2025 General Standard Revision — Feedback and Outcomes

Summary

In Questions 1, 2, and 3 of the Second Public Comment Period, the Project asked stakeholders about a proposed limited evaluation for certain Inputs that are normally excluded from evaluation. The purpose was to confirm that these Inputs did not contain prohibited substances without requiring them to demonstrate Non-GMO sourcing. The proposed evaluation would have relied on an Affidavit. The Project asked who could reasonably complete the Affidavit, whether implementation would differ among Processing Aids, Growth Media, Compost, and animal feed materials, and how often the documentation should be updated.

Key Themes

Commenters questioned whether Participants would have enough information to complete the Affidavit accurately, particularly when the needed information is only available from suppliers earlier in the supply chain or involves proprietary components. Existing Technical Administrator forms already collect some of this information, which raised questions about whether a separate Affidavit would add value. Feedback also identified practical differences among Input types, along with concerns about additional documentation, longer evaluation times, and possible confusion between confirming the absence of prohibited substances and demonstrating Non-GMO sourcing. If the proposal moved forward, annual portfolio-level documentation was generally preferred over separate documentation for each Product.

Outcome

The proposal was withdrawn, and the Affidavit was not included in v17. Version 17 Section 2.2 Input and Ingredient Evaluation clarifies that prohibited Input and Ingredient requirements apply to Inputs and Ingredients within the scope of evaluation.

References: v17 Section 2.2 Input and Ingredient Evaluation, specifically 2.2.1 and 2.2.3.

Summary

Redline Draft 2 made it explicit that certain Biological Compounds normally sourced from animals or humans are prohibited when they are instead produced using Biotechnology. It also extended the prohibition to cell-free systems, while continuing to exempt Enzymes. For example, collagen sourced from Non-GMO animals is allowed in Verified Products, while collagen produced by a GM Microorganism is prohibited. In Question 4 of the Second Public Comment Period, the Project asked whether enough information is generally available to determine how these compounds are produced.

Key Themes

Commenters indicated that the information needed to determine compliance is generally available through existing evaluation processes and did not identify significant implementation challenges. Feedback noted that the change would be particularly relevant to Micro Ingredients because the new requirement gives evaluators a clearer basis for determining compliance based on the source and production method of these compounds. Existing Technical Administrator forms were identified as a practical way to confirm this information without creating new documentation requirements.

Outcome

The proposal was retained in v17. Additional research focused on supporting consistent evaluation of Micro Ingredients under the new requirement.

References: v17 Section 2.2 Input and Ingredient Evaluation, specifically 2.2.1.e; v17 Appendix A Terms and Definitions, “Biological Compound.”

Summary

Redline Draft 2 proposed changing how the Micro Exemption applies to Enzymes and Microorganisms. The Micro Exemption allows certain Micro Ingredients to be used in a Verified Product without demonstrating that the Ingredient comes from a Non-GMO source. Under the proposal, an Enzyme or Microorganism listed in the Ingredient declaration could lose eligibility for that exemption when it was also named in consumer-facing text on the Principal Display Panel, the main display area of the package. The intent was that when a Micro Ingredient is intentionally named as part of how the Product is presented to consumers, the Ingredient would need to be sourced Non-GMO rather than rely on the exemption. In Question 5 of the Second Public Comment Period, the Project asked what kinds of packaging or label formats could create uncertainty about whether an Ingredient was intentionally named in this way.

Key Themes

Commenters indicated that the distinction was generally clear when a Product had a distinct Principal Display Panel. Other package formats could create uncertainty. Small or single-panel packages, shared or fold-out labels, digital or multilingual labels, and information placed on the label to meet regulatory requirements could make it less clear whether an Ingredient was being intentionally named as part of the Product’s presentation to consumers. Feedback cautioned that these circumstances should not automatically cause an Enzyme or Microorganism to lose eligibility for the Micro Exemption.

Outcome

The proposal was refined following additional research. In v17, the requirement applies when an Enzyme or Microorganism is voluntarily named in text on the Principal Display Panel, including when it is reasonably considered to characterize an Ingredient that is voluntarily named there. This distinguishes voluntary naming from information that appears on the Principal Display Panel for other reasons.

References: v17 Section 3.1 Weight Percentage, specifically 3.1.3.a.v.c); v17 Section 10.2 Labeling, specifically 10.2.5.

