Many people are familiar with the most common GMO crops — corn, soy and canola — but did you know that some potatoes are also GMOs? GMO potatoes are so common that potatoes have been added to the Non-GMO Project's High-Risk List.

The High-Risk List identifies crops most likely to come from GMO sources. Non-GMO Project researchers look at criteria such as how a crop is used, how many acres are planted with it, and its potential to contaminate other crops to determine which crops are at a high risk of coming from GMOs. You can find out more about the High-Risk List here.

The varieties of GMO potatoes which are currently available entered the market in 2015. By 2018, these spuds had sufficient presence in the US supply chain and were added to the Non-GMO Project's High-Risk List. 

GMO potatoes — not their first rodeo

The GMO potatoes currently on the market are not the first of their kind. Agrochemical giant Monsanto engineered the first generation of GMO potatoes to produce their own insecticide. Food writer Michael Pollan chronicled his experience growing them at home. However, Monsanto's GMO potatoes came and went in the late 1990s and early 2000s without gaining the market share earned by more recent GMOs.

In 2015, the FDA approved J.R. Simplot's "Innate" White Russet GMO potato. The White Russet was engineered to reduce discoloration and to produce less acrylamide when cooked. The following year, the company added the Simplot "Innate" 2G Russet Burbank, which carried the same traits as the White Russet, plus protection from potato blight.

The White Russet and Russet Burbank were created through a genetic engineering technique called RNA interference, or RNAi. RNAi artificially interrupts genetic instructions from reaching their destination inside the cell, effectively "silencing" the expression of specific genes. The gene that causes discoloration when the potato is damaged has been silenced in GMO potatoes.

It's crucial to note that while the discoloration does not occur, the damage still does. One of the scientists behind Simplot's GMO potatoes has expressed his concern that they might be treated more roughly during harvest and transport because they give the impression of indestructibility. Not only do GMO potatoes conceal damage, their creator says, they conceal a lot more of it. Discoloration, though unsightly, serves an essential purpose by identifying places where pathogens might have entered.

Where are they now — and how can you avoid them?

GMO potatoes are part of the US food supply. Many grocery stores carry them in the produce section, bagged whole and raw. They might also be processed into other products, such as frozen foods and prepared products that contain potato or potato derivatives (e.g., potato starch, potato flour, dextrose, or potato alcohol).

Whole potatoes sold in grocery stores carry the name "White Russet" with language such as "reduced bruising" and "fewer black spots" displayed on their packaging. Because the USDA's List of Bioengineered (BE) Foods includes GMO potatoes, the bags must carry a disclosure, such as text, a website or phone number, or the BE logo. (While the Non-GMO Project supports mandatory labeling of GMOs, the bioengineered food labeling law in its current form can be complex and counterintuitive — you can find out more about it here.)

However, BE foods can be harder to discern when found in processed foods. For example, a product made from GMO potatoes as a primary ingredient (think potato starch) doesn't require a BE disclosure if there is no detectable DNA in the finished product. Or, a can of beef stew with GMO potato chunks would not require disclosure if meat is the first ingredient listed on the package. Even if water, broth or stock is the first ingredient and meat is the second, the stew still wouldn't carry a disclosure because those kinds of liquids don't count.

Restaurants and other food service venues using bioengineered ingredients are not required to provide BE disclosures. Interestingly, McDonald's, one of the largest potato buyers in the world, made headlines when it declared it would not use Simplot's GMO potatoes for its french fries. 

GMOs on the horizon

J.R. Simplot has several more GMO potato varieties in development that are not yet available. At the same time, other biotechnology companies are pushing the boundaries of genetic engineering techniques — and potatoes. Check out our New GMO Alert for the low-down on Finally Foods, a start-up working on genetically modified potatoes that express dairy proteins.

As always, the Non-GMO Project's dedicated research team monitors developments in the biotechnology industry and the state of GMOs in the supply chain — including changes to the High-Risk List. We work to provide up-to-date and valuable information so you can decide for yourself whether or not to eat GMOs.

Did you know that most GMOs on the Non-GMO Project High-Risk List are commodity crops? These GMOs are processed into low-nutrient ingredients that appear in an estimated 80% of packaged goods sold in stores. 

And then there's papaya. Papayas are also considered high risk for being GMO because most US-grown papaya is genetically modified for disease resistance. However, it's different from most other crops on the High-Risk List. While many other GMOs were produced by huge agrichemical corporations, GMO papayas were developed by researchers at the University of Hawaii. Plus, papayas are usually sold fresh or frozen, not as ultra-processed additives in packaged goods. 

Let's look at the outlier on the High-Risk List — the GMO papaya. 

Getting to know papayas

Papayas are technically berries that grow on tall, tree-like plants. They are native to Central America and do well in tropical climates. Modern papaya farming takes place in Asia, Africa, and the Americas. Common varieties for US markets include the small, solo-type grown in Hawaii, which usually weighs less than 1 lb, and the larger Maradol varieties produced in Mexico, which weigh 3-5 lbs.

