Q&A: GMO Transparency Services

  • Open How soon can I expect to be verified?

    Once NSF has received all of your application documents and payment, you can expect to receive a pre-assessment review letter in three to four weeks. Upon NSF’s receipt of your complete response to the letter, you can expect to receive your verification decision in about eight weeks.

  • Open How do you define a “primary participant”?

    The primary participant is the company that enrolls in the Non-GMO Project’s Product Verification Program. This is the entity that is seeking Non-GMO Project verification and will “own” the verification certificate.

  • Open How do you define the “location seeking verification”?

    This is the physical address of the location seeking verification. The name and address of the location seeking verification should be the same as the company that wishes to own the verification process and certificate, sign a contract with NSF, pay the NSF fees and be the NSF client. The location seeking verification may be the same location as the primary participant. Alternatively, if the primary participant is already enrolled, the location may be an additional location, which is owned by the primary participant.

  • Open How do you define the “primary contact”?

    The primary contact should be the person responsible for the Non-GMO Project program at the location seeking verification. This is the person NSF will contact regarding the verification process.

  • Open How do you define a “brand owner”?

    A brand owner is any entity that owns a specific brand or ID mark and contracts third parties to manufacture products under that brand or ID mark.

    Note: Brand owner that manufacture, process or repack their own product, as well as those that own or manage any of their facilities, should seek verification as a handler and complete the Non-GMO Project Handler Compliance Plan and profile forms.

  • Open What are the brand owner compliance requirements?

    The brand owner compliance requirements are outlined in NSF’s Brand Owner Compliance Plan. Essentially the brand owner must meet the same basic compliance requirements as any Non-GMO Project participant for traceability, compliant inputs and testing. The brand owner must also ensure that all co-packers are either Variance #9 approved co-packers or Non-GMO Project verified participants

  • Open How do you define a co-packer vs. a handler?

    A handler is any production or handling operation seeking verification to sell, label or otherwise represent goods with any Non-GMO Project verified claim.

    A co-packer is a type of handler. However, some co-packers, which co-pack for Non-GMO Project verified brand owners, may be approved to handle Non-GMO Project verified product under Variance #9.

  • Open What are the co-packer requirements?

    Co-packers must be either fully enrolled Non-GMO Project verified participants or Variance #9 approved co-packers.

    Variance #9 approved co-packers must have a contractual relationship with the brand owner/primary participant, produce product of a system (such as organic certification and other identity preservation systems) that has been designed to avoid GMOs and have a defined plan for becoming fully enrolled in the Non-GMO Project Product Verification Program within a defined time frame, not to exceed three years. Alternatively, the brand owner may sponsor the facility survey and on-site inspection for contracted operations.

    For specific details, please see the Non-GMO Project Standard – Variance #9.

  • Open What are the requirements for a re-packer?

    A re-packer must meet the same Non-GMO Project requirements as a handler.

    For an outline of these requirements, please see NSF’s Non-GMO Project Handler Compliance Plan. Contact nongmo@nsf.org to obtain the compliance plan document.

  • Open What format do you want the production and procedures flow chart in?

    The flow chart can be submitted as a Word, PowerPoint or Visio document. It can be as simple as text with arrows showing the flow of your products and procedures.

  • Open What is a “high-risk input”?

    Ingredients or inputs that are derived from or contain genetically modified organisms (GMOs), which are grown or produced on a large scale in North America and other parts of the world.

  • Open What is considered a “high-risk input”?

    High-risk crops currently include alfalfa, canola, corn, cotton, papaya, soy, sugar beets, yellow summer squash and zucchini.

    Other categories of high-risk inputs include animal derivatives, livestock production inputs, microbes and microbial products, and processed/processing inputs and ingredients, and related derivatives, derived from crops, livestock or microorganisms.

    Please refer to Appendix B of the Non-GMO Project Standard for a current list of high risk inputs, as the list is subject to change.

  • Open What is a “major input”?

    Major inputs include any ingredient or input that is a defining ingredient whose name appears in the name of the product or that represents 5 percent or more of the product.

  • Open What is a “minor input”?

    Minor inputs include any ingredient or input that represents between 0.5 to 5 percent of the product and that is not a defining ingredient whose name appears in the name of the product.

    Minor ingredients can be determined to be compliant with the Non-GMO Project Standard if they are the products of a system designed to avoid GMOs.

    Page 2 of NSF’s Non-GMO Project Compliance Affidavit may be completed to demonstrate compliance for high-risk minor ingredients. Contact nongmo@nsf.org to obtain the compliance affidavit.

