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On April 21, 2021, the USDA invited public comments on the future of the food system: From commodities and food crop production to the supply chains that process crops and transport them. This kind of comprehensive look at critical systems is both timely — with lessons learned from the global pandemic — and crucial to our collective welfare and security as we face a changing climate. 

Among the Non-GMO Project's guiding principles is the belief that everyone deserves access to good food. Food security, climate change and social justice are inextricably linked, and each element inevitably impacts the others. 

We are in a moment unlike any other in human history. The interconnected impacts of our choices and the consequences of "business-as-usual" lie in sharp relief. There is a shared sense of purpose and a renewed appetite for change, drawing us toward systemic reforms that benefit producers, workers and consumers alike.

In support of a truly resilient, regenerative food system that supports jobs and wellbeing today and for generations, the Non-GMO Project advocates for: 

Industrial agriculture is currently the dominant practice in the United States. While this system has produced high-yield, low-cost commodity crops, a closer look reveals exorbitant hidden and externalized costs, including environmental degradation, biodiversity loss and increased health risk to millions of consumers.

Because of the systems of centralized power that "lock in" industrial agriculture, change will be most effective when economic and social policies are grounded in ecological principles. 

Here, we offer our vision for the future.

A systemic shift toward diversified farming systems

While uniformity is the basis of an industrialized system, diversity is the basis of resilient agriculture.

Agriculture occupies more than 900 million acres of land in the United States, the overwhelming majority of which is used for livestock and the production of a few GM commodity crops. 

This homogenous and extractive model squanders natural resources, devastating biodiversity above and below ground. Industrial-style crop production degrades soil and hastens erosion. Monoculture planting creates ideal conditions for destructive pests and pathogens because it works against the natural inclination of the landscape towards diversity. 

Biodiversity is critical to successful and sustainable agriculture. Pollinating insects and birds are responsible for a third of the food we eat, while crops rely on healthy soil that is home to billions of invertebrates and microorganisms. 

Diversified farming systems that integrate livestock and crop production drastically reduce the need for costly synthetic fertilizers while supporting healthy soil. A growing body of evidence indicates diversified farming systems can provide a diverse and healthy diet with sustained yields over time and strong performance under environmental stressors. 

Healthy ecosystems provide a range of services that support human health: water and air purification, nutrient cycling, habitat and food for diverse species and billions of soil microorganisms that are the basis for new medicines. Support for these activities is vital: There is more crucial natural infrastructure in a healthy landscape than we could ever hope to construct by artificial means. 

The challenges we face in the coming decades require bold action. We must provide economic incentives for farmers to rebuild healthy ecosystems in their operations. Subsidies for commodity crops — many of which are overproduced — should be redirected as incentives for diversification: promoting crop rotation, nutrient-dense fruits, nuts and vegetables, as well as non-GMO and organic foods. Using more acreage for domestic consumption will revitalize rural economies.

Moving from an extractive model of agriculture toward a diverse and regenerative one will improve soil, water and air quality, restoring them as high-quality resources just as valuable as the crops. By adopting a holistic view of our food system and optimizing production practices, we will build a sustainable and resilient system — aiding our work to heal a broken planet.

Regional food hubs

The Covid-19 pandemic illuminated and exacerbated our food system’s pre-existing flaws. Consolidation in food processing has produced brittle supply chains, unable to adapt to disruptions. More disruptions are coming: The form may vary, but disruption has become a recurring variable rather than an outlying event. 

During this time, there were also success stories. Small-scale and organic operations pivoted during the pandemic, meeting the needs of farmers and their local communities.  What worked provides a blueprint for a truly resilient and nimble food system.

We must create a strong network of regional, mid-size processing, storage and transportation infrastructure to protect the supply chain, enhance agility and create markets for small and mid-sized producers. Designed strategically, smaller processing plants also offer safer work environments — an important consideration given the increased frequency of emerging zoonotic diseases.  

By intentionally building a diverse and regionally-based production and processing system, we bolster the supply chain against future disruptions and create market opportunities for smaller operators.