Papayas are susceptible to various insect pests, including the papaya whitefly, papaya webworm, hornworms, leafhoppers, aphids and scale insects. Insects can also act as vectors for disease. One of the greatest threats to papaya production, a pathogen called Papaya Ringspot Virus (PRV), is spread by aphids as they move from one plant to the next. A papaya plant infected with PRV develops discolored and mottled leaves and suffers from stunted growth. Young plants might die quickly, while older ones produce small quantities of substandard fruit with distinctive "ringspot" markings. 

PRV is a global problem for papaya producers. Wherever papayas are grown, PRV is there.

The problem with papayas

Papayas were first introduced to the Hawaiian islands in the 1800s, and commercial cultivation began the following century. During the 1950s, PRV was discovered in commercial plantations on Oahu. Papaya production shifted to the Big Island in an attempt to outrun the pathogen, but this strategy was unsuccessful. By the mid-2000s, Hawaiian papaya production had fallen by more than 50% because of PRV.

Researchers at the University of Hawaii were looking for a solution to protect the papaya industry and turned to biotechnology. They inserted viral genes into the papaya to impart PRV resistance, like a vaccination. PRV-resistant GMO papayas are available today as the red-fleshed SunUp and the yellow-fleshed Rainbow varieties.

After regulatory agencies approved GMO papayas in 1998, commercial growers quickly adopted them. Since then, the media and biotech industry have touted Hawaii’s GMO papaya as a shining example of how genetically modified crops are an unquestioned success. 

The papaya question(s)

GMO papayas have so far been effective at reducing PRV, but the road has had some bumps. Adopting GMOs meant that some countries that didn't accept GMOs closed their doors to Hawaiian-grown fruit, and organic farmers risk GMO contamination as pollen drifts from genetically modified plants. The industry facing a destructive pathogen was ultimately reshaped by the GMO varieties adopted to resist that pathogen. PRV has evolved in China to evade the GMO papayas' defenses.

Another question is about the purported necessity of GMO papayas. If PRV poses an existential threat to the papaya industry that only GMOs can avoid, how do other papaya-growing countries continue without them? India, for example, is the world's largest producer of papayas, but the only GMO crop approved for commercial cultivation is Bt cotton. Or Mexico, which is another papaya powerhouse. The US imports 80% of the papayas we consume from Mexico, where PRV is present in papaya-growing regions, but GMO papayas are not. According to recent reports, the papaya industry in Mexico is flourishing. 
GMOs continue to attract controversy in Hawaii, where biotech companies take advantage of the long growing season to develop GMO seeds for sale on the mainland. In recent decades, a passionate and dedicated movement against GMOs and pesticide spraying has emerged, with citizens demanding a more sustainable food system that protects Hawaii’s environment and people. Let’s hope their voices will be heard, and the safety, health, and values of this beautiful island paradise will be preserved for generations to come. Take part in the movement by choosing USDA organic or Non-GMO Project Verified papaya.

We get this question a lot. 

Non-GMO Project Verified and USDA certified organic are the two most sought-after labels at the grocery store. Both are considered clean-label indicators, both deal with agricultural production — and both certifications take strong stances on GMOs.

However, Non-GMO Project Verified and USDA certified organic are different certifications. They accomplish different things and go about it in different ways. As a single-issue certification, the Non-GMO Project is uniquely positioned to help preserve and build the non-GMO food supply. 

Here's how our expertise sets the Butterfly apart from other clean label certifications, including USDA certified organic.

A clear definition

Definitions are crucial to any certification. A well-crafted and specific definition helps to establish a shared understanding of the certification's scope.

The Non-GMO Project Standard's definitions of GMOs and biotechnology (the techniques used to create GMOs) are adapted from an international agreement ratified by 173 countries that aims to address potential risks posed by living modified organisms. Our definitions offer essential clarity about what is (and what isn't) a GMO, providing a north star in the changing landscape of biotechnology.

The Standard defines GMOs as organisms to which biotechnology has been applied, and defines biotechnology as the application of 

1. in vitro nucleic acid techniques, including recombinant deoxyribonucleic acid (DNA) and the direct injection of nucleic acid into cells or organelles; or  
2. fusion of cells beyond the taxonomic family, that overcame natural physiological, reproductive, or recombination barriers and that are not techniques used in traditional breeding and selection.

It is essential to work from an established, recognized and concise definition of GMOs, particularly as the applications of biotechnology evolve rapidly. 

Emerging biotechnology techniques are leading to a steady stream of new GMOs, many of which are entering the marketplace unlabeled and unregulated. Examples of new techniques include molecular farming, synthetic biology, and gene editing techniques such as CRISPR and TALEN. Around the globe, the biotech industry is lobbying regulatory bodies to treat new GMOs as though they aren't GMOs at all, shifting the goalposts to ease the market arrival of novel products that have never before been part of the human diet.

