials Review Institute (OMRI) for evaluating the GM status of non-organic inputs used in organic crops, livestock production, and food processing (

The decision tree asks questions about the GM status of agricultural and non-agricultural ingredients. Answers to the questions help certifiers determine the GM status of an ingredient and whether a company’s GMO statement is acceptable. For example, with non-organic agricultural ingredients, Oregon Tilth’s decision tree asks, “Is the substance made using excluded methods (GMO’s) at any step of the production chain?” A positive answer means it is prohibited; a negative answer means it is allowed.

In addition to the decision tree, Oregon Tilth requires a signed Non-organic Ingredient Declaration or company statement verifying the non-GMO status of non-organic ingredients.

Create consistency among certifiers
The decision tree aims to clarify complexities of evaluating non-organic substances for GM content. Wyard says organic processors run into compliance problems when they submit an affidavit that just says there is no GM DNA or protein in the final product. “The problem is organic is a process certification. We’re asking whether they use GMOs, not whether there is GM DNA or protein in the final product.”

Another aim of Tilth’s decision tree was to create a more consistent approach among organic certifiers. “We wanted to get some consistency in addressing the issue and to get on the same page with other certifiers,” says Chris Schreiner, Oregon Tilth’s quality control director.

Wyard shared the decision tree with fellow members of the Western Alliance of Certification Organizations, which include CCOF, Quality Assurance International, and Washington State Department of Agriculture. Combined, these organizations certify the majority of processed organic food in the United States.

CCOF developed its own GMO decision tree based on information from several sources, including Tilth’s decision tree, OMRI’s information, and its own processes, says Brian McElroy, certification services manager.

McElroy says each non-organic ingredient presents unique challenges with regard to verifying non-GMO status. “There is a lot of case-by-case handling of things because not all ingredients are the same; each one comes from a different background,” says McElroy.

Challenge with tocopherols
Verifying the non-GM status of tocopherols/Vitamin E has been particularly challenging. This is because one or two companies controlled the supply of Vitamin E, and they collected soybean oil from many commingled sources. “This is far from having an identity preserved system,” says Wyard.

More supplies of identity preserved tocopherols are becoming available (see The Organic & Non-GMO Report, September 2004).

Oregon Tilth requires that tocopherols come from an identity preserved, non-GM source, but Quality Assurance International (QAI) does not require an IP tocopherol, says Jessica Walden, QAI technical specialist.

QAI GMO Declaration
QAI developed a “GMO Declaration” to address questions raised by the NOP’s rule on genetic engineering. “Because of the lack of clarification (in the NOP rule), we tried to set up some parameters,” says Walden.

The declaration describes QAI’s policy toward GMOs focusing on three categories. With non-organic agricultural ingredients, such as cornstarch, used in “Organic” and “Made with Organic” categories, the original organism that produced the ingredient must be non-GM. With non-organic non-agricultural ingredients, such as flavors and colors, the product must be free from GM DNA or proteins. Lastly, if microorganisms, such as citric acid, are used, the microorganism must be non-GM.

On the declaration, the supplier must highlight measures taken to verify their non-GMO claim, such as traceability/identity preservation, GMO testing, and independent audits.

QAI’s GMO declaration has streamlined the response from suppliers for GMO documentation. Instead of receiving various GMO statements, QAI has its clients submit the GMO declaration. “We wanted to get one affidavit to use as a reference,” says Walden.

GMO statements won’t do
Both Wyard and Walden emphasize that submitting GMO-free statements is not enough. “If someone sends an affidavit saying a product is non-GMO, we don’t accept it,” says Walden.

“Whenever I get a statement saying an ingredient is GMO-free, I go back to the client and ask for more information,” says Wyard. This is because GM material may not be present in the final product, but could have been used to produce the ingredient.

Some manufacturers state that they comply with European Union regulations with regard to labeling GM ingredients. This is also not acceptable, says Wyard, because EU rules do not address the use of GMOs in processing aids, such as enzymes, which are prohibited in organics.

Wyard also says many manufacturers won’t sign certifier’s non-GMO declarations, instead insisting on using their own statements, such as “while we can’t be certain…this product is free of DNA or protein as tested by PCR methods.”

100% verification may not be possible
Organic certifiers want to ensure that GMOs are not used in organic products, but getting 100 percent verification that all non-organic substances are non-GMO may not be possible. “If we required 100 percent verification, we might grind (a processor’s operation) to a halt,” says Wyard.

Still, organic certifiers must be strict. “The market will respond to the requirements. The harder we push the more we’ll see companies that make citric acid develop identity preservation systems (to ensure non-GMO status),” says Wyard.

Organic certifiers cannot advise their clients on specific sources for non-GM ingredients, but they can tell them they are available. “With some ingredients we know identity preserved sources are out there, and we continually stress to our clients that they are available,” says Walden.

Organic certifiers hope to receive further guidance on GMO prohibitions from the National Organic Standards Board (NOSB). “We try to address the rule as best as we can, but the ultimate clarification will have to come from the NOP,” says Wyard.

©Copyright 2006. The Organic & Non-GMO Report.
(April 2006)