Everyone deserves access to nutritious food

The elements of a nutritious diet are well-known: regular, moderate meals with an emphasis on plant-based foods. But our agricultural landscape doesn't reflect our goals. It reflects the reality of unbalanced, unsustainable and unhealthy food choices, prioritizing high-yield crops with lower nutrient density.

For example, of more than 900 million acres of agricultural land*: 

If every American voluntarily switched to a healthy, flexitarian diet with plenty of fruits and vegetables, there would not be enough produce to feed them. 

We eat what we grow, and we are as sick as our landscape. 

Food issues emerge in different forms: Food insecurity stems from poor access, often due to poverty or the absence of grocery stores. Nutritional insecurity, on the other hand, when we rely on low-quality foods. A poor-quality diet may meet our caloric needs, but fresh foods and essential nutrients are lacking. Diet-related diseases are the number one cause of mortality in the States. 

Food insecurity increased dramatically during the pandemic — particularly in families with young children and in Black and Hispanic households. We've seen government programs and private entities scramble to provide meals to those in need. If we transition acreage to diversified farming systems and strengthen regional food networks, federal and state initiatives such as SNAP, WIC and school meal programs could create markets for locally-produced, nutritious food. By building these intersecting systems across the supply chain, we can move beyond food security and toward true nutritional security, crop diversification and secure markets for nutrient-dense fruits, vegetables and nuts — a triple win.

The solutions to food and nutrition insecurity are often regionally specific. These are unique situations determined by population density, social dynamics, geography or myriad other factors. A "one-size-fits-all" approach to food and nutritional security simply doesn’t work. 

However, fantastic organizations across the country are already deeply engaged with the communities they serve. We must increase support and funding for regional food hubs that prioritize local and nutritious food, food sovereignty, and food justice, elevating this expertise to benefit the communities that need it the most.

Workers' rights: Seed saving, secure incomes and support for BIPOC farmers

Through land theft, dispossession and exploitative working conditions, the modern food system has been devastating to the people whose labor sustains it. Black farmers saw an erosion of ownership and food sovereignty over the past century. Millions of essential workers who earn their living doing hourly work in the food sector — from on-farm to processing and service jobs — make some of the lowest wages in the country. 

Discriminatory laws fail to provide some of these positions with basic protections and marginalized and BIPOC workers disproportionately bear the impact. The continued denial of rights and protections to an essential sector of the workforce sustains inequalities that have been part of the agricultural system since this country's founding. We must build something better for the workers who feed us.

Owners and operators on agricultural land are also struggling. For 19 of the past 20 years, the average farmer spent more to produce crops than they earned from their operations. Subsidy programs improved the financial outlook of commodity farmers, but these programs prop up an inherently unsustainable system. By redirecting support to promote diverse farming systems, farmers gain income security, produce more nutrient-dense food and regenerate their land.

Ultimately, converting acreage toward diversified operations reduces mechanization and leads to more hands-on jobs. It is essential to create a labor market that does not rely on exploitation. Through legislation and policy development, we must increase support for groundbreaking nonprofits like the Fair Food Program, a highly successful certification and enforcement program that improves conditions for workers. 

Our vision for the future of our food system relies on integrated systems and a bold commitment to social and environmental justice. It is a heavy lift. But the challenges we have faced during the past 18 months are proof of just how quickly systems can change in a crisis. Adaptation saves lives and livelihoods. When the initiating event is not a once-in-a-century pandemic but an existential threat to humanity in the form of climate change or the ongoing nutritional deficiencies and food insecurities that stifle our potential, surely we can act just as decisively. 

As the Covid pandemic recedes, we welcome the Biden Administration's efforts to "Build Back Better." We respectfully ask for bold action to ensure nutrition security for all and to restore our environment.



USDA, Agricultural Statistics Board, NASS, Prospective Plantings, 2021.

USDA, ERS, The Adoption of Genetically Engineered Alfalfa, Canola and Sugarbeets in the United States: Report Summary, 2016.

USDA, NASS, 2017 Census of Agriculture, 2019.