The USDA National Organic Food Production Act does not include a definition of "genetically modified organism." Rather, GMOs are described within the definition of "excluded method." The definitions included in the Non-GMO Project Standard help the Butterfly react to new GMOs as they enter the supply chain, remaining firm in the face of industry spin.

Testing and surveillance

The Non-GMO Project Standard requires that all major, testable, high-risk ingredients undergo testing to ensure they come from non-GMO sources, while untestable high-risk ingredients are assessed by legally binding documentation, such as affidavits. Additionally, the Surveillance Program monitors Verified products on store shelves to ensure compliance. Read our blog to learn more about testing and surveillance.

However, the National Organic Program does not require testing for GMOs. The Program sets forth specific provisions for how organic farming and manufacturing are to be conducted, with the assumption that products made per this guidance are organic. However, it does not challenge or verify those assumptions through testing. According to Non-GMO Project Executive Director, Megan Westgate, "It’s important to understand that claims like 'organic is always non-GMO' are based on intention rather than fact." 

Given the ubiquity of GMO crops such as corn and soy, the prevalence of GMO contamination and the complexity of the supply chain, we believe the non-GMO food supply is best served by rigorous testing requirements. 

Action threshold

Under the Non-GMO Project Standard, an action threshold offers a precise metric by which to evaluate test results. However, an action threshold is not a GMO allowance. Action thresholds reflect the complexity of the supply chain and the reality of GMO contamination, helping to make our Standard meaningful and achievable. 

On the other hand, organic certification does not indicate action thresholds for contamination by GMOs or any other excluded method. This makes sense under a process-based organic certification which does not require testing for GMO contamination. However, Non-GMO Project Verified is a product-based certification that requires testing of major, high-risk ingredients and sets action thresholds by which to assess test results.

The focus and rigor of the Non-GMO Project Standard helps set the Butterfly apart from other clean label certifications. In 2014, Consumer Reports compared the Butterfly with USDA certified organic, self-made non-GMO claims and conventional products. It found that Non-GMO Project verification offered the strongest mechanism for avoiding GMOs due primarily to testing requirements. Testing provides added certainty in the strength of the claim and helps protect your right to choose whether or not to consume GMOs.

Non-GMO Project verification focuses on the single issue of GMOs. GMOs in the food and personal care industries are our area of expertise – hence our name – and we adapt continually to the changing landscape of biotechnology. As a single-issue certification, the Butterfly is uniquely positioned to assess the state of the non-GMO supply chain, moving us closer to our goal of a truly non-GMO food supply.

Since 2007, the Non-GMO Project has been a leader in raising awareness of GMOs in the food supply. It's an issue that impacts every single one of us, at breakfast, lunch and dinner. Today, an estimated 96%¹ of Americans are familiar with the GMO issue. 

However, our work isn't done. The bioengineering landscape continues to evolve alongside a barrage of industry messages about novel food ingredients. New terms, new techniques, and misguided or misleading information add to the confusion. 

Having the basics at your fingertips is essential for making the right decision for yourself and your family about whether or not to consume GMOs. So let's get down to it: How are GMOs created? What are "new GMOs" and how does the changing landscape of biotechnology impact your food supply?

What are GMOs?

A GMO, or genetically modified organism, is a living thing whose genetic makeup has been altered using biotechnology. Biotechnology includes techniques such as using synthetic genetic sequences to change the organism's genetic material (i.e., DNA or RNA), or forcing the combination of very unrelated organisms that would not normally reproduce in nature. Manipulating a living organism's genetic material can change its fundamental characteristics and may result in gene sequences never before seen in nature.

Some biotechnology techniques force the combination of organisms that are not reproductively compatible by inserting foreign DNA into a target organism. The result is called a "transgenic GMO." The most common example of a transgenic GMO is a soybean plant with bacterial genes that make the plant immune to certain weedkillers. Other transgenic GMOs include genetically engineered corn, canola, cotton, sugar beets, alfalfa, pineapple and papaya.

Transgenic GMOs represented only a handful of crops, but they've had a massive impact on North American acreage and the food supply. Today, most conventional prepared foods in the grocery store contain ingredients and inputs derived from GMOs. Meanwhile, a new generation of GMOs made from emerging techniques is proliferating in the supply chain. 

What are "new" GMOs?

New GMOs, also known as "NGTs," are made from emerging technologies such as gene editing. They have crucial differences when compared with traditional, transgenic GMOs  — we'll unpack those below. However, new GMOs are still made using biotechnology, and that means they are GMOs under the Non-GMO Project's definition and under existing international standards.

So, new GMOs and transgenic GMOs are both created using biotechnology. There are also important differences between them, including the following:

• New genetic engineering techniques don't necessarily use foreign DNA to modify an organism. This can impact whether or not their production has government oversight or whether the products must be labeled as a GMO.
• Some new GMOs that use foreign DNA are made into highly processed ingredients, so the modified genetic material is removed from the final product. Again, this often results in the product not being labeled as a GMO.
• Some new techniques are cheaper and more accessible than transgenic technology. We've seen a dramatic increase in the number of biotech developers exploring the field.

