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Vermont's mandatory genetic engineering labeling law

Consumer Protection Rule 121

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Dory1

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Posted 16 March 2016 - 04:58 PM

We are being asked to prepare to meet the new Consumer Protection Rule 121 that requires food manufacturers to label their product if it has been  produced with ingredients using genetic engineering. I have my opinion on this, but as far as the ruling goes, I'm looking for clarification. Can anyone tell me if this means that our pallets or case labels need to include statement or that (in our case), individual POS items are labeled such? If this is so, it will be a huge expense to update all of our current film/packaging to comply by a July 1 deadline.

I realize that this really isn't an SQF specific question, but as we are an SQF certified company, I'm hoping for some insight. Thanks



Anika

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Posted 16 March 2016 - 05:24 PM

I think labeling would apply for all consumer packaging so primary for sure if House passes the bill that is



lmarsh16

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Posted 16 March 2016 - 05:41 PM

Hi,

 

We are located in Vermont and are in the same situation. The website for the Vermont Attorney General's is a good source.  They have issued guidance and published FAQs to help navigate the new ruling.  



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Dory1

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Posted 18 March 2016 - 08:25 PM

Thank you. Further investigation has definitely shown that we would need to change package labeling.

We are on West Coast and sell very little in the state of Vermont thru a couple distributors.  This is pretty big for us little guys and something we'll have to see how important it is to our business.

Thanks for your responses.



EmmE

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Posted 18 March 2016 - 09:46 PM

We are in the same boat.   However, because we do mainly private labeling, the option to update packaging has been passed along to our customer.  They either choose to pay the cost to update the packaging or choose not to send products to distribution centers in that state. 

 

With a small company, new packaging can be an enormous cost.  There is also the option work with existing packaging for all other states while creating new packaging for Vermont specifically.  However with that option, some tight controls need to be added so there are no mistakes out on the floor during packaging. 

 

I have not researched extensively so I don't know if this is a real possibility, but have you looked into whether or not you can add on a label that states whether or not its non-gmo?  An added label to the package isn't the prettiest, but sometimes when you're a small guy, it can be cost effective.



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Charles.C

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Posted 18 March 2016 - 11:55 PM

hi Dory,

 

To probably be followed by radiology if not there already.


Kind Regards,

 

Charles.C


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SQFconsultant

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Posted 20 March 2016 - 03:19 AM

Yes, the statement goes on each product.

Hats off to Vermont for requiring food companies to be transparent as to the poison they have been putting in their products for years.


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moskito

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Posted 25 March 2016 - 03:54 PM

Hi,

 

labelling is for Vermont - some huge US food companies stated in the last days that they will label not specially for products sold in Vermont but all.

http://www.ewg.org/e...mars-label-gmos

 

Rgds

moskito



RMAV

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Posted 25 March 2016 - 04:27 PM

Yes, the statement goes on each product.

Hats off to Vermont for requiring food companies to be transparent as to the poison they have been putting in their products for years.

 

The implications of this statement forms an unfortunate broad brush to paint all of us in the food industry.



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GMO

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Posted 26 March 2016 - 08:04 AM

Not aware of this but I export to the US.

 

One thing that would be interesting for me is if it also applies to GMO produced enzymes and starter cultures?  So for some industries, these are widely used but there is no GM material in the product it's the method of producing something which then goes into the product.

 

If we didn't allow it then there would be no vegetarian cheese...



QAGB

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Posted 28 March 2016 - 06:33 PM

Not aware of this but I export to the US.

 

One thing that would be interesting for me is if it also applies to GMO produced enzymes and starter cultures?  So for some industries, these are widely used but there is no GM material in the product it's the method of producing something which then goes into the product.

 

If we didn't allow it then there would be no vegetarian cheese...

 

 

GMO,

 

I agree, and we have a few products with GMO enzymes but GM material is not found in the product. I'm really not sure what we do as far as verbiage is concerned. I'd be inclined to label it as "made with GM material" at the very least. :helpplease:

 

 

QAGB



GMO

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Posted 28 March 2016 - 09:39 PM

GMO,

 

I agree, and we have a few products with GMO enzymes but GM material is not found in the product. I'm really not sure what we do as far as verbiage is concerned. I'd be inclined to label it as "made with GM material" at the very least. :helpplease:

 

 

QAGB

 

I was sent a PDF from a customer which indicated that this kind of situation would be exempt on two counts, one due to the very small quantities and one due to the fact they are processing aids the sections I quoted were:

 

© Processing Aids
Processed foods that would be required to be labeled under section 121.02 of this rule solely because the food includes one or more processing aids or enzymes produced with genetic engineering.
 
(e) Foods with Minimal Genetically Engineered Content
Processed foods that would otherwise be required to be labeled under section 121.02 of this rule, if the aggregate weight of the genetically engineered materials in the food is no more than 0.9 percent of the total weight of the food.


RMAV

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Posted 22 June 2016 - 01:12 PM

We are in the same boat.   However, because we do mainly private labeling, the option to update packaging has been passed along to our customer.  They either choose to pay the cost to update the packaging or choose not to send products to distribution centers in that state. 

 

With a small company, new packaging can be an enormous cost.  There is also the option work with existing packaging for all other states while creating new packaging for Vermont specifically.  However with that option, some tight controls need to be added so there are no mistakes out on the floor during packaging. 

 

I have not researched extensively so I don't know if this is a real possibility, but have you looked into whether or not you can add on a label that states whether or not its non-gmo?  An added label to the package isn't the prettiest, but sometimes when you're a small guy, it can be cost effective.

 

35. Can a sticker or stamp containing the required GE disclosure be placed on a product’s label to bring it into compliance?

Yes, it is acceptable for the required disclosure to appear on a product in the form of either a sticker or stamp as long as all disclosure criteria are met, and the sticker or stamp is such that it results in all disclosure criteria being present on the product when it is offered for retail sale

 

--Just for giggles:--

 

41. What happens if a retailer in Vermont offers for sale a non-compliant product that it purchased out of state and was never meant for distribution in Vermont?

All products offered for retail sale within Vermont retail premises must be labeled in compliance with the GE labeling law, regardless of whether the product was originally distributed into Vermont.

 

43. If I already have a product on my shelves that does not meet the GE Labeling Law’s requirements, and that product does not sell before January 1, 2017, can I be fined for keeping the product on its shelf past that date?

Generally, if the product is a packaged processed food, no, compliance with the labeling law would be the manufacturer’s responsibility.

 

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

 

The attempts at enforcement should be interesting.  But if the people of VT that pushed this through are smart, they'll go after us little guys first.






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