Summary

Redline Draft 2 retained the proposal to treat Verified as a compliance pathway rather than a Risk Status. This means a Verified Input or Ingredient keeps its own Risk Status, while its Certificate of Verification can be used to demonstrate compliance. Questions 6 and 7 asked whether additional Chain of Custody requirements, the controls used to keep compliant materials identified, separated, and traceable, should apply when a Verified Input or Ingredient is used in another Product and whether those requirements should differ by Risk Status. The Project also asked stakeholders to consider a proposed onsite inspection requirement for facilities Parallel Processing certain Verified Ingredients.

Key Themes

Commenters differed on how far traceability should extend. Some feedback recommended tracing a Verified Ingredient back to the entity that originally obtained verification, while other feedback considered Chain of Custody beginning at procurement sufficient when the Ingredient and its supporting documentation can be identified.

Feedback supported considering Risk Status when determining Chain of Custody requirements, but differed on how to apply it. Suggestions included more extensive traceability and segregation documentation for High-Risk Verified Ingredients and simpler evidence for Low-Risk Verified Ingredients. Food safety certifications and facility procedures were also identified as possible supporting evidence, and some feedback suggested requiring a current Certificate of Verification only for High-Risk Ingredients.

Commenters also questioned whether requiring onsite inspection specifically because a facility Parallel Processes Verified Ingredients would provide enough additional assurance to justify the cost and administrative work. Feedback cautioned that this could discourage Participants from sourcing Verified Ingredients.

Outcome

Verified was retained as a compliance pathway rather than a Risk Status. In v17, Verified Inputs and Ingredients require proof of verification and Chain of Custody from the point of procurement to the finished Product.

The broader questions about whether additional Chain of Custody requirements should apply to Verified Inputs and Ingredients, and whether those requirements should differ by Risk Status, were not fully resolved during the v17 revision and remain areas for continued work.

The proposed onsite inspection requirement tied specifically to Verified Ingredients was not retained. Research on the inspection question expanded into the broader revision of v17 Section 5 Onsite Inspections. The final framework requires annual onsite inspection when a Producing Facility engages in Parallel Processing of a Major High-Risk Input or Ingredient. Beginning November 1, 2027, eligible Producing Facilities may qualify for reduced onsite inspection frequency under the risk-based framework.

References: v17 Section 3.2 Risk Status; v17 Section 3.4 Product Compliance by Input and Ingredient Classification, specifically Table 3-2 Compliance of Verified Inputs and Ingredients; v17 Section 4.1 Activities; v17 Section 5 Onsite Inspections.

Summary

In Question 8 of the Second Public Comment Period, the Project asked what would make a Certificate of Compliance valuable for Ingredients typically used at Minor or Micro levels in a Product. These categories apply to Ingredients used at lower Weight Percentages. The idea was to explore whether a simpler way could demonstrate that an Ingredient used in a small amount meets the applicable requirements of the Standard without putting the Ingredient through the full verification process used for a Product.

Key Themes

Feedback supported exploring a streamlined approach that could reduce evaluation time and documentation for Minor and Micro Ingredients. One suggestion was a Certificate of Compliance that would confirm that the applicable requirements had been met without requiring the broader documentation associated with full verification. Other feedback noted that existing Certificates of Verification are already useful for High-Risk Ingredients at Minor or Micro levels because they can consolidate documents that would otherwise need to be collected separately, such as organic certificates and Non-Testable Affidavits.

Outcome

A separate Certificate of Compliance for Ingredients used at Minor or Micro levels was not added in v17. The broader question of whether additional ways to demonstrate compliance could support the use of compliant or Verified Inputs and Ingredients at Minor and Micro levels remains part of continuing work beyond the v17 revision.

References: v17 Section 3.1 Weight Percentage; v17 Section 3.4 Product Compliance by Input and Ingredient Classification.

Summary

Redline Draft 2 revised the definitions of Input and Ingredient to clarify how they relate to each other and to the Product. Under the revised definitions, every Ingredient is an Input, but not every Input becomes part of the finished Product. Animal feed is an Input to milk production but does not become an Ingredient in the milk. Flour used to make bread is an Input that becomes an Ingredient because it remains in the finished Product. The Input definition also clarified that materials used earlier in production can be Inputs, not just those used at the final manufacturing step. In Question 9 of the Second Public Comment Period, the Project asked how recognizing Inputs “at any point in the supply chain” might improve or complicate how the Standard is understood or applied.