Because of these differences, products made with new genetic engineering techniques largely side-step regulations and labeling requirements designed for transgenic GMOs, meaning new GMOs are increasingly entering the food supply unlabeled and unregulated.

New GMO techniques involve altering an organism's genetic material by adding, removing or cutting DNA or interfering with gene expression. While new techniques have been heralded as precise tools with which to modify an organism's genome, significant uncertainties remain. Genes are incredibly complex, powerful and delicate things; unintended outcomes and off-target effects are common in biotechnology.

Do GMOs feed the world?

We've mentioned that most processed, conventional food in grocery stores is made using GMOs. Because GMOs are so prevalent in the food system, many people are surprised to learn that most GMOs aren't used to feed people. 

GMO crops such as corn, soy, cotton and alfalfa are grown on more than 200 million acres in the U.S. alone. More than half of the crops grown on that land end up in animal feed. Another 40 million acres-worth goes toward biofuels such as ethanol or biodiesel. The fraction that goes toward human consumption shows up as highly-processed, low-nutrient additives. 

GMOs are in our food, but they don't feed us and they certainly don't nourish us. In fact, most people on Earth, around 70%, rely on the expertise of small-scale farmers who operate outside of the industrial agriculture system favored in North America. 

GMOs are an effective tool to increase the profit margin of massive agrochemical corporations. GMO crops and their growing systems often require excessive chemical inputs to ensure production, and the costs associated with growing GMOs can push farmers into debt. The vast monocultures where GMO flourish invite disease, pest infestations, and soil degradation for which the agrichemical industry offers even more accompanying chemical or fertilizer “solutions” (for a price). 

Every day, we all make choices about the kind of food system we want to create and leave for future generations. The Non-GMO Project protects your right to choose non-GMO at every meal.

Note: This post was originally published on October 6, 2023 and since has been updated to reflect the latest data.

¹ Organic & Natural 2022, ©2022 The Hartman Group, Inc.

"Each seed held a trace of life that would spark when given water, when given the appropriate conditions. Everywhere I looked, I saw how seeds were holding the world together."

— Diane Wilson, author of "The Seed Keeper"

Take a moment to think about what you've eaten so far today, or what kinds of fabrics you're wearing. Now consider where that food and fiber came from. 

Most of the raw ingredients that meet our basic daily needs start with seeds, tiny but powerful players that deserve to be celebrated. A seed that grows into a mature plant can generate hundreds or thousands of more seeds for you to save and share next year. Also, seeds are in a constant state of adaptation. They have evolved in tandem with the natural environment for millions of years, and, since humans began practicing agriculture, we've helped to shape the Earth's seeds, and be shaped by them.

If you have a green thumb and a bit of garden space, sowing seeds is a fascinating and frugal way to fill your yard. Did you know growing and saving seeds can also help build strong communities, help expand genetic biodiversity and generate locally-adapted crops? 

Partners in diversity

People have been planting, growing, harvesting and selecting seeds for around 12,000 years, giving rise to countless new crop varieties. The power of seeds combined with the impact of human intervention have laid the foundation for a resilient agricultural system. All the different kinds of crops, from wild relatives to natural varieties to more recent cultivars, contribute to diversity — specifically, agricultural biodiversity. Agricultural biodiversity is the variety and variability of animals, plants, and micro-organisms that are important to food and agriculture. It results from the interaction between the environment, genetic resources and the impact of human intervention. 

Seed diversity is, quite simply, the difference between fortune and famine. We mentioned above how a single seed can generate hundreds or thousands more — that is wealth generation, right there! The converse is also true: When we rely on too few crops or too few varieties of crops, our agricultural systems become precarious, and could be wiped out by a single pest infestation or disease. In a diverse system, many different crops are grown together, each with its own strengths and weaknesses. The variety makes it harder for a single pest to cause devastation.  

Diversity also helps crops adapt to extreme weather events, which are occurring with more frequency as the climate changes. Through each growing season, seeds adapt a little to the particular microclimate, soil conditions and external stressors they experience. Skilled farmers and seed breeders carry the strongest seeds forward, encouraging helpful traits such as tolerance of drought or poor soil and the ability to grow on uneven terrain. Traits are carried forward into the next generation, and so on.

When it comes to seed and food, diversity is most definitely our strength.

Use it or lose it

"More than 90% of crop varieties have disappeared from farmers' fields."

— United Nations Food and Agriculture Organization

However, diversity must be nurtured. During the last century, the rise of industrial-style agriculture has undone a shocking amount of the previous 12,000 years of work. An estimated 75-90% of plant genetic diversity has been lost because farmers were encouraged to give up locally-adapted, regional seeds in favor of hybrids and GMOs, which can't be saved. Farmers have to purchase new seed every season from the multinational corporations that own them. A global market of privately owned, unsaveable seed makes farmers dependent on external inputs, on supply chain disruptions and corporate greed. In most of Canada and the US, seed saving is a thing of the past. 

