It's been a big year for the biotech industry. You may have noticed the wealth of headlines reporting breakthroughs in gene editing and other new GMO techniques, news stories littered with acronyms like CRISPR, TALEN and RNAi. These are just some of the new techniques being used to create novel products in our food supply — some of which are even being marketed as "non-GMO"!
But you won't see the Butterfly on these products.
At the Non-GMO Project, we recognize that any process in which an organism’s genetic material is engineered in a laboratory is genetic engineering. The products of emerging techniques — including CRISPR, TALEN, RNAi and gene drives — are GMOs. The Non-GMO Project Standard adheres to the definition of GMOs laid out by the Codex Alimentarius, the internationally recognized set of standards addressing food issues, from production to labeling and everything in between.
Because the new federal bioengineered food labeling law does not recognize many products of emerging genetic engineering techniques as GMOs, tracking new techniques and their impact on the food supply is more important than ever. Rest assured, the products of gene editing are excluded from the Non-GMO Project Standard, and packaged goods that rely on gene-edited ingredients are not eligible to wear the Butterfly seal.
A GMO-producing trio: TALEN, CRISPR and RNAi
In 2019, a GMO soybean became the first gene edited crop commercially available in the United States. The soybeans were engineered using a technique called TALEN, resulting in more oleic acid and fewer trans-fats. These soybeans do not require disclosure under the new bioengineered food labeling law, and oil or meal derived from the GMO soybeans could end up entering the food supply marketed as a "non-GMO product."
TALEN has also been used to modify alfalfa for animal feed, and even to modify the animals themselves. One infamous case of TALEN-gone-wrong can be found in the GMO cattle engineered to be hornless. The hornless bull was initially hailed as a success, but was later found to contain non-bovine DNA that could increase antibiotic resistance. This extra genetic information was picked up in the lab during the genetic engineering process. Critically, the company responsible for the creation of the GMO cattle did not find this error — it was detected purely by chance by an FDA researcher running tests on software.
Another gene-editing tool used to create GMO livestock is CRISPR. Of all the emerging acronyms, this is likely the most familiar, as CRISPR has generated a lot of press — and controversy. Its creators won the Nobel Prize in Chemistry for their discovery, while a scientist in China "shocked the world" with the use of CRISPR to edit human embryos.
There are many projects involving CRISPR in development, including some varieties of genetically modified livestock. Researchers are working to create animals that offer producers higher profit margins or can better withstand the harsh conditions of factory farming. Genetically modified animals include such creations as "double-muscled" pigs and poultry with enhanced immune systems.
CRISPR is often described to layfolk as "operating like a pair of scissors." Or, in a much grander vision for the future, the Nobel Prize press release described CRISPR as "a tool for rewriting the code of life" — a jaw-dropping example of hubris considering how much we don't know about the function of genetic material.
Whether it's kitchen chemistry or re-creating the world, the overall message is, "We've got this."
In truth, we very much don't have this. The gene-editing process can impact sections of DNA that weren't intended, creating so-called "off target effects." There are also the unforeseen consequences resulting from our limited knowledge of the complex and interrelated functions of genes.
"A close look at Cosmo’s DNA after birth revealed Crispr’s unpredictability. Researchers said there was a piece of genetic code that didn’t belong, and Cosmo had more SRY, the gene that causes male traits, than intended."
The Baker City Herald continues with a description of odd side effects in other CRISPR animals: “pigs with extra vertebrae, cattle that die prematurely, rabbits with huge tongues.”
This "rewrite" of the code of life is clearly not ready for publication.
Short for RNA Interference, this new GMO technique uses RNA molecules to interfere with the expression of certain genes in order to modify an organism's attributes. For example, RNAi was used in the creation of the Arctic Apple to interfere with the apple's natural tendency to turn brown when it's cut open.
Additional products of RNAi currently on the market include some varieties of Simplot Innate potatoes, engineered to reduce the appearance of bruising. The trouble with inhibiting a gene to hide damage is that the damage is still there, weakening tissues and providing an entrypoint for pathogens. It's only the visual indicators that have been eliminated. At the Non-GMO Project, we believe that's important information and we're better off recognizing it for what it is.
Syn(bio) City — GMO dairy, breast milk and "meat juices"
Short for synthetic biology, “synbio”refers to the merging of biology and engineering. Currently, the term largely refers to the genetic engineering of microorganisms such as yeast and is often used to produce flavorings or dairy proteins.
Synbio dairy proteins are a hot item in the frozen foods aisle, providing the key ingredient to several GMO frozen dairy desserts, including Brave Robot, Smitten N’Ice Cream, Nick's and Graeter’s Perfect Indulgence. These brands all get their "dairy-identical" synbio dairy proteins from a single source: Perfect Day, who brought their own limited release ice cream to market for $20/pint a few years back. One of the co-founders at Perfect Day, Ryan Pandya, described their marketing strategy in enigmatic terms: "We want people to know it’s plant-based but not from plants, it’s an animal product but without animals." Which leaves one to wonder: What is it, then? Well, it's GMO.
These dairy-without-the-animals desserts put a lot of weight on their non-animal status, appealing to the vegan market. But here we hit a snag: Producing the non-animal dairy protein relies on a digitized copy of a cow gene. While that information is part of an open source database, the genetic material originally came from an animal. According to Perfect Day, it came from a cow named L1 Dominette 01449. Depending on how strictly one defines and practices veganism, the origin of the genetic material becomes vitally important. A product that originated with blood drawn from a cow may not satisfy some vegans.
Other synbio products include human collagen for the skin care market, as well as "heme," a synbio compound that is used to create meat-like juices in the Impossible Burger. The Impossible Burger is also a tricky proposition for vegans: While the heme is derived from GMO soybeans, Impossible Foods conducted animal testing during its development.
Developers are also using new techniques to synthesize proteins found in human breast milk, with a potential use in GMO infant formula.
The Butterfly is more important than ever!
With novel products made with new GMO techniques entering the market, it's more important than ever to look for the Butterfly. Many of these products won't require a "bioengineered food" disclosure under the new BE labeling law — a law which focuses on foods with detectable modified genetic material in the final product.
The biotech industry knows all too well that the majority of Americans want GMOs to be clearly labeled. So, as they bring new products to market, they are bending over backwards to distance themselves from the simplest and most powerful acronym of all: G-M-O.
At the Non-GMO Project, we believe that everyone has the right to know what's in their food. That is only more critical in light of emerging technologies and new techniques, creating organisms that humans haven't eaten before.