As the Safe and Accurate Food Labeling Act makes its way through Congress, ingredient suppliers are left with some crucial questions.
For an ingredient like corn at high risk of containing GMOs, non-GMO testing makes sense. But does it make sense for other ingredients for which the risk of containing GMOs is far, far lower? Photo © iStockphoto.com/aydinmutlu
U.S. headlines are filled with news of the Safe and Accurate Food Labeling Act of 2015, also known as the “Deny Americans the Right to Know” Act, which passed in the U.S. House of Representatives this July. The bill would create a federal standard for the voluntary labeling of GMO products, as well as a USDA certification process for a GMO-free label. Whether you support or oppose the bill, the House passage forces us to imagine a future with continued, but now permanent, voluntary GMO/non-GMO labeling. Like many along the food and supplement supply chain, ingredient suppliers are wondering how this bill, if passed, may affect the industry. For suppliers, the law’s effect would depend on the standards the USDA sets forth.
For an efficient-and, more importantly, relevant-transition, the USDA should not require verification for all ingredients but only for at-risk ingredients-ingredients that truly are at risk of genetic engineering. If a raw material is inherently non-GMO, then requiring testing and convoluted documentation for the ingredient is unwarranted. The USDA should first determine a list of at-risk ingredients; then, for ingredients determined to be not at-risk, create a simple, yet viable, documentation process.
Take, for instance, the vast number of botanicals that are still wildcrafted. There is zero incentive to gene splice a one-off ingredient only grown deep in the Andes. Involving anything more than a non-GMO statement for such an ingredient would be a waste of testing, effort, and money. For these types of ingredients, manufacturers can already rest assured that the ingredients are inherently non-GMO.
Value can only be found in extensive non-GMO verification for ingredients that are truly at risk of genetic modification, with the label serving as an assurance that manufacturers will consistently be supplied with a non-GMO version of at-risk products.
Unfortunately, as we know, the GMO issue is not as black and white as the above example. There is a lot of gray area. There are products that are not GMO themselves but that utilize at-risk ingredients such as processing aids. For instance, enzymes are standardized with cornstarch; extracts utilize corn-based solvents; yeast grows on sugar beets; animals are fed with genetically modified feed; and so on.
If the USDA determines that these processing aids have to be non-GMO-verified in order to bear a USDA “non-GMO” label, then suppliers face the significant challenge of proving that ingredients-through processing and beyond-are non-GMO, stemming from testing at seed level. Would a bromelain supplier have to trace back to the seed of the cornstarch used to standardize the ingredient? If so, a complete readjustment in the supply chains of these gray-area ingredients will be needed.
And, in the end, will there be enough availability of acceptable ingredients? Sourcing, validation, testing, and corroboration between supplier and customer would contribute to increased raw-material costs. If this is the case, will there still be demand?
If the Safe and Accurate Food Labeling Act of 2015 passes the Senate and gets signed into law, it will set in motion a direction that the entire industry will have no choice but to follow. There are still many questions to be addressed, questions that only those in the industry can answer. No one understands the nature of our products and our supply chains better than we do. We in the industry, both manufacturer and supplier, need to be the ones setting the standards. Federal voluntary GMO/non-GMO labeling will be a process-a process that the USDA has yet to define and can only achieve with the help of the industry.
George Pontiakos is president and CEO of BI Nutraceuticals (Long Beach, CA).