A loss of diversity is apparent on the corporate landscape, too. After decades of mergers and acquisitions, 60% of the global seed supply is now owned by just 4 corporations. 

What you can do

There are many ways to celebrate the wonder of seeds at home.

If you have space for gardening, this is the perfect time of year to get sowing! Here are some resources to get you started:

• Learn more — The Organic Seed Alliance offers fantastic resources for home growers interested in growing and saving seeds. We recommend their Seed Saving Guide.
• Find seeds — Seeds are for sharing! Exchanging seeds with friends and neighbors is a fantastic way to build community and share the wealth. Or, check out your local seed library. Seed libraries are often affiliated with regular public libraries, and they work in basically the same way — search this map to find one near you. The Seed Savers Exchange helps you share seeds online with other growers. If you decide to purchase seeds, seek out products from smaller-scale seed companies. Feed stores and food co-ops often carry seed from regional companies who work in your area. Our favorites, such as Botanical Interests and High Mowing Organic Seeds, include midsize companies with products available nationally. 
• Practice landrace gardening — "Landraces" are seeds that are adapted to their local microclimate through the efforts of the gardener or farmer who grows and saves them (that could be you!). Landrace gardening is open to everyone, and Joseph Lofthouse's book will help get you started. 

If you aren't able to sow seeds yourself, you can still support people who do. Here's how: 

• Join a CSA — CSA stands for Community Sustainable Agriculture. It's a subscription service where people buy a share of a local farmer's produce before the start of the season. Farmers use that money to grow the freshest and bestest produce, delivering boxes to shareholders over the following months. CSAs are a win-win because they provide financial security to local farmers and fantastic food to subscribers. Local Harvest operates a database of thousands of CSAs across the US. 
• Visit a farmers' market — Meet your farmer at the local farmers market! Many of the same growers who operate CSAs can be found at farmers markets on the weekends — find out where here.
• Listen to seed stories — Seeds offer much more than food, fiber or fuel. Seeds are a crucial part of cultural identities and traditional practices. One of the many gifted storytellers who use their work to feed the spiritual side of seed stewardship is Diane Wilson, activist and author of "The Seed Keeper" — you can listen to our interview with Diane here.

Just like a seed, our actions in supporting agricultural diversity can start small. If we all choose seed saving over corporate seed ownership, together we can move towards a more secure food system that supports all life on earth. 

The Non-GMO Project operates North America's most trustworthy certification for GMO avoidance. Products undergo rigorous evaluation by third-party experts to ensure the formulations meet the requirements of our Standard. However, our vigilance doesn't stop there. The Non-GMO Project team also conducts year-round surveillance to ensure the Verified products you see on store shelves can withstand the strictest scrutiny.

The Surveillance Program supplies an added layer of rigor to product verification. It's a barometer of our efficacy at delivering the promise of the Butterfly. Surveillance provides crucial insight into how the Standard's benchmarks help the Non-GMO Project achieve its goals. 

Let's look more closely at the Surveillance Program's goals, processes and ambitions. 

Which products are good candidates for surveillance?

Selecting Verified finished products for the Surveillance Program begins with a random group pulled from our database. From that list, we ask a series of questions, narrowing the selection down to products that will generate meaningful and accurate results while addressing the most impactful aspects of the supply chain. 

"Does it contain a high-risk ingredient?" — The first question we ask is about risk status. The term "high risk" indicates that the GMO version of a crop is so commonplace in the supply chain that a buyer would likely end up with a GMO unless they intentionally looked for a non-GMO version. "High risk" does not indicate an inherent danger to human, animal or environmental health. 

Assigning risk statuses helps us focus scrutiny on the parts of the supply chain where we're most likely to encounter GMOs. You can learn more about risk status here.

"Is the high-risk ingredient testable?" — Not all GMO crops are detectable through commercially available tests. In recent years, we've seen a dramatic increase in non-testable GMO crops. The Product Verification Program and the Surveillance Program have evolved to address the issue of non-testable GMOs while maintaining program rigor. 

Products made with non-testable GMOs are still part of the Surveillance Program. Still, the review process differs from products made with testable high-risk ingredients — we'll explore testability in greater depth below.

"How processed is the high-risk ingredient? How processed is the finished product?" — Processing can degrade DNA, making it harder to detect genetically modified DNA through testing, which is particularly significant when reviewing finished products. Processing includes any manufacturing step to transform the raw agricultural product into a finished, consumer-ready product, such as cooking, milling or refining.

Let's see how processing impacts different products made with corn, a high-risk crop, to see how this plays out. Corn shows up in a variety of forms, which directly impacts surveillance.

Example #1 — Corn oil. While the main ingredient of corn oil is corn, corn oil is a highly refined product. We know that processing can degrade DNA, and that is particularly true for refined oils. Generally, if you can see through a product, it's unlikely to be a good candidate for surveillance. Refined corn oil is unlikely to contain sufficient intact DNA for testing, making it a poor candidate for surveillance.