Key Themes

Commenters indicated that the revised definitions reflect how Inputs and Ingredients are already treated during evaluation and do not, by themselves, change which Inputs are within the scope of evaluation. Feedback also raised concern that “at any point in the supply chain” could be interpreted as making Participants responsible for materials several tiers earlier in the supply chain, where they may have limited access to documentation or control over sourcing.

Outcome

The revised definitions were retained. No additional limitation based on ownership or decision-making authority was added to the Input definition because requirements elsewhere in the Standard determine when documentation and compliance requirements apply.

Version 17 Figure 1-1 The Relationship Among Inputs, Ingredients, and Products was also added to illustrate that all Ingredients are Inputs, while some Inputs support production without becoming part of the finished Product.

References: v17 Section 1.3 Methodology and Approach of the Standard; v17 Figure 1-1 The Relationship Among Inputs, Ingredients, and Products; v17 Appendix A Terms and Definitions, “Input” and “Ingredient.”

Summary

Redline Draft 2 clarified that controlled substances and substances that are illegal are prohibited under the Standard. The proposal expanded the jurisdictions considered from U.S. and Canadian law to also include Mexican law and the laws where a Product is manufactured or sold. If a government authority is still determining whether a substance is legal, the Project may also prohibit that substance while the determination is pending. The prohibition applies both to Product eligibility and to Inputs and Ingredients within the scope of evaluation.

Key Themes

No objections to the proposal were identified in the feedback analyzed.

Outcome

The proposal was retained in v17.

References: v17 Section 2.1 Product Eligibility, specifically 2.1.2.a; v17 Section 2.2 Input and Ingredient Evaluation, specifically 2.2.1.a.

Summary

Redline Draft 2 proposed shifting the Project’s tracking of emerging GMO developments from the Risk Status framework within the Standard to a separate public resource designed to support ongoing awareness of crop-specific GMO activity. This would allow the Risk Status framework to focus on classifications that determine compliance requirements. Because Monitored Risk and Low Risk had the same compliance requirements, removing Monitored Risk would not change the applicable requirements for crops listed as Monitored Risk in v16.1. Sugarcane was proposed separately for addition to the High-Risk List.

Key Themes

No objections to the proposal were identified in the feedback analyzed.

Outcome

Monitored Risk was removed as a Risk Status in v17, separating the Standard’s compliance classifications from the Project’s tracking of emerging GMO developments. The applicable compliance requirements for crops listed as Monitored Risk in v16.1 did not change. Sugarcane was addressed separately and was added to the Non-Testable High-Risk List, effective December 1, 2028. The Project now maintains the GM Crop Library as a separate public resource for tracking emerging GMO developments outside the Standard.

References: v17 Section 3.2 Risk Status; v17 Table 3-1 The Three Risk Statuses.

Summary

Redline Draft 2 proposed more specific requirements for evaluating mushroom cultivation substrates, the materials used to grow mushrooms. The proposal clarified when cultivation substrates would be within the scope of evaluation, when Compost could be excluded, and when substrates would be excluded because the mushroom is used as a Micro Ingredient.

Key Themes

Feedback recommended standardized documentation to support consistent evaluation across Technical Administrators. Feedback also questioned how the Weight Percentage of substrate Inputs should be determined and suggested using the approach applied to Growth Media rather than the approach used for livestock and poultry Rations.

Outcome

Additional research explored a new method for evaluating non-composted cultivation substrates. Technical Administrator consultation identified practical concerns, including how far back in the supply chain documentation would need to be obtained. The proposed new method was withdrawn, and the mushroom-specific requirements presented in Redline Draft 2 Section 9.4 were removed.

Version 17 Section 2.2 Input and Ingredient Evaluation identifies mushrooms and mushroom cultivation substrates directly among the materials within the scope of evaluation, while established evaluation practices continue. Mushroom cultivation substrates are excluded from the scope of evaluation when the mushroom is represented in or present in the finished Product as a Micro Ingredient.

References: v17 Section 2.2 Input and Ingredient Evaluation, specifically 2.2.2.c.vii and 2.2.3.d.

Summary

Redline Draft 2 retained the proposal to classify sugarcane as High Risk in response to the commercial availability of GM sugarcane and the resulting potential for commingling in the supply chain. Sugarcane was proposed as Non-Testable, meaning sugarcane-derived Inputs and Ingredients would follow the applicable Non-Testable High-Risk compliance pathways. The Second Public Comment Period provided another opportunity for stakeholders to comment on the classification and its potential effect on the supply chain.