"Okay, you see this little bean that destroyed itself and gave you a new sprout?... Put that in the soil so you can get a hundred other ones, and then put one of those in the soil so you can get a thousand." Ron Finley, educator, activist, gangster gardener

Seeds are magical things. Each seed contains all the information it needs to grow into an entire plant, providing food and shelter and even producing "offspring" in the form of next season's seeds. Over the years, seeds adapt to their environment, the changing weather cycles and soil types, becoming better candidates for success in their little corner of the world.  

The crops we grow today are the product of millions of years of natural selection, as well as millennia of human stewardship around the globe. During the last century, private interests, corporate consolidation and some very questionable court rulings have changed how seeds are grown, saved, shared and sold. 

In the early 20th century, plants and seeds were considered natural creations. As products of nature, not of man, they could not be patented. Since that time, a lot has changed. Today, restrictive seed patenting is the norm, and 60% of the world's seed supply is owned by just 4 chemical companies. This has major implications for farmers who have traditionally saved seed from year to year. When it comes to GMOs, Jack Kloppenburg remarks in his book First the Seed, "farmers no longer buy seeds, they rent that seed." 

How did we get from there to here?

Who owns plants?

"It would be 'unreasonable and impossible' to allow patents upon the trees of the forest and the plants of the earth." U.S. Commissioner of Patents, 1889

Patents are a kind of intellectual property right meant to promote and protect innovation. They provide legal ownership to the inventors of new and useful discoveries for a limited period of time. Different classes of patents apply to different types of inventions. The largest category is "utility patents," which can apply to "any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof." Many of the appliances, gadgets and gizmos that we use in modern life would have been covered by utility patents when they were invented. 

Ownership of living organisms like plants, however, was viewed differently at the beginning of the last century. Living organisms were considered products of nature and not eligible for patents. The work of plant breeders and seed producers is unique: It's a combination of the products and processes of nature and human intervention. 

In time, provisions were made to offer some protection to plant breeders. Plant patents were first introduced in 1930. However, seed varieties — which reproduce sexually and include many of our common food crops — were not eligible for plant patents. It wasn't until the Plant Variety Protection Act of 1970 (PVPA) that seed breeders had some protection for the varieties they produced. The PVPA walks a fine line: While it offers protection to seed breeders, the Act acknowledges that continued innovation depends on the plants and seeds being shared. To keep the practice of plant breeding moving forward, neither plant patents nor plant variety protections provide the kind of exclusive power that utility patents — which we mentioned above in relation to appliances and gadgets — do. According to legal scholar Malla Pollack, the laws that protect plant breeders have two significant exceptions: "one allowing farmers to save seed for later planting and one allowing research. " 

Under the PVPA, seed varieties can, in some instances, be shared. Other researchers can build on the earlier work, and farmers can save seeds for planting the next year — a practice that bolsters their autonomy and builds a supply of regionally-adapted seeds that offer some of the best genetic traits for resilience and high yields.

Genetically modified organisms and the techniques used to create them are eligible for the much more restrictive utility patents. This classification prohibits farmers from saving or breeding the seed and keeps the genetic material private for the duration of the patent. 

The legal basis for this decision is all thanks to General Electric, an oil spill and a genetically engineered bacteria.

How GMOs changed the landscape 

In the 1970s, microbiologist and General Electric employee Dr. Ananda Chakrabarty created a genetically engineered bacteria capable of breaking down crude oil. Dr. Chakrabarty saw a potential use for this bacteria in cleaning up oil spills. His quest to patent his invention inadvertently set the stage for the privatization of the seed supply. 

Dr. Chakrabarty's GMO bacteria was initially denied a patent because bacteria is a living organism. Living organisms were considered a "product of nature" by the U.S. Patent Office. The only patent class that permitted living organisms was plant patents, and the GMO bacteria didn't fit in there. Ultimately, the Supreme Court decided the GMO bacteria qualified as a "new composition of matter" — one of the clauses describing a utility patent — because of the genetic modification. The genetically engineered bacteria was a living organism, but because of the modification to its DNA, it was no longer in a state of nature. 

This decision established human-made organisms as patentable, and just as importantly, patentable under the restrictive utility class. The restrictions of utility patents are why the genetic material is held privately — unavailable for public research — for the duration of the patent, and why farmers cannot save GMO seed.