Example #2 — Corn flour. Like corn oil, corn flour is made from corn as the main ingredient. However, unlike corn oil, it is minimally processed, leaving sufficient DNA for an accurate test result. Corn flour would be a good candidate for surveillance testing.

Example #3 — Baked goods. What if the product we're checking is a baked good made with corn flour, corn oil or cornstarch as one of many ingredients? This one is tricky. Remember that corn oil is too refined for testing. The corn flour might produce an accurate test result depending on how much of it is in the product formulation. The testability of cornstarch varies depending on how it is processed. However, the amount in each product unit is likely too small to produce an accurate test result. With so many variables at play, our team's technical expertise would be crucial to determining next steps.

Rest assured that even the products not selected for surveillance are still thoroughly evaluated by independent technical administrators during verification.

Having narrowed the selection to the most impactful products, the surveillance team procures products. We look for products in the same places shoppers get them: brick-and-mortar stores and online retailers. This approach ensures that our samples honestly reflect what the public buys and consumes, though it does involve some practical limitations. Not all products are available or in stock when we want them. Our team is based in the U.S., while the Non-GMO Project label can be found on products for sale in Canada and Mexico, too — we might not have access to products sold across national borders. Perishable or refrigerated products pose unique challenges.

The Surveillance Program reviews at least 1% of all Verified products (currently more than 64K) each year, amounting to hundreds of products made with high-risk ingredients that undergo extra scrutiny and testing.

How testability impacts surveillance

When the surveillance program began in 2016, all the crops on the High-Risk List were testable. Since that time, the biotechnology landscape has changed. Non-testable GMOs have become much more common.

When we refer to a crop as "testable," we mean there are commercially available tests that can pick up the presence of modified DNA. Of course, ingredients and derivatives made from a testable GMO crop aren't necessarily testable because processing can degrade DNA (this is particularly important with surveillance, which deals exclusively with finished products). We prioritize products made with minimally processed high-risk ingredients to make the most of the Surveillance Program's resources.

A "non-testable" GMO means there is a GMO crop for which no commercially available test is currently available. The difference between the two often comes down to how the GMOs are made. Regulators often required developers of older GMOs to produce a test for their product to bring it to market. However, GMOs made from newer techniques don't necessarily face the same regulatory hurdles. GMO developers are unlikely to provide a test if regulators don't require one.

To be clear, GMO crops, whether made with old techniques or new ones, are not inherently untestable. Testability comes down to whether a test has been developed, not whether a test could be developed. For our purposes, if no widely available and reliable test exists on the market, that GMO crop is considered non-testable.

The rise of non-testable GMOs in the supply chain has driven evolution in product verification and surveillance to ensure the Standard remains meaningful, regardless of testability. New processes are in place specifically to address the rise of non-testable GMOs in the supply chain, and verification relies on legally binding documentation such as affidavits. Surveillance of products made with non-testable, high-risk crops involves a document-based review. 

The question of compliance

The vast majority of Verified products reviewed under the Surveillance Program are in compliance with the Non-GMO Project Standard, meaning that they meet the requirements of the Standard. The required documentation is up-to-date and test results show that modified DNA does not exceed the action threshold. High levels of compliance show that the Product Verification Program sets an achievable benchmark and most brands and third-party technical administrators have checked every box during the verification process. 

The Non-GMO Project invests a great deal of thoughtfulness and expertise into the Surveillance Program. Surveillance draws on technical expertise and supply chain vigilance to keep the Butterfly soaring. It illuminates where the Non-GMO Project Standard supports our goals and where there are opportunities to refine our approach, collaborate with stakeholders and increase our efficacy. We continually look for ways to improve it and glean more valuable insights.

Surveillance is a compelling measurement of how well the Butterfly delivers on its promises to shoppers and eaters across North America. 

Did you know that two-thirds of U.S. households share their homes and lives with pets? That's 86.9 million homes with dogs, cats, birds, fish, lizards, turtles, rabbits, and more. To some, pets are delightfully weird little guys who live with us rent-free. To others, they are essential service providers whose talents, smarts and noses help us navigate the world. 

And to nearly all, they are family. 

Just like our families, we want to give them the best. With an estimated $63 billion in sales last year, pet supply companies are continuously upping their game to meet our expectations and our pets' needs.

Let's explore where GMOs can show up in pet products and why you might want to seek non-GMO options. 

The truth about cats and dogs

North Americans are more likely to live with a cat or dog than any other kind of creature. Unsurprisingly, products for house panthers and canine companions dominate the market — not to mention the list of Non-GMO Project Verified products. 

Cat and dog products share some of the same ingredients and, therefore, some of the same GMO risks. Recipes revolve around meat, poultry and fish, which is good news for conscientious shoppers. Commodity crops such as GMO corn, soy, canola, cottonseed and alfalfa mostly end up in livestock feed, so choosing meat, poultry or fish products with non-GMO or organic certification can have an outsized impact on the GMO supply chain.