Key Themes

No objections to the proposal were identified in the feedback analyzed.

Outcome

Sugarcane was added to v17 Appendix B.1.1 as Non-Testable, with its High-Risk classification taking effect December 1, 2028. Beginning on that date, sugarcane-derived Inputs and Ingredients in new Products shall comply through the applicable Non-Testable High-Risk pathways. Existing Products shall comply beginning with their next renewal after December 1, 2028.

Reference: v17 Appendix B High-Risk List, specifically Appendix B.1 Testable and Non-Testable High-Risk Inputs and Ingredients.

Summary

Redline Draft 2 carried forward several proposals introduced during the First Public Comment Period. These proposals had not changed substantially and were presented again during the Second Public Comment Period.

Key Themes

No objections to these proposals were identified in the feedback analyzed.

Outcome

The proposals were retained in v17. They include:

• standardizing mandatory language by using “shall” instead of “must,” without changing the requirements;
• defining Probiotics and updating related terminology;
• removing language describing the Growth Media exclusions for Probiotics and Enzymes used in vitamin and supplement Products as temporary or subject to future review;
• clarifying the Testable and Non-Testable definitions to better reflect how testability is determined under the Standard;
• retaining the contract processor inspection exemption while removing language describing it as subject to future review;
• refining references to Products, Inputs, and Ingredients where compliance requirements apply specifically to Inputs and Ingredients; and
• moving Participant administration and other program requirements to The Non-GMO Project Program Rules and Procedures so the Standard focuses on Product evaluation.

The final changes are described in the Summary of Changes from Version 16.1 of the Standard.

Summary

General feedback included in the Second Public Comment Period analysis covered scientific, technical, program, policy, and consumer issues that did not respond directly to a specific question. The comments raised questions about how the Standard determines GMO status and compliance, what Non-GMO Project Verification communicates to consumers, how certain Inputs and Ingredients are evaluated, and barriers to participation and access to program information. Some of this feedback led to additional research during the revision, while other topics fell outside the scope of the Standard or were referred to relevant teams for further consideration.

Key Themes

Process-based and outcome-based compliance: Feedback questioned whether the way something is produced should determine compliance when no GMO material is detectable in the resulting material. Examples included a proposal to allow egg-derived materials to demonstrate compliance through testing of the resulting material rather than through the poultry Ration, and a proposal to allow nature-identical Ingredients produced through fermentation using Biotechnology when no modified DNA is detectable in the resulting compound.

Scope and meaning of Verification: Feedback raised questions about what the Butterfly label establishes beyond GMO avoidance. Comments asked whether Verified Products may be produced using glyphosate or synthetic fertilizers and why Products containing artificial colors, natural flavors, substantial amounts of sugar, or other attributes a consumer may consider undesirable can still be Verified. Feedback also questioned how an individual Product can be Verified when the same company or manufacturing operation produces GMO Products.

Evaluation consistency and documentation: Feedback raised several questions about how existing requirements are applied. These included whether Minor and Micro Inputs and Ingredients should be treated consistently when a livestock or poultry Ration is itself the Product or is used as an Input, how mushroom cultivation substrates should be documented and assigned a Weight Percentage, and whether the Apiculture Affidavit adds information beyond organic certification.

Participation and program access: Feedback identified the 1.5% Action Threshold as a potential barrier to verification for Products that are not ingested or topically applied, such as textiles, packaging, cleaning supplies, and other household Products. For these Products, Testable High-Risk Inputs and Ingredients generally must test at or below 1.5% GMO presence to demonstrate compliance. Feedback questioned whether this level is achievable for some agricultural materials, particularly where cross-pollination or other contamination is unintentional. Other concerns included verification costs for small companies, access to certificate information and a searchable certification database, and the amount of material stakeholders were asked to review during public comment.

Emerging Biotechnology techniques: Feedback asked whether gene-edited organisms are classified as GMO under the Standard when no foreign gene is inserted and whether mRNA-derived Inputs and Ingredients are included within the Standard’s definition of Biotechnology. Some feedback requested that these technologies be identified more explicitly in the Standard.

Post-harvest coatings: Feedback raised several concerns about coatings applied to produce. These included whether a coating could trap pesticide residues or other contaminants on the produce, whether a discontinued coating should remain eligible for Verification, and whether the complete formulation, extraction process, and safety of a coating should affect how it is treated under the Standard.

