We're often asked how Non-GMO Project Verification and USDA Organic Certification intersect. If "Organic is always non-GMO," then what does the Non-GMO Project Verification mark offer to brands and shoppers? A lot! Let's walk through it.
The Non-GMO Project Verification Program is focused solely and deeply on GMOs, supported by testing and supply chain tracing. USDA Organic Certification is a holistic, process-based certification with practices modeled on natural ecosystems. Each certification examines food production from different angles. But when the two seals appear together on your favorite products they reflect the gold standard for food.
Only the Butterfly tests for GMOs
The Non-GMO Project is a single-issue certification. We look at one thing, and we look at it deeply. This focus lets us dive intensely into the world of traditional and emerging GMOs to monitor developments in a rapidly growing field. Keeping up with the biotech industry is a full time job. Specifically, it is the full time job of the Non-GMO Project research team that monitors the industry’s developments.
By contrast, the National Organic Program — or "NOP," which develops regulations for USDA Organic certification — examines the systems of agricultural production. To become a certified organic producer, farmers develop and implement an "organic system plan." This plan covers a range of practices, such as preserving soil health, crop rotations, pest management, livestock care and more. The system is designed to build soil, minimize erosion and protect the water supply from contaminants — all laudable aims.
While GMOs are considered an Excluded method of production under the NOP regulations, there is no requirement for testing and no mechanism to address contamination. The phrase "Organic is always non-GMO" is based on the idea that a producer, having followed their organic system plan, will not have purposefully used GMOs. The reality is that GMOs travel. Pollen drifts on wind and by the movement of diverse wildlife. Genetically modified organisms, once released into the environment, cannot be recalled.
That is why the Non-GMO Project Standard outlines explicit requirements for GMO avoidance, including ongoing testing of all major ingredients considered high-risk for being GMO. By evaluating each product rather than the system that produced it, our Standard tackles contamination (or fraud) in Non-GMO Project Verified products — including how to correct an issue and keep the Butterfly strong.
Without testing requirements, the National Organic Program can miss contamination events and even outright fraud. A well-publicized case of organic fraud came to light in 2018, in which a Missouri farmer sold $140 million of conventionally grown grain as organic. The farmer's activities were ultimately discovered by the FBI — not by the USDA or the NOP — because of other criminal activities that were funded by the fraudulent acts.
How non-GMO supports organic
By examining how our food is produced from different perspectives, Organic Certification and Non-GMO Project Verification provide shoppers with a much clearer picture of what they are investing in. That's not the only way that these two certifications complement each other.
Farms are often impacted by what happens upwind and upstream. Given GMOs’ propensity for travel, an organic farmer whose neighbors grow non-GMO is better protected from contamination. A non-GMO buffer makes the investment in organic just that much safer. That's important, because transitioning to organic is a long and costly process. Before a farm can even be considered for organic certification, the land must be free from non-organic practices — including synthetic fertilizers, pesticides and GMOs — for 3 years. That's 3 years during which a farmer adopts new practices, but is not yet able to sell their product as organic. After the 3 year transition period, certification can take another 3-6 months. That is a significant financial investment, with 3-4 years before the farmer sees a return.
Farmers often operate with tight margins, and to stagger the costs of going organic, some choose to transition their land incrementally, becoming "split producers." In this case, transitioning organic and non-organic operations exist side by side under the same operator. For split producers, growing non-GMO crops on pre-transition plots acts as an investment in their organic future, and because non-GMO doesn't require a transition period, the premiums producers earn from their non-GMO crops are gained within the growing season.
When the National Organic Program was first introduced, genetically modified crops were also quite new. The first draft of the NOP was published in 1997 — an incarnation which actually allowed the use of genetic engineering. The public outcry was deafening. Of course, the draft was revised, and the spirit and practice of organic production emerged. Genetically modified organisms were listed as an Excluded method in the "Terms defined" section, akin to a glossary.
At this time, there were only a handful of GMO crops on the market. They were produced using DNA from other species and engineered to either withstand the application of herbicides or to produce an insecticide within the plant. Since then, emerging techniques for producing GMOs have outpaced regulation, investments in agricultural biotechnology have skyrocketed and GMOs face deregulation and decreased scrutiny. USDA officials have made public statements on the benefits of genetic engineering — even within organic agriculture — to the horror of many in the organic movement.
This worries us, and we're not the only ones. It also concerns the National Organic Standards Board, or "NOSB" — the federal advisory committee that assists in developing standards for Organics:
"Genetic engineering is a rapidly expanding field in science. The NOSB recognizes the need to continually add methods to the list for review and to determine if the methods are or are not acceptable in organic agriculture."
There are currently two NOSB recommendations which would update and expand the definition of GMOs to include some of the emerging techniques in genetic engineering. They were submitted in 2018 and 2019, and neither has been integrated into existing regulations. During that time, the Non-GMO Project team has observed a massive increase in GMO development. Business is booming while regulation is stalled.
Biotech companies go to great lengths to market new GMO technology as something distinct from traditional GMOs. This is a blatant attempt to distance themselves from negative perception of GMOs held by much of the public. In the European Union, new GMOs are regulated as traditional GMOs, but the stance in North America remains purposefully shrouded. This confusion has the power to erode public trust in federal certifications, ultimately allowing loopholes through which new GMOs can enter the food supply in places consumers would not reasonably expect them. That's why the Butterfly is more important than ever — it remains the highest standard for GMO avoidance in North America.
Each certification provides you with valuable insight into what you are purchasing and what kinds of agriculture you are supporting with your purchase. The combination of the USDA Organic Certification and the Butterfly seal offers a unique and powerful leverage point for working towards a better food system for all. The future is organic and non-GMO!