Non-GMO Project responds to new IGEN Program for non-GMO labeling

NutraSource Diagnostics’ program for vitamins and supplements could mislead consumers

On Monday, NutraSource Diagnostics announced a new non-GMO labeling program for vitamins and supplements. Based on testing of finished products and ingredients, the program, called IGEN, has three tiers. In the absence of a published standard the technical details are vague, but the information available seems to suggest that the IGEN Program has critical shortcomings and could potentially mislead consumers.

As a non-profit organization committed to preserving and building a truly non-GMO supply chain, the Non-GMO Project would like to shed light on what we feel are some apparent flaws of the new labeling scheme.

Testing finished products and ingredients does not reliably show GMO content

Tiers 1 and 2 of the IGEN Program are based on testing of finished product and ingredients, respectively. This approach is fundamentally flawed because DNA and proteins are often degraded during processing, meaning that even a very sensitive test cannot always accurately quantify the GMO content of the source material.

Because of these limitations, it is possible, for example, to take a batch of corn that is 100% GMO and turn it into a processed ingredient that can return a test result of “non-detect,” or show only very low levels of GMO. Although a non-GMO claim can be made on this basis, it would arguably be very misleading to consumers.

For this reason, the Non-GMO Project Standard requires that “appropriate laboratory controls indicate that the DNA of the input or the input’s precursor is sufficiently intact to allow valid quantitative analysis.” In short, no matter how sensitive or accurate the test, the Non-GMO Project won’t accept the results unless testable components of the source material were still largely present. In contrast, the new IGEN Program appears to have no such requirements for tiers 1 or 2.

Products of synthetic biology, gene editing, and other new forms of genetic engineering may not be detectable by testing

Another basic problem with a non-GMO claim based only on testing is that new forms of genetic engineering are rapidly entering the market for which tests may not be available. For example, there are dozens of products of synthetic biology now in commercial production, none of which can be identified with a test, and many of which could potentially be used in vitamins and supplements. Likewise, products of gene editing, another new form of genetic engineering, are often difficult or impossible to test for using current methods.

The only way to make a meaningful non-GMO claim in relation to such inputs is through a verification system that requires a multi-pronged approach of testing, traceability, and segregation. The Non-GMO Project Standard requires thorough documentation to demonstrate absence of inputs derived from new and untestable forms of genetic engineering. In contrast, the IGEN Program’s reliance on testing does not appear to control for products of synthetic biology or gene editing.

IGEN Tier 3 unlikely to correspond with Non-GMO Project Verified

A March 6th article in NutraIngredients USA states that tier 3 of the IGEN Program “corresponds to the level of GMO-free certainty supplied by a Non-GMO Project.” Although it is impossible to disprove this statement without the IGEN standard available publicly, the veracity of this claim seems extremely unlikely. The Non-GMO Project has verified vitamin and supplement products since 2010, with annual revisions to its Standard reflecting ongoing learning from this very complex sector.

Over the past 18 months in particular, the Project has been working intensively with the Coalition for Supplement Sustainability to ensure the rigor and meaningfulness of its Standard in relation to vitamins and supplements. Among other things, this work has involved the development of specialized program documents informed by highly technical and exclusive production flowcharts that took years to source and compile. Version 14 of the Non-GMO Project Standard, ratified on March 3rd and effective as of April 3rd 2017, further reflects the specialized expertise that the Project has developed in consultation with industry experts.

Finally, an important part of the Non-GMO Project Verified claim is that it is backed by third-party credibility and non-profit trustworthiness. The Project follows international principles for credible standard setting, including rigor, transparency, and impartiality. In contrast, based on the information available it seems IGEN is a private for-profit program operating to an undisclosed standard with no public comment process.

Bottom line: Non-GMO claims on products derived from GMO ingredients are misleading to consumers and undermine important efforts to transform the supply chain

Despite the unique challenges with transparency and sourcing of non-GMO ingredients for vitamins and supplements, committed companies have made great strides in recent years and will continue to do so. Claims based on diluted programs undermine this critical progress on ingredient transparency. The Non-GMO Project supports meaningful non-GMO claims that are in the best interest of the consumer and advance the preservation and growth of the non-GMO supply chain.