GMOs are also used as secondary ingredients, such as corn, soy or canola. Our regular readers know that GMO commodity crops can harm soil health, environmental wellbeing and farmers’ ability to save seed — all good reasons to seek out non-GMO options. Pet supply brand Honest Kitchen shared their compelling reason for going non-GMO in their 2021 Impact Report, citing a study in which "hogs that were fed a genetically modified diet had considerably more stomach inflammation than a group fed a strict non-GMO diet." Ouch.

Birds, bunnies and beyond

Cats and dogs aren't the only show in town, of course. Practical reasons such as allergies or lack of space can lead animal lovers to explore the joys of smaller pets, including birds, rabbits, and guinea pigs, to name a few. The Non-GMO Project is proud to work with several brands catering to small animals' unique needs.

Some commonly used ingredients in small animal feeds come from crops considered high risk of coming from GMOs, such as soy, canola, corn and alfalfa. Harrison's Bird Feed explains its decision to source non-GMO and organic ingredients by describing the shortcomings of conventional products on the market. 

Traditional feed, they write, "...removes [the] seed coat, using steam, high pressure, or solvents to separate high-value components, such as oils, vitamins, antioxidants, and nutraceuticals. What is left is classified as a byproduct. Corn used for ethanol, various fibers and simple carbohydrates are reconstituted in various feeds. These starches are further bleached, colored and offer the ideal base for extrusion caramelization, giving a light fluffy finished product. The resulting flours act like purified sugars, digest fast and overwhelm the homeostasis of the nutrient system." 

We're grateful to brands like Harrison's for communicating their non-GMO commitment. Honest Kitchen, whose 2021 report we mentioned above, used more than 15 million pounds of non-GMO produce that year in their pet products. That's a lot of happy dogs and cats! 

Millions of pounds of non-GMO ingredients can make a lot of other animals happy, too. Farmers who switch from GMO crops to non-GMO report increased biodiversity in their fields — more pollinators, microorganisms and wildlife whose activities support the food system all of us depend on. And maybe those wild animals aren't going to fetch a ball or snuggle with us while we watch TV, but that's okay. We've already got family for that.  

Spring is on the horizon.

For gardeners, this is the perfect time to plan what to grow this year. Seed catalogs are arriving in the mail with a dizzying array of choices. However, some of these catalogs appear to be written in code, with lingo that leaves the beginning gardener scratching their head. If you don't know the difference between a hybrid and an heirloom, if you can't tell your cultivars from your cross-pollination, we're here for you. 

Here's a basic list of terms.

Skip to the glossary

But first, let's address the elephant in the room: GMOs. Historically, GMO seeds have not been available to home growers. Farmers who purchase GMO seed sign restrictive use agreements, so it is unlikely that the average citizen would accidentally buy and plant GMO seeds. However, that's starting to change. 

The GMO purple tomato is the first GMO seed made available to home growers. Last year, a few small farmers in the U.S. sold the tomatoes at farmers markets. This year, the GMO Purple Tomatoes will be available at select retail and farmers market locations, and seeds are sold online. You can find out more about the GMO Purple Tomato, including non-GMO alternatives that offer the same health benefits, here.

And now, the glossary!

Cultivar — A cultivar is a group of plants that have been bred through human intervention for desired traits. The word "cultivar" is short for "cultivated variety." Cultivars may be propagated reliably through cuttings or grafting, but are unlikely to retain the characteristics of the parent plant if grown from seed.

"F1" — This term appears frequently in seed catalogs. "F1" indicates a hybrid seed. "F1" is the first generation following the successful cross-pollination of the two parent plants. The cross-breeding process can continue: Offspring of F1 hybrids would be called F2 hybrids, indicating that they are part of the second generation, and so on. As a hybrid, "F1" seed will be stable for one generation, but the seed those plants produce will not remain "true to type," retaining the characteristics of the original parent plant.

Heirloom — An heirloom plant variety is a named, open-pollinated strain that either pre-dates modern breeding programs or has not been altered by them. As a general rule of thumb, heirloom varieties have undergone open-pollinated reproduction for more than 50 years. 

Hybrid — A hybrid is a new variety of plant that is made through crossing two different parent plants of related species. While hybridization can occur naturally, home growers most often encounter hybrids that were purposefully created by seed breeders by crossing two parent plants with desirable traits. The increased genetic diversity of a hybrid can result in more abundant crops, a phenomenon known as "hybrid vigor." If you're interested in saving seeds season after season, keep in mind that hybrid plants grown in your garden won't produce seed that is "true to type" because the genetics aren't stable. 

Landrace — A landrace crop is a cultivated variety, or cultivar, that has evolved over generations of farmer selection. Landrace crops contain great genetic diversity and can display a range of traits. The quality that they share is their adaptability. Landrace crops will thrive in the bioregion where they were produced — a quality called "local adaptation." Their genetic diversity makes them a gold mine for traits such as drought-tolerance or pest-resistance. Landraces are constantly changing in response to their environment and the decisions of the farmer who grows them.

