By Brandon Nauman
As one of the fastest growing value-added labels in modern grocery history, the Non-GMO Project Verified label has tapped into one of the core memes of the current zeitgeist – the quest for authenticity. As food and agricultural technologies advance with ever increasing speed, so too, it seems, does the demand for simplification, a harkening back to the way things were. This is not merely nostalgia, however – it is undeniable that the industry is confronted with deep ethical questions and a fear of letting the genie out of the bottle without fully evaluating the consequences.
Finding themselves in the middle, brand owners and food manufacturers are now reexamining their suppliers and production operations to determine how best to meet this demand. As a critical link in the supply chain, they have responsibility for maintaining the integrity and identity of non-GMO products and their inputs. In this short article, I will outline the key steps participants must undertake to obtain verification under the Non-GMO Project.
From the outset, it is important to know that participation is sometimes established at the brand owner level; therefore, not all of the facilities in the supply chain are necessarily required to be Non-GMO Project Verified. However, regardless of whether the participant is a brand owner or a manufacturer, specific information is required for each facility that handles, processes, packages, or labels products that are Non-GMO Project Verified. In all cases, the participant must work closely with the facilities involved in the production chain to facilitate the provision of records needed to complete the evaluation.
The first major step is to gather and submit facility documentation. Participants must show that facilities involved in handling, processing, packaging, or labeling products, including any contracted facilities, are physically capable of meeting the requirements of the standard, demonstrated with supporting documentation. For instance, facilities that process high-risk inputs must provide written standard operating procedures, input source documentation, lot control/identity preservation information, batch and production records, and sales or outbound documentation. Coordinating communications among all of the facilities is essential for streamlining the review.
Once documentation is submitted and reviewed, on-site inspections may be deemed necessary, focusing on the ways in which facilities preserve the identities of approved inputs. Facilities that use only low-risk inputs, or high-risk inputs that meet exemption criteria, do not need to undergo inspection, nor do facilities that are not engaged in parallel production. Contract processors who would otherwise require an inspection are eligible for a three year exemption period.
Following the inspection, an audit report is prepared. This report includes a discussion of any potential issues or findings identified during the inspection related to areas of non-conformance or opportunities for improvement. Participants will have an opportunity to discuss these issues with the auditor, then take next steps to correct non-conformities.
Once verification is completed, a certificate of compliance valid for one year is issued, and food manufacturers are permitted to use the “Non-GMO Project Verified” seal on product packaging.
Brandon Nauman is Associate Managing Director of the SCS Global Services Food and Agriculture Division and manages its organic and non-GMO programs.
Photo: SCS Global Services