  • Open What is a “micro input”?

    Micro inputs include any ingredient or input that represents less than 0.5 percent of the product and is not a defining ingredient whose name appears in the name of the product.

    Beginning May 21, 2019, no product can include more than 0.9 percent total in non-verified high-risk micro ingredients. Until then, up to 10 micro ingredients can be exempted from the Standard’s requirements.

    Page 3 of NSF’s Non-GMO Project Compliance Affidavit may be completed to demonstrate compliance with Variance #4 for high-risk micro ingredients, with the exception of: viable microbes and their functional components, which replicate their action; microbial products that have no viable microbes, or functional enzymes, but which are not isolates (such as cheese, bread, wine, beer and fruit puree); enzymes (such as chymosin) and any added nutrient, vitamin, mineral or other active component contained in a finished supplement product. (Please note, this exception will take effect May 21, 2019.)

    If Variance #4 is not applicable, micro ingredients may also be applicable to Variance #5 if they are the products of a system designed to avoid GMOs. Page 2 of NSF’s Non-GMO Project Compliance Affidavit may be completed to demonstrate compliance with Variance #5.

    Contact nongmo@nsf.org to obtain the compliance affidavit document.

  • Open What is a “low-risk input”?

    A low-risk input is an input or ingredient that only contains crops for which genetically modified versions have not yet been commercialized and/or for which there are no known or suspected instances of contamination.

  • Open What supporting documentation should be submitted for low-risk inputs?

    Low-risk inputs do not require GMO testing, but must be able to demonstrate the non-GMO status of an input (for example, through specification sheets that verify the absence of high-risk inputs, PCR negative tests and organic certificates).

  • Open What are the requirements for a Non-GMO Project compliant testing and sampling plan?

    Sampling plans must be designed to achieve a 90 percent confidence interval (which expresses how well the sample represents the population) and must occur at least once post harvest.

    Technical guidance on sampling plans may be obtained from GIPSA, ISO and GAFTA.

    Samples must contain sufficiently intact DNA. Materials that are overly processed may not provide valid quantitative test results. In this case, you would need to test the precursor ingredient.

    Quantitative real-time or digital PCR tests must meet these action thresholds: human food, ingredients, supplements and personal care products: 0.9 percent, seed and propagation materials: 0.25 percent; animal feed and supplements: 1.5 percent; and packaging, cleaning products, textiles and other products not ingested or directly applied to skin: 1.5 percent.

    Qualitative real-time PCR tests are acceptable only if the test results are negative with a .01 percent limit of detection. If the qualitative test results are positive, an additional quantitative test would be required.

    Lateral test strips shall only be used for spot checks and in unblended livestock feed ingredients.

  • Open What are the requirements for a Non-GMO Project compliant testing lab?

    Testing must be carried out by an ISO/IEC 17025 accredited lab. Check out a list of approved labs. We recommend Eurofins.

  • Open What are the Non-GMO Project’s labeling requirements?

    Labeling claims must be accurate and truthful, and must not mislead the consumer about the GMO content of the product. Any reference to the Non-GMO Project or use of the seal must be approved by a written agreement with the Non-GMO Project.

    Examples of claims that are not acceptable are “contains zero GMOs,” “GMO-free” and “GE-free.”

  • Open What are the documents required for a downgrade?

    Where an input that is normally classified as high risk is demonstrated to be produced under conditions where the risk does not exist (for example, a crop grown in a country where no GMO production has been allowed), an input may be downgraded and may not require testing.

    Downgrades are determined on a case-by-case basis and are subject to review and possible approval by the Non-GMO Project Standards Committee.

    To apply for a downgrade, please complete page 1 of NSF’s Non-GMO Project Compliance Affidavit. Be sure to include any justification documentation that will help support the case for a possible downgrade.

    Contact nongmo@nsf.org to obtain the compliance affidavit document.

  • Open When should a single ingredient product list be used?

    Please include all single-ingredient finished products that are repacked or processed by your operation and seeking Non-GMO Project verification on the Non-GMO Project Single Ingredient Product List.

  • Open What supporting documents are required for repack items?

    The same supporting documents are required for repack items as for any other inputs. Please see Section 2.4 Input Categories of the Non-GMO Project Standard for further details.

  • Open When should a warehouse affidavit be used?

    If you have a storage facility that is storing inputs/ingredients to be used in a Non-GMO Project product, please complete a Non-GMO Project Warehouse Affidavit.

    A warehouse affidavit is not required for storage facilities that store finished product in impermeable retail packaging.

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