Open-pollinated — Open-pollinated plants are propagated in a field, the pollen carried by wind or pollinating insects and animals to neighboring plants. Open-pollinated plants grown in isolation will produce seed that can be saved year to year, whereas open-pollinated plants that are allowed to cross with others of their species will produce hybrids (see hybrid). Open-pollinated seeds are a better choice than hybrids if you're interested in saving seeds produced in your home garden and replanting them next year.

Variety — A variety is a group of plants that has evolved due to natural selection rather than human intervention. The plants have naturally evolved to exhibit a common set of characteristics, and those characteristics vary from the rest of its species. Plants grown from the seed of a species variety will often produce exact copies of the parent plant. 

On the last day of 2020, Mexican President Lopez Obrador pledged to phase out GMO corn imports and prohibit the use of glyphosate — the herbicide that commonly accompanies many GMO crops — by 2024. The decree was ambitious and controversial, and faced immediate pushback from U.S. trade representatives. Since the initial decree, Mexico has softened its stance, agreeing to GMO corn imports for animal feed and industrial uses but not for human consumption. 

However, despite Mexico's concession, the dispute between the two countries continues. America is the birthplace of GMOs, including GMO corn. More than 92% of the corn grown in the States is GMO. Mexico is the birthplace of corn, and one of the United States' largest agricultural trading partners. 

The U.S. alleges that GMO corn restrictions violate the United States-Mexico-Canada Agreement (USMCA), the trade agreement which replaced the North American Free Trade Agreement (NAFTA) in 2020. The combination of NAFTA and GMO corn devastated the livelihoods of Mexican corn farmers in the 1990s, setting the stage for the current dispute.

The trouble with NAFTA

Before NAFTA went into effect in 1994, Mexican farmers supplied most of the corn for domestic consumption. The government protected corn farmers by allowing foreign imports only if the domestic supply faced a shortfall.

NAFTA eliminated the Mexican government's protection mechanisms for Mexican farmers while preserving U.S. corn subsidies for American farmers. The results were devastating for Mexico. During NAFTA's first decade, cheap U.S. corn flooded the Mexican market, causing the price of domestically-grown corn to plummet. The economic devastation to Mexico's agricultural sector cannot be overstated, and contributed to a 75% increase in illegal immigration into the States.

During the same time period, genetically modified corn entered the market. As GMO corn was adopted by more U.S. farmers, it gained a foothold in shipments headed for Mexico.

GMO contamination in the homeland of maize

The cultivation of genetically modified corn for commercial purposes is already prohibited in Mexico. That means that it's illegal to grow GMO corn with the intention to sell it into the marketplace. While some GMO corn has been grown in test plots in Northern Mexico, agribusiness writer and researcher Tim Wise believes the test plots are not significant sources of contamination. "[It] isn’t pollen on the wind, it’s kernels of maize in people’s pockets.” Kernels that came across the border as imported grain.

Mexico imports an estimated 16 billion tons of U.S. corn each year. Most of that is genetically modified yellow corn used for livestock feed or industrial purposes. Mexican farmers grow white corn domestically for human consumption. However, corn is a very promiscuous crop, and different varieties of corn can cross-pollinate. The resulting GMO contamination of native corn varieties grown in Mexico is well-documented.

"The source of life"

The word "maize" is often used interchangeably with the word "corn." The term comes from the Indigenous word mahiz, meaning “source of life." The reverence of the crop's name underscores its importance to food security, political stability and cultural identity. 

In the U.S., the National Corn Growers Association's director of public policy Angus R. Kelly objected to Mexico's initial decree, which he criticized as a rejection of biotech crop traits "without any scientific basis." Dismissing Indigenous rejection of unwanted technology as "unscientific" is a common racist dog whistle reflecting bigoted views. It's also simply not true. There is science supporting caution or outright rejection of GMOs, including significant work supplied by the Union of Concerned Scientists. (Since the initial decree, the U.S. has declined Mexico's proposal to undertake joint scientific research on GMO corn).

What threat does GMO contamination pose to native Mexican corn varieties? A report written by the Commission on Environmental Cooperation explored the issue in 2015:

"Impacts on the genetic diversity of Mexican maize could have direct repercussions on the diversity of maize and ecosystems in all of North America and the rest of the world. Mexico is one of the centers of origin for maize. To lose a variety of maize in Mexico is to lose it throughout the planet."

The report also notes that one trait of the contaminating pollen — the production of Bt insecticide — has had negative effects on non-target organisms in the United States.

The native species at risk of contamination carry invaluable genetic information and unique traits. Many can thrive in difficult growing conditions such as poor soil or mountainous land. Protecting native corn allows breeders to incorporate their traits into new varieties, creating plants that are crucial as we adapt to a changing climate.

The Non-GMO Project applauds Mexico's decision to restrict genetically modified corn imports, safeguarding native maize varieties from GMO contamination and preserving Mexico's cultural heritage. This bold action will help protect and build the non-GMO food supply while preserving Mexico's sovereignty and autonomy.