Protecting GMOs with utility patents also reveals a kind of duplicity in the rhetoric of the chemical companies that create them: To investors and patent offices, companies emphasize the novelty and innovation of GMOs to secure funding and utility patents, while to regulatory boards and the general public, they argue the opposite, marketing GMOs as an extension of traditional breeding techniques. 

To one audience, they cry, "It's totally new!" 

To another, "It's totally natural!"

It's no wonder chemical companies face a skeptical public.

Privatization and monopoly in the food system

"The courts and the PTO [Patent and Trademark Office] have given a few large businesses the power to close down most independent research on basic food crops." Malla Pollack

For all the resources deployed to develop GMO crops and the fortunes made from marketing them, there are at this time a limited number of commercially available varieties owned by a handful of corporations. This small group casts a vast shadow across the agricultural land of North America — 90% of U.S. cropland is dedicated to just 3 commodity GMO crops (corn, cotton and soy). From there, GMO crops are processed and find their way into an estimated 80% of the conventional processed foods. This produces a very unbalanced kind of control of food and resources: 

This monopolization means that our food systems — and the ecosystems they rely upon — are based on a limited number of crops. The more reliant we are on that limited number of crops, the more our fates are tied to theirs. As the effectiveness of herbicide-tolerant and pest-resistant crops fail, it's well past time to diversify our food system portfolio. Monopolies do not foster innovation, and chemical corporations show no signs of loosening their grip.

Some of the most powerful corporations in the world routinely harass farmers, seed savers and breeders around the globe as they try to operate outside the monopolized and privatized seed supply. Harassment can come in the form of legal action, as has been extensively reported by the Center for Food Safety. There are also cases of casual intimidation, such as when a major corporation mailed baseless patent infringement notices to small seed companies across the U.S.; or in another instance when good faith efforts by small farmers to resolve GMO contamination risks were rebuffed by corporate lawyers

What you can do

Promoting seed sovereignty and biodiversity are essential to creating a truly resilient and healthy food system that works for everybody. There are many organizations — including the Non-GMO Project — working to restore farmers' rights. An obvious first step is to avoid GMOs by looking for the Butterfly — after all, we can choose how our food is made. Here are some additional resources:

For all our craftiness and innovation, it's worth remembering that the seeds didn't start with us, nor will they end with us. We hold them in our hands for a while. If we're truly lucky, we watch them grow.

Non-GMO Project Verified Cotton

We’re all familiar with cotton—this versatile crop is used to make a good portion of the clothing and other textiles most people use daily. However, these consumer goods represent only a small piece of cotton’s impact on our economic and environmental systems. Cotton is considered a high-risk crop under the Non-GMO Project Standard because GMO cotton is widely commercially available. About 94 percent of cotton grown in the United States has been genetically modified. This means any product containing or derived from cotton is subject to extra scrutiny when it goes through our Product Verification Program.

You may have noticed that there aren’t many Non-GMO Project Verified cotton goods such as clothing, linens, or bandages at this time. There are, however, many Verified products that contain animal-derived ingredients. Cotton is extremely prevalent in animal feed. When animals are fed GMO cotton, their meat, milk, and other products are not eligible for use in a Non-GMO Project Verified product. The Non-GMO Project Standard follows animal-derived products such as milk and meat all the way back to animal feed—it’s hard work to get animal-derived products verified. Most GMOs become either automobile fuel or animal feed, so feed material is an extremely meaningful leverage point in our shared food system. Besides, your diet isn’t just what you eat—it’s everything that goes into any animal-derived foods you eat, too.

Some animal feeds contain as much as 15 percent cottonseed content. Cottonseed and cottonseed meal both contain a high fat content and can be a protein source for animals. Cottonseed hulls can also end up in animal feed as roughage, but this material has little nutritional value. GMOs aside, animals cannot have too much cotton in their diet because cotton contains gossypol; this compound can be toxic to people and animals in sufficiently large quantities. The United States Department of Agriculture recently deregulated a new type of GMO cotton in which the gene responsible for producing gossypol has been switched off. In theory, this would make the resulting cottonseed meal safe for human consumption. This specific type of cotton is not yet commercially available, but most cotton is already genetically modified.

