Aquaculture feed producers face some challenges in the E.U.’s new GMO Labeling and Traceability regulations, which will be enforced, starting in April 2004.
As always, where there’s a challenge, there’s an opportunity for new business. Cost-effective traceability systems can help aquaculture feed producers, processors and exporters meet these new marketplace and regulatory demands for food safety and identity preservation in aquaculture feed.
What are the key components of the new regulations, and what do these new regulations mean in practical terms?
Traceability: Mandates product traceability through documentation and implementation of Identify Preservation systems and procedures for the entire supply chain.
Labeling: Products containing or produced from GMOs must be labeled as such, even when GMO is undetectable by test. Products containing traces of GMO below the appropriate regulatory thresholds are exempt from labeling, provided that compliant traceability systems are in place and traces of GMO can be demonstrated to be adventitious and technically unavoidable.
Thresholds: 0.9% regulatory threshold for EU authorized GMOs and 0.5% for unauthorized GMOs that have already received a favorable EU risk assessment. Compliant traceability systems must be in place and must demonstrate that any traces of GMO are adventitious and technically unavoidable.
What food and feed producers need to do in order to comply with the new regulations
There are two essential elements that need to be in place to comply with the new EU regulations:
• A well documented traceability system. You need to be able to demonstrate that all reasonable precautions and all due diligence were taken to exclude GM material from the product, and that any traces of GMO present are adventitious or technically unavoidable.
• GMO testing to verify that levels of adventitious GMOs are below the relevant thresholds (0.9% or 0.5%). Since these thresholds are quantitative, the testing method used should also be quantitative. These are thresholds, not tolerances—it is not sufficient to merely demonstrate that a product has less than this amount of GMO present. You must also demonstrate due diligence in keeping GMO out of raw materials and input ingredients as well as your processes and final products.
Non-GMO Certification for an IP System
The new EU regulations do not provide guidance for developing a non-GMO traceability or identity preservation (IP) program for compliance purposes. Many food and feed producers have contracted with independent third-party organizations to verify their non-GMO IP system. Leading certification organizations such as Cert ID provide independent non-GMO IP System Certification, which validates and certifies that the production system operates in accordance to a rigorous independent non-GMO standard such as the Cert ID non-GMO Standard.
Non-GMO Product Certification
Non-GMO product certification programs can be designed to demonstrate that a product complies with the new EU requirements, with some other standard of the producer’s choosing, or with an independent standard such as the Cert ID Non-GMO Product standard, which requires GMO presence of less than 0.1%. In the case of Cert ID, non-GMO Product Certification is verified to buyers through Transaction Certificates of Compliance that accompany each shipment.
These third-party non-GMO programs provide an independent verification that increases buyer and consumer confidence in the product. This is essential for aquaculture feed producers and for major food manufacturers and retailers who are concerned about the potential for brand damage and who want to differentiate themselves from competitors with an independent non-GMO certification.
Labeling: ‘GMO free’ vs. ‘Non-GMO’
We recommend that food and feed producers not make ‘GMO Free’ claims on Web sites or product labels. “GMO Free’ is a scientifically indefensible claim and may be seen as misleading. A more desirable and defensible claim is ‘non GMO,’ supported by a well-designed non-GMO IP System and Product program that includes GMO testing and is based upon a recognised industry standard such as the Cert ID Non-GMO Standard.
About the author
John Fagan, Ph.D., founded and serves as chief scientific officer of Genetic ID NA, Inc., which uses PCR-based DNA tests to detect specific traits and genetically modified organisms (GMOs) in food and agricultural products. Dr. Fagan is also a Director for Cert ID, which develops, implements and monitors IP certification programs for food and agricultural producers in North America, South America, Europe, and Asia. He can be reached at 1-641-472-9979 or info@genetic-id.com.
Resources:
The new E.U. regulations, 'Food and Feed' EU Regulation 1829/2003 and ‘Traceability and Labeling' E.U. Regulation 1830/2003 can be viewed online at www.genetic-id.com.
