When we were getting the Project started, the thing that motivated me the most was the need to preserve non-GMO choices in the food supply, because they were disappearing. There weren't going to be any non-GMO choices if we didn’t do something.
— Megan Westgate, Non-GMO Project Executive Director
The Non-GMO Project Standard is the guiding document for our work protecting and building the non-GMO food supply. Every two years, the Standard is revised and strengthened to address the challenges of product verification in the changing landscape of biotechnology and modern supply chains. One of those challenges involves micro ingredients.
As the name implies, micro ingredients are ingredients present in a final product in minute amounts. Despite their size, micro ingredients can significantly impact the efficacy of the Product Verification Program — we'll unpack that in depth below. Provisions within the Standard for certain micro ingredient exemptions are critical to our work of preserving and building the non-GMO food supply.
The Standard is a strategic and evolving document, built to further the Non-GMO Project's mission by placing pressure on the most impactful parts of the supply chain: the genetically modified commodity crops that dominate agricultural production. The Standard's guidance on micro ingredients exemptions is similarly strategic. It makes the difference between a meaningful, achievable and scalable Non-GMO Project Standard and a food system in which GMOs have edged out the genetic diversity and resilience that makes up our natural inheritance.
Because of the outsize impacts of micro ingredients, these tiny players are worth a closer look. What are the challenges posed by micro ingredients, and how does the Standard address those challenges, moving us closer to a non-GMO future?
What goes into your food?
Generally speaking, how do the labeling and ingredient lists on individual food products relate to the big picture of the supply chain? Well, that big picture is massive. It encompasses on-farm production, preserving and processing aids and the dizzying world of food additives. The square footage of ingredient panels is miniscule by comparison. What goes into your food and what goes into your food's label isn't always the same. The difference between the two balances the consumer's need for concise information and the complexity of supply chains and commercial markets.
For example, the FDA allows some ingredients to be present at "incidental amounts" without being listed on the product packaging. Incidental additives are identified by the FDA as ingredients present at insignificant levels which don't have any effect in that food, such as food processing aids or some sub-ingredients. Or, under USDA Organic Certification, products may be labeled "Organic" if they contain at least 95% organic ingredients (there are restrictions regarding the remaining 5%). Each certification is unique, with specific allowances that strengthen the label's impact without undermining its primary goal.
One place this balance shows up in the Non-GMO Project Standard is in the guidance for micro ingredients. Micro ingredients can be any number of things: added colors, flavors, stabilizers, preservatives and texturizers, to name a few. They aren't determined by their effect, as in the FDA's incidental amount provision, or by market availability, as in the NOP's non-organic ingredient allowance. The constant feature of micro ingredients is the amount (by weight) that is present in the finished product.
Common micro ingredients include the added flavors made by specialized suppliers known as "flavor houses." Flavor houses are the czars of kitchen chemistry, creating unique compounds to make nacho cheese tortilla chips even nacho cheesier. These potent concoctions are micro ingredients because a little goes a very long way — the finished product will contain only a tiny amount.
Their diminutiveness presents unique challenges during verification.
How small is a micro ingredient?
To best serve our mission, the Non-GMO Project considers the GMO risk status of ingredients based on how common genetically modified versions of a crop are in the supply chain. Product ingredients are divided into categories based on weight: Major ingredients make up at least 5% of the finished product. Micro ingredients are at the other end of the spectrum, with each micro ingredient less than 0.5% of the finished product. Minor ingredients are everything in between.
Let's look at those nacho cheese tortilla chips to see how this plays out:
- The major ingredients in this kind of product would be corn and a cooking oil such as canola. More than 90% of the corn and canola grown in the U.S. is genetically modified, making the major ingredients in this product high risk for being genetically modified. For the finished product to wear the Butterfly, these ingredients would be tested and/or traced to their origin to prove their non-GMO status.
- The minor ingredients might include whey, cheese powder, onion powder, garlic powder, tomato powder and nonfat milk powder. Of these ingredients, the whey, cheese powder and milk powder would be high risk because they are animal-derived. For this product to be Verified, both the animals and their feed must be compliant with the Standard.
- The micro ingredients in these chips might include flavor enhancers such as citric acid, or added colors and flavors. Micro ingredients might be eligible for exemption from evaluation provided they meet certain criteria outlined in the Standard. The total volume by weight of all exempted micro ingredients cannot exceed 0.9% of the finished product.
Micro ingredient exemptions are included in the Standard because of the unique challenges of evaluating minuscule quantities of materials. The supply chain from which they emerge is murky at the shallow end and unfathomable in its depths. Brands that seek verification for their products do so in part to increase transparency in their supply chain. The investigative work they conduct helps to illuminate an otherwise opaque industry, but the process is not perfect. Dead ends can and do occur, and the Standard's provisions for micro ingredient exemptions refines the impact those dead ends have on consumer interests and on the GMO landscape as a whole.
