following the discussions on BE labelling (NBFDS) in the US there are still some questions for me related to the requirement of labelling in the context of enzymes.
To my understanding the use of enzymes in the manufacturing of ingredients (glucose syrup from non-GMO corn with enzymes produced with an engineered microorganism (e.g. amylase from Bacillus) does not require a labelling of BE on the finished product (e.g. a biscuit), when this ingredient is used.
1) But unclear for me is what is requirement for an enzyme produced in the same manner, but used as processing aid for manufacturing e.g. a biscuit?
2) In the EU we have the definition of self-cloning which to my knowledge does not exist in the US. Self-cloned organisms (only rDNA from the organism itself -> e.g. multi-copy) are not GMO in the EU (rational: can happen in nature).
Does it make a difference in BE labelling if the enzyme is produced with the aim of an self-cloned micro?