5 replies to this topic

[sruggero]

Hello! We have a product that is labeled "non-GMO".  As per BRC 5.4.4: "Where products are labeled or claims are made on finished packs which are dependent on the status of a raw material, the status of each batch of the raw material shall be verified."  Since all of our ingredients are inherently non-GMO, i.e. a GMO version doesn't exist, I'm getting hung up on the phrase "...dependent on the status of a raw material..."  Do I still verify non-GMO status of each batch even though the ingredients could never be GMO's? Thank you!

[Charles.C]

Hello!

 

We have a product that is labeled "non-GMO".  As per BRC 5.4.4: "Where products are labeled or claims are made on finished packs which are dependent on the status of a raw material, the status of each batch of the raw material shall be verified."  Since all of our ingredients are inherently non-GMO, i.e. a GMO version doesn't exist, I'm getting hung up on the phrase "...dependent on the status of a raw material..."  Do I still verify non-GMO status of each batch even though the ingredients could never be GMO's?

 

Thank you!

 

Hi sruggero,

 

Can you inform type of products involved ?

[sruggero]

Hi Charles,

 

Our product is vegan cookies.  All of the ingredients are non-GMO: dates, oats, maple syrup etc.

 

Thank you!

[pHruit]

Personally I'd tackle it via a fairly simple "risk assessment", going through each ingredient and documenting that no GM version currently exists.
Your verification per batch is then simply a case of your normal ingredient checks at intake, e.g. if you order oats, you check that you've received oats, and in combination with your document confirming there are no GMO oats, this should be ample verification IMO.

Nonetheless it'll be a bit easier if you happen to land an auditor who is moderately familiar with the current GMO landscape

[Koko LMQ]

It is requirement so if you claim nonGM, so all materials shall be verified for nonGM status. No choice.

[moskito]

Hi,

 

I think all raw materials and processing aids in your and in the supplier processes etc. have to be verified e.g. by non-GMO Project or comparable programs for the US. From the past I know that some companies have GMO-pledges published and created a logo on their own.

In EC such claim does not exist. The "GMO-law" is totally different from US law, e.g. any ingredient or contamination has to be declared as long a level was not exceed or the contamination occurred accidentally or unintentionally. Therefor any claim needs detailed analysis to prevent misleading complaints from authorities or competitors, especially when it comes to consumers understanding and the discussion about animal feed. In Germany we have a special claim with defined requirements "ohne Gentechnik".

Rgds

moskito