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#1 Weebus90

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Posted 05 April 2016 - 02:57 PM

HI Everyone, 

We are working on being compliant with the new Vermont GMO labeling regulations but need some help.

For produce items that are sold in bulk but sold as retail products, would it be acceptable to put a blanket statement on the invoices for the customers so they know that the products may contain GMO's and then it would be up to the retailer to have the signage displayed on the product shelf also saying may contain GMO's?

 

Or 

 

would we have to put a statement next to each individual product on the invoice line stating whether it contained GMO's?

 

This would be only for the bulk produce items that are sold in bulk but the retailer sells as retail products. These products would not have a label that would carry the statement. 

 

Thanks!

Weebus


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#2 Anika

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Posted 05 April 2016 - 06:32 PM

I'm not sure about the questions but look forward to someone more knowledgeable to help out :helpplease:

 

Couple of threads that might be useful:

 

http://www.ifsqn.com...ges/#entry99184

 

http://www.ifsqn.com...round-the-fsma/


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#3 QATX12

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Posted 05 April 2016 - 08:09 PM

Hi Weebus,

 

    Act 120 requires specific statements depending on whether your product is a raw agricultural commodity or a processed food and whether it is packaged or unpackaged.

1.  A packaged raw agricultural commodity, such as a separately packaged summer squash, must be labeled “produced with genetic engineering” if it is a product of GE. The manufacturer(s) who packages and labels the food is responsible for this label. See CP Rule 121.01(16); CP Rule 121.02(b)(i).

2.  A raw agricultural commodity produced with GE that is not packaged, such as sweet corn sold by the ear, must be labeled on the shelf or bin where the produce is displayed with the statement “produced with genetic engineering.” The retailer is responsible for this label. See CP Rule 121.01(25); CP Rule 121.02(a)(i).

3. A packaged processed food, such as a box of cereal, must be labeled with one of the following statements if it is offered for retail sale in Vermont and contains ingredients produced with GE. The manufacturer(s) are responsible for this label.

 

 

Depending on the type of produce you are handling, if every item in the Invoice is a GE product then I don't see why a blanket statement would be an issue so long as that blanket statement states that ALL products in the Invoice are GE or May be Produced with GE. If there are some items in the invoice that are GE and others that are not, I can see how a GE statement next to each item would be required to avoid any confusion. It is the retailers responsibility to label an un-packaged raw agricultural commodity, so I'm sure you'll hear from them if your system isn't working for them.

 

 

 

Regards,


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#4 Anika

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Posted 06 April 2016 - 02:05 PM

We are a confectionary and sell to the U.S A blanket statement for bulk products should work for us then right?

 

Seems like, whichever product goes to the consumer (not customer) needs to be labeled with GE if GE products are used. So retailers would be responsible for individually selling bulk items as GE or not as GE. Am I correct?


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#5 QATX12

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Posted 06 April 2016 - 03:00 PM

We are a confectionary and sell to the U.S A blanket statement for bulk products should work for us then right?

 

Seems like, whichever product goes to the consumer (not customer) needs to be labeled with GE if GE products are used. So retailers would be responsible for individually selling bulk items as GE or not as GE. Am I correct?

 

Any product that is already packaged whether it'd be a process food or raw agricultural commodity needs to be labeled by the manufacturer. Retailers are not allowed to label product that is already packaged.

 

For example, you are providing me with potatoes...if the potatoes are packaged in 5lb bags ready for retail then that package needs to be labeled. If you are providing me with potatoes in a tote where I as the retailer will put out in a tote for customers to pick out and weigh out their own potatoes, then I need to put a sign up by the container indicating the GE status of the food product.

 

 

Here are some references:

www.leg.state.vt.us/docs/2014/Acts/ACT120.pdf

http://ago.vermont.g...beling-rule.php  (see Frequently Asked Questions regarding Act 120)


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#6 Anika

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Posted 06 April 2016 - 04:15 PM

Any product that is already packaged whether it'd be a process food or raw agricultural commodity needs to be labeled by the manufacturer. Retailers are not allowed to label product that is already packaged.

 

For example, you are providing me with potatoes...if the potatoes are packaged in 5lb bags ready for retail then that package needs to be labeled. If you are providing me with potatoes in a tote where I as the retailer will put out in a tote for customers to pick out and weigh out their own potatoes, then I need to put a sign up by the container indicating the GE status of the food product.

 

 

Here are some references:

www.leg.state.vt.us/docs/2014/Acts/ACT120.pdf

http://ago.vermont.g...beling-rule.php  (see Frequently Asked Questions regarding Act 120)

Thank you QATX12 :smile:


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#7 L. Mathies

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Posted 07 April 2016 - 01:54 AM

What would be the requirements for someone who would be selling bulk vinegar that would be used in a product that might be sold in Vermont?


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#8 jportz

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Posted 22 June 2016 - 01:08 PM

Our supplier for vinegar now states that the vinegar we receive is a gmo product.  We are now sending statements to all our customers saying because of the Vermont Act 120 the products you receive from us are now GMO.  Most of the products we produce are in bulk and for further manufacturing.  We do a small amount of retail but, don't ship directly to Vermont.  Do we add to our labels that our products are GMO?  How are other companies addressing this?  We have looked and asked around but no one seems to have a straight answer.  Our customers are asking us if their labels need to say GMO also if they don't go to Vermont and we are unsure how to answer them because we can't find a definite answer ourselves.  Any help would be appreciated.


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#9 RMAV

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Posted 22 June 2016 - 01:15 PM

What would be the requirements for someone who would be selling bulk vinegar that would be used in a product that might be sold in Vermont?

As I understand it you may be asked by your customer to provide a sworn affidavit regarding it's GE status, but you are not subject to Vermont labeling as you are not providing a retail-packaged item.  Somewhat related:

 

29. Is a food that is produced entirely via fermentation (e.g., vinegar) required to be labeled?

Currently, no determination has been made requiring vinegar and other such fermented food products to be labeled. The Attorney General’s Office will update this section of the FAQ once a determination has been made

 

http://ago.vermont.g...ce-and-faqs.php


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#10 RMAV

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Posted 22 June 2016 - 01:40 PM

jportz,

As I understand it, the options for retail packaging is "Produced with Genetic Engineering," "Partially Produced with Genetic Engineering," and "May be Produced with Genetic Engineering."  The threshold is 75% genetically engineered material of *applicable* ingredients.  So there's some 4th grade math to do there along with determining what ingredients you have are exempt, what the percentage of GE material is in each ingredient, then excluding water and salt what the total GE material by weight in the retail item is to determine whether "Produced" or "Partially Produced" must be used.  "May be Produced" may only be used if you could not determine, after "reasonable inquiry" that your ingredients contain or do not contain GE. 

 

For us who use vinegar, it will be interesting.  For now, I have to assume that vinegar will not be exempt and label accordingly.  If Vermont decides later that it is exempt, it will change the calculation of the formula and will go from "Produced with" to "Partially Produced with" and therefore whatever product I have on the shelf at that time in Vermont will be in violation.  I'm sure there will be a grace period, but the product has 1.5 - 2 year shelf life.


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