Genetically Modified Cotton is Everywhere

Some GMO cotton crops have been genetically modified so that they tolerate the direct application of chemical herbicides such as glyphosate. These herbicide-tolerant, or HT, crops allow farmers to douse their fields and pre-treat the ground rather than applying herbicides carefully to weeds. Glyphosate use has doubled fifteen times over since the introduction of this type of GMO became available in the mid-1990s.  

Other GMO cotton crops have been engineered with DNA from the naturally-occurring bacteria Bacillus thuringiensis (Bt). Bacillus thuringiensis can produce Cry proteins; specific types of these proteins are toxic to insects that possess the corresponding receptors to activate those proteins. Naturally produced Cry proteins are largely harmless to other organisms that do not possess these receptors. However, many people have concerns about the other ways Bt impacts the environment on a larger scale.

Read more: Three fascinating case studies on Bt crops

Pesticide Treadmill

Bt crops can be effective in the short term, but they lead to pest resistance over time. Just as bacteria can become resistant to drugs and medications, pest populations can become resistant to Bt crops over time. This type of resistance is a function of natural selection. Pests that are not killed by consuming Bt are more likely to live long enough to reproduce and make more Bt-resistant larvae. Some research suggests that Bt resistance is speeding up over time. Once touted as a miracle panacea and a solution to economic insecurity where cotton is grown, Bt crops around the world are failing to deliver on biotech’s promises to farmers.

Watch: Farmers in Burkina Faso share their experiences with Bt cotton

Pest resistance of any type presents a major concern because when one pesticide stops working, the typical solution is to use more pesticides. The pattern of requiring more and more pesticides to control a pest problem is called a pesticide treadmill, and it represents a significant problem in modern agriculture. We can’t outrun or outsmart evolution, but biotech companies keep trying!

Where is Cotton Grown?

China, India, and the United States grow the vast majority of the world’s cotton. In India, the system that produced Bt cotton has been increasingly connected to serious issues including bankruptcy and suicide among farmers. It is important to consider that approximately 65 percent of India’s cotton crop comes from farmers who rely on rainwater—irrigation is not available to everyone. Farmers in this region face socioeconomic pressures that are very different from what farmers in the United States or Canada face, and the royalty fees associated with patented GMO seeds can exacerbate these pressures. Research is showing that the more dependent Indian farmers are on rainfall, the more likely Bt cotton is to push them toward bankruptcy and the problems that go along with it.

Dr. Vandana Shiva puts it better than we ever could:

As a scientist, I have tried to understand what is driving our small farmers to suicide. Two things are evident. One, the suicides begin with the period of globalization which allowed MNCs [Multi-national corporations]  entry into India’s Seed Sector, making seeds a non-renewable “input”, to be bought every year.

Secondly, the suicides have further intensified after the introduction of GMO Bt cotton. GMOs are intrinsically linked to Intellectual Property Rights, which in turn are linked to royalty payments. Royalties are extracted from poor farmers through credit and debt...the shift to Bt cotton meant a jump of 8000 percent in the cost of seed. This is at the root of the farmers’ distress in the cotton areas of India.

The Non-GMO Project believes that we have the power to change the way our food is grown and made. We can choose not to support practices that privatize our food supply, hurt small farmers, and restrict the free flow of information. The non-GMO movement is about more than the right to know, it’s also about doing what’s right! If—like us—you find this type of GMO-based colonialism upsetting, you can refuse to buy into this system by opting out of GMO cotton. That doesn’t just mean avoiding GMO cotton textiles and home goods (choosing Organic is a great start), it means making sure the animals who produce any meat, eggs, or dairy you eat also avoid GMO feed.

We’ll leave you with Dr. Shiva’s words again:

GMOs are not a “thing,” they are a set of relationships, and it is the context created by these relationships that is driving farmers to suicide. GMOs are not a disembodied “technology” as so many pro-GMO commentators try to present. These commentators then proceed to protect this abstract construction of GMOs as disembodied technologies from the evidence of reality. In reality, what exists is a GMO complex, or nexus, that has an impact on real ecosystems and real farmers.

Read more from the Alliance for Food Security in Africa

This content was originally posted on 5/7/2019.

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