High-oleic sunflower oil: Feedback raised concerns about the sourcing and marketing of high-oleic sunflower oil. The comment addressed seed origin and GMO status, differences in fatty-acid composition and oxidative stability, and whether marketing claims accurately represent differences among high-oleic and other sunflower oils.

GMO labeling and food-safety policy: Feedback raised broader questions about the safety of GM foods and whether GMO foods should carry more prominent or mandatory labeling. These concerns extended beyond the requirements established through the Product Verification Program.

Environmental impacts and the future of GMO avoidance: Feedback raised concerns about environmental impacts associated with farmed fish, the potential release of materials used in Genetic Engineering into the environment, biodiversity, and whether GMO avoidance can remain viable as Genetic Engineering becomes more widespread.

Consumer support and education: Feedback expressed support for the Butterfly label, Verified Products, and the Project’s educational work. Commenters described using the label and Project communications to inform purchasing decisions and encouraged continued consumer education about GMOs and the food supply.

Fundamental disagreement with GMO avoidance: Feedback also challenged the Project’s overall approach to GMO avoidance. The comment argued that GMO risks are mischaracterized and that opposition to GMO technologies could impede agricultural research and technologies intended to contribute to food security.

Outcomes

Changes and additional work during the revision

• Livestock and poultry Rations: Research confirmed that Minor and Micro Inputs and Ingredients are excluded from evaluation whether the Ration is itself the Product or is used as an Input to an animal-derived Product. This treatment is reflected in v17.
• Mushroom cultivation substrates: Feedback informed additional research into substrate evaluation and standardized documentation. The proposed new evaluation method was ultimately withdrawn, and established evaluation practices continue.
• Apiculture Affidavit: Research identified differences in how organic certification bodies evaluate apiculture-derived materials. The Affidavit requirement was retained.
• 1.5% Action Threshold: Additional research considered whether the threshold should change, whether testing methodology contributed to the difficulty of demonstrating compliance, and how existing compliance pathways apply to these Products. The 1.5% Action Threshold was retained.
• Emerging Biotechnology techniques: The GMO definition was retained. Subsequent work resulted in v17 Appendix C Biotechnology Techniques, which provides representative examples of techniques included within the definition of Biotechnology.

No Standard change or work outside the General Standard Revision

• Process-based compliance: Feedback proposing that compliance be based on testing or the characteristics of the resulting material did not change the Standard’s process-based approach. No Product-specific exemption was added for egg-derived materials based on testing, and no general pathway was added for nature-identical Ingredients produced using Biotechnology based on chemical equivalence or the absence of detectable modified DNA.
• Agricultural chemicals and other Product attributes: Questions about glyphosate and synthetic fertilizer use did not result in Standard changes because the Standard does not regulate agricultural chemical use. Questions about sugar content, flavors, colors, and other Product attributes likewise did not result in changes because Non-GMO Project Verification addresses GMO avoidance rather than broader nutritional or compositional qualities. Feedback about the scope and meaning of Verification was referred for consumer education where appropriate.
• Post-harvest coatings: Concerns about post-harvest coating safety, pesticide residues, formulation, and extraction processes did not result in Standard changes because those issues fall outside the Standard’s GMO-avoidance requirements. Coatings and their Inputs and Ingredients remain subject to the Standard where they are within the scope of evaluation.
• High-oleic sunflower oil: The feedback did not result in a Standard change. Questions about fatty-acid profile, oxidative stability, and comparative marketing claims fall outside the Standard’s requirements, while sunflower remains outside the High-Risk List.
• Broader GMO policy and environmental concerns: Questions about GM food safety, mandatory GMO labeling, environmental regulation, biodiversity, and environmental monitoring did not result in changes to v17. These issues extend beyond the requirements established by the Standard.
• Program access: Verification costs and proposals for expanded certificate access or database functionality were referred to relevant teams because they are administered outside the Standard.
• Public comment accessibility: Feedback about the accessibility of the public comment process was retained for consideration in future Standard revisions and stakeholder engagement.
• Consumer support and disagreement with the Project’s approach: Supportive feedback did not require a change to the Standard. Feedback fundamentally disagreeing with the Project’s GMO-avoidance approach did not propose a change to a specific requirement and did not result in a change to v17.