For example, the exact formulation of added flavors is a secret tightly guarded by the flavor houses that supply them. Added flavors are the "11 herbs and spices" of tastebud wizardry that can make a product entirely unique. According to senior flavorist Kim Juelg, “It would be similar to a chef in a kitchen creating dinner for you and you want to take home that recipe to make a banana cream pie. That chef is not going to give you that recipe." This means a brand can come to the verification process with a formulation list for their product, but they may not know what goes into the tiniest ingredients they use.
To prevent the unnecessary exclusion of products from the Product Verification Program — which would lessen the non-GMO impact on the supply chain and compromise our goal of a non-GMO future — the Non-GMO Project Standard exempts some micro ingredients during the verification process. The total amount of exempted micro ingredients cannot make up more than 0.9% of the finished product. That means that less than 1% of the product you hold in your hands could have been micro-exempted — and that micro-exempted portion doesn't necessarily contain GMOs.
The three habits of highly effective certifications
We live in a messy, imperfect world. Stuff gets onto other stuff. Our food system is unsustainable and just plain broken. For a certification like the Butterfly to be an effective vehicle for change, it must be meaningful, achievable and scalable.
To be meaningful, it provides a service for the consumer while urging the system toward the shared goal of a non-GMO future. To be achievable, a high-quality standard acknowledges the realities of and works within the existing framework of the food system. To be scalable, the certification must be able to grow, meeting the needs of small and large brands while maintaining its integrity.
In order to serve the public interest and achieve our mission, the Non-GMO Project Standard puts pressure strategically on the most impactful parts of the food supply chain: the high-risk crops that make up the bulk of processed foods and animal feed. There are more than 175 million acres of land in the U.S. planted with GMOs crops*. The Non-GMO Project works continually to expand the market for Verified food and build a non-GMO supply chain.
Let's bring back our hypothetical nacho cheese tortilla chip to see how micro ingredient exemptions support this goal. The most prominent ingredient in tortilla chips is corn. Corn is one of the highest of the high risk crops — more than 90% of all corn grown in the U.S. is GMO. Unless a brand intentionally looks for non-GMO corn, they will probably purchase GMO corn from that 90%. For their tortilla chips to be Non-GMO Project Verified, they are required to source non-GMO corn. This helps build a market for non-GMO crops and preserve a non-GMO seed supply.
Without a micro ingredient exemption, what happens to that same product, and how does that reverberate through the supply chain?
Our hypothetical nacho cheese tortilla chip contained a few micro ingredients: a flavor enhancer made from citric acid as well as added colors, or added flavors purchased from a flavor house. The brand that makes the chips may not have access to the formulation of those flavors — that's a trade secret held by the flavor house and they aren't giving it up. Without the micro ingredient exemption, this product would be ineligible for Non-GMO Project verification, even if the micro ingredients don't contain GMOs. The uncertainty alone would make verification unattainable.
Without the possibility of verification, that brand would have no incentive to source non-GMO corn, an ingredient they'd buy by the truckload to make tortilla chips. Should the market for non-GMO corn continue to shrink, producers would be more likely to stay on the chemical treadmill of GMO commodity crops with all the negative impacts of increased pesticide application, biodiversity loss and declining soil health. Even farmers who were interested in organic production would face extra challenges without access to non-GMO markets during the 3-4 years of transition.
All because of the micro ingredients on a chip. That's the butterfly effect in action.
The Butterfly offers the most rigorous certification for GMO avoidance
In 2015, some U.S. states — including Vermont, Illinois and Arizona — passed regulations requiring the labelling of GMOs, regulations that included exemptions for micro ingredients. When those state laws were superseded by the federal DARK Act — which ultimately became the National Bioengineered Food Disclosure Standard (NBFDS) — Americans lost meaningful and actionable regulation in favor of an insufficient law that falls short of what they deserve.
The Non-GMO Project Standard is an evolving document that is revised every two years. During this time, industry experts and stakeholders review the latest trends in the field of biotechnology, regulation and the supply chain. They update guidance for the current version, and note emerging issues that appear on the horizon. The external landscape of GMOs is continually changing, and the Standard is continuously evolving to meet those changes.
With 175 million acres in the U.S. alone, as well as lab-based GMOs made with new techniques, it's a big task. But the desire of the public is clear: The vast majority of people want meaningful labeling on GMO food. We believe that everyone deserves access to non-GMO options, as well as transparent standards for the food they consume and serve their families. The Non-GMO Project Standard achieves this better than any other regulation.
USDA, ERS, Genetically engineered soybean, cotton, and corn seeds have become widely adopted, 2020.