Non-GMO Verification for Dietary Supplements

By Sandra Kepler

The food industry is witnessing an unprecedented upsurge in successful third-party non-GMO (genetically modified organism) verification programs. In the United States, the Non-GMO Project’s Product Verification Program has grown to include over 15,000 verified products, representing more than US $5 billion in sales. In Europe, where GMO labeling regulations have been in effect for 13 years, third party non-GMO verification programs such as Nourri Sans OGM, Ohne Gentechnik and Gentechnik-Frei are growing in participation.

International market research reveals that, increasingly, consumers desire to know the contents of their food, and specifically, that there is strong awareness and concern about GMOs driving purchase decisions. The Natural Marketing Institute (NMI) conducts research globally and maintains data from 500,000 consumers from 34 countries. NMI data shows that product label reading by consumers in the United States has risen from 60 percent in 2006 to 66 percent at present. The label reading percentages increased to a high of 90 percent in China, with 88 percent in India, 82 percent in Brazil and 69 percent in South Africa.

Looking at non-GMO as an attribute along with “great tasting,” “nutritious” and “short list of recognizable ingredients,” NMI finds “no GM ingredients” plays a major role in purchase decisions. In Russia, 71 percent of consumers indicated that “no GM ingredients” was more important than “great tasting” and “nutritious.” In Brazil, China and India, 56 percent, 57 percent and 51 percent, respectively, said that “no GM ingredients” was important, coming close to the percentages for “great tasting” and “nutritious.” Discovering a favorite brand was made with GMO ingredients would make a purchase less likely for almost half of consumers surveyed. Hartman Group research indicates that U.S. consumers cite GMOs as one of the top three things they are looking to avoid when shopping for food, a 56-percent increase from two years ago.

As consumer preference grows for non-GMO choices, the number of non-GMO product launches has increased steeply. Global sales are expected to reach $800 billion by 2017. In the United States, the Non-GMO Project Verified is the fastest growing label in the natural products industry, and is recognized by a significant percentage of consumers. One-third said they would be more likely to buy the product with the Non-GMO Project Verified seal versus one without it. Some brand owners believe that since non-GMO has become a key product attribute, shoppers are looking first for the Non-GMO Project Verified seal before selecting the brand. In other words, a brand’s differentiating attributes can take a back seat to the presence of the Non-GMO Project Verified seal. A sustained increase in sales is reported for verified products, and in some cases, the increases have been quite significant.

There are many available supplement products that have been Non-GMO Project Verified, with many more in various stages of the verification process. This success would not have been possible without the contribution of the Non-GMO Dietary Supplement Working Group. Co-founded by FoodChain ID, the lead technical administrator of the Non-GMO Project’s Product Verification Program (PVP), the Working Group is facilitating the introduction of a greater number of non-GMO verified supplement products and ingredients, and in many cases, helping to shorten the length of time for a brand owner to receive verification approval.

Brand owners can take some steps to simplify the verification process and reduce cost and effort. In advance of enrolling in the Non-GMO Project’s PVP, brand owners should obtain documents directly from ingredient manufacturers. These documents would include disclosures of formulation percentages, non-GMO declarations of enzymes and fermentation organisms, process flow charts to identify raw material sources, country of origin information for raw material sources, and traceability and segregation practices.

When formulating new products or selecting products to be verified, manufacturers can consult with the non-GMO scheme owner’s technical administrator for a pre-enrollment assessment to identify compliance challenges, program cost efficiencies, or to identify best enrollment strategies. With compliance as the goal, substituting a low GM-risk ingredient for a high GM-risk ingredient may be recommended; for example, switching a tapioca maltodextrin for a tapioca source or a corn alcohol with a cane sugar source.

Before working with a new vendor, brand owners should require that the vendor participate in the verification program. Or, ask the technical administrator to review vendor documentation for compliance. When a vendor makes a change that impacts a verified product, the change must be reviewed by the technical administrator. If compliance is being sought for a large product line, begin with the products that contain the largest number of shared ingredients, and plan a staged enrollment for the rest. This will create a more manageable workload for the quality department. 

The availability of non-GMO ingredients is growing in North America as ingredient manufacturers work to meet the demand created by rising public awareness and the Non-GMO Project. International sectors have played a big role in providing non-GMO ingredients because strict in-country labeling laws and non-GMO market conditions have driven the proliferation of non-GMO crops available for ingredient processing.

The Non-GMO Project’s Standard requires non-GMO compliance for ingredients “made with” and “made from” GM risk inputs before a product can be verified. This is more stringent than certain international GMO labeling regulations such as EC 1829 and 1830 for Europe. For example, the use of GM animal feed for livestock products, GM substrate material for fermentation processes, or the use of GM enzymes as processing aids does not trigger a GM labeling event with EC 1829 and 1830. A product cannot be Non-GMO Project Verified unless all inputs in this example are compliant with non-GMO requirements. These differences can represent an operational paradigm shift for the supplement manufacturer, which can require an additional layer of ingredient procurement, traceability and segregation standard operating procedures (SOPs) and add a GMO testing requirement.

The supply chain involved in manufacturing supplements can be multi-dimensional and involve several different supplier stages. For example, for ascorbic acid, the basic staging involves corn procurement, starch, glucose and sorbitol production and fermentation. Each stage needs to demonstrate it is a system designed to avoid GMOs according to how the non-GMO scheme defines such a system.  Included in the definition may be traceability, segregation and GMO testing at critical control points. There may be additional supplier sources of carriers, excipients, or additives present or the presence of residual solvents, all of which may be derived from GM risk sources and subject to the non-GMO scheme requirements.

With proper preparation, non-GMO verification efforts in the United States can apply to international markets. There are varied labeling, threshold and regulatory requirements on a country-by-country basis, but obtaining verified status in the United States is a good beginning platform for exports. With successful non-GMO verification, brand owners report that they have developed greater control of their supply chain, and have begun new and improved supplier relationships.

Sandra Kepler is the CEO of FoodChain ID (foodchainid.com; formerly FoodChain Global Advisors), the founding technical consultant and technical administrator of the Non-GMO Project’s product verification program. She has more than 15 years of experience in non-GMO consulting, verification and certification programs. FoodChain ID is part of the Global ID Group family of companies with a shared mission of providing services to support safe, ethical, sustainable global food production.