The Non-GMO Project is North America's most rigorous certification for GMO avoidance. Our Standard requires ingredient tracing, segregation and testing of major ingredients that are high risk for being GMO.
Testing is essential for managing the risks posed by novel organisms, including potential environmental harm and economic impacts. Just as importantly, testing for the presence of GMOs supports your right to know how your food was made.
We believe everyone has the right to choose whether or not to consume GMOs.
Testing and documentation
To earn the Butterfly logo, verified products must comply with the Non-GMO Project Standard. The Standard requires testing of ingredients that are:
- Major ingredients (making up 5% or more of the finished product)
- Considered high-risk for being GMO
- Testable (tests for GMOs are commercially available)
However, not all GMOs have commercially available tests (we refer to these as "nontestable" ingredients). In the case of nontestable, high-risk major ingredients, the Standard requires comprehensive and legally-binding affidavits. We also work to expand testing capabilities for new GMOs.
"Making the invisible visible."
Some GMO developers claim that GMOs made through gene editing are the same as crops produced by traditional cross-breeding, except they are created more quickly. Thanks to emerging testing capabilities, we know that's not true. Nontestable GMOs are simply GMOs for which a test has not yet been developed — and the Non-GMO Project is working with a coalition of scientists, nonprofits and retailers to change that.
Here's one example of the coalition at work: In 2014, the first gene-edited crop, herbicide-tolerant SU canola, entered the market. Because gene-edited crops don't necessarily incorporate DNA from foreign organisms, the SU canola was nontestable when it was released. So the Non-GMO Project contributed funding toward the Health Research Institute's work developing a reliable test.
The resulting test — freely available to labs worldwide since 2020 — counteracts the narrative that gene editing produces "nature identical" crops. According to Health Research Institute chief scientist Dr. John Fagan, "the same method used to test for every GMO for the past 20 years can be used for gene-edited GMOs" if information about the changes made to the crop is available.
Our commitment to quality
In the meantime, the Project conducts quality assurance and surveillance testing of verified products to protect the integrity of the Butterfly. The quality assurance team goes incognito to purchase samples of Non-GMO Project Verified products from suppliers across North America and sends the products to accredited laboratories for testing. Surveillance testing helps us to monitor and address contamination issues or supply chain disruption.
The Non-GMO Project protects your right to choose in many ways, including testing, ingredient tracing, product surveillance and developing tests to identify new GMOs. The Butterfly is more than Verified products and the most rigorous certification in North America – it’s also a pathway toward a sustainable, non-GMO food supply for all.
At the Non-GMO Project, part of our goal is to help people better understand the GMO issue so they can make the best decisions for themselves. Through articles like this one, as well as infographics and videos, we educate the public about GMOs and where they might appear. That work often involves combatting common misconceptions.
Here's an example: One common misconception is that GMOs are necessary to feed a growing population. Contrary to biotechnology industry promises, a careful analysis of GMOs finds that they have not meaningfully increased crop yields or reduced global hunger. Or the misconception that new GMOs made with emerging techniques such as gene editing are not GMOs. Common gene editing techniques meet the definition of GMOs.
Under the Non-GMO Project Standard*, a GMO is a living organism to which biotechnology has been applied. We define biotechnology as in vitro nucleic acid techniques — the alteration of genetic material in a petri dish or test tube ("in vitro" means "in glass") — or combining genetic material from different organisms beyond natural reproductive barriers in ways that aren't used in traditional breeding. (You can find more information about what makes a GMO a GMO in our recent article, What Is a GMO?)
How do those misconceptions measure up against our definition of a GMO? In other words, what's not a GMO?
Traditional cross-breeding ≠ GMOs
Here's one myth we'd love to dismantle entirely and forever: The idea that after thousands of years of selective breeding by skilled farmers and indigenous experts, all our modern food crops are genetically modified. In other words, if human hands have played a role in changing an organism, that organism is a GMO.
This idea is categorically false.
GMOs aren't just the end product of change guided by human hands. GMOs are the result of biotechnology, and biotechnology consists of manipulating the genetic material of an organism in glass petri dishes or test tubes (in vitro) or combining genetic material from different organisms in ways that overcome natural reproductive barriers.
How does the claim that "all crops have undergone changes directed by human breeders, so they're all GMOs" measure up against the definition of GMOs? Let's see:
- Are new traits the result of in vitro nucleic acid techniques (altering the organism's DNA in a glass petri dish or test tube)? No.
- Do the new crops combine genetic material from different organisms using techniques different from those used in traditional breeding and selection? No.
Zero out of 2 criteria were met, meaning modern crops are not all GMOs just because humans selectively bred them.
For our next question: What about the mutants?
Mutants and watermelons
It's summertime. As the temperature rises, grocery stores offer big bins of heavy, sweet watermelons, with or without seeds. We frequently hear from people wondering if those seedless varieties are GMOs, and we're happy to set the record straight.
The short answer is no, seedless watermelons are not GMOs. The slightly longer answer is that seedless watermelons aren't GMOs because the process by which they are produced doesn't meet the Non-GMO Project's Standard's criteria for biotechnology.
Seedless watermelons are created through a process called "random mutagenesis." A young watermelon plant is exposed to a chemical compound to induce a genetic mutation in the plant. The mutation causes the plant to develop double the usual number of chromosomes. That plant is then cross-bred with a regular watermelon plant, resulting in a seedless melon. (You can find more information about mutagenesis in our article, Does Mutation Breeding Produce GMOs?)
How does that process of creating a seedless watermelon measure up against the definition of GMOs? Let's see:
- Were the changes made using in vitro nucleic acid techniques (altering the crop's DNA in a glass petri dish or test tube)? No, random mutagenesis is not an in vitro nucleic acid technique.
- Do seedless watermelons combine genetic material from different organisms overcoming natural reproductive barriers? No, the cross-breeding part of the process is between a watermelon and another watermelon.
Again, 0/2 criteria are met. Seedless watermelons are not GMOs.
For more examples of mistaken identity, read Exposing GMOs: Are You Being Fooled By Imposters?
If you have questions about a specific product or crop and want to know if it's a GMO, contact us at firstname.lastname@example.org. We're happy to walk you through the definition and see how a suspected GMO measures up.
*The Non-GMO Project Standard's definitions of GMOs and biotechnology are adapted from the Cartagena Protocol on Biosafety, an international treaty designed to protect biodiversity from potential risks of GMOs. It is consistent with definitions used by the UN's Food and Agriculture Organization and the European Union's GMO Legislation. By adhering to international standards for clarity and consistency/specificity, the Non-GMO Project upholds the highest standards for rigor, transparency and subject matter expertise.
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.
We are delighted to announce that Version 16 of the Non-GMO Project Standard has been officially released and can be found here — free of charge, at any time. We are tremendously proud of the hard work and expertise that has gone into v16, including the contributions of Project staff, professional stakeholders and industry experts from a diverse range of backgrounds. The common thread that unites the contributors is their shared commitment to a fair, just and sustainable non-GMO food system for all.
What is the Standard?
The Non-GMO Project Standard is the central guiding document for the Product Verification Program. It outlines the criteria each product must reach before it can wear the Butterfly seal. The Standard is also an evolving document, revised every two years by a committee of industry stakeholders with valuable insight into the food system. While new GMOs, testing methods and supply chains are developed, this Standard Committee works steadily to identify and adapt to the changing landscape. That means that you don't have to maintain an encyclopedic knowledge of GMOs on the market or in development — our team does that for you.
When you purchase a product that wears the Butterfly seal, you can be sure the product was thoroughly evaluated and is in compliance with North America's most trusted Standard for GMO avoidance.
Caterpillar to monarch: The evolution of the Standard
The Non-GMO Project Standard is developed through the collaboration between researchers, independent industry experts and Non-GMO Project Staff.
The Standard Revision process takes the better part of a calendar year to complete, beginning with an announcement and call for public comments. Anyone with a stake in how our food is grown and produced can submit a comment: We welcome input from producers of crops, seeds and livestock; retailers and manufacturers; as well as consumer advocates and independent researchers. After all, each of these groups holds unique insight into how GMOs affect their corner of the supply chain. While the formal term for these people is "stakeholder groups," that is an arms' length way of saying that anyone who is invested in the food system.
The Standard Committee reviews all of these comments, proposing changes to the Standard as necessary based on their areas of expertise and best thinking. The proposed changes and the reasoning behind them are then published on our website to ensure full transparency and public engagement with the process. This comment-analysis-evaluation process is repeated until a consensus is reached that the revised Standard reflects the best adaptations to concerns and developments in the field of genetic engineering.
Changes to the Standard might include:
- Crops that are added to or removed from the Monitored or High-Risk List.
- Changes to eligibility for Verification.
- Changes to reflect incoming labeling requirements, including the National Bioengineering Food Disclosure Standard (NBFDS).
View the Non-GMO Project Standard v16 Summary of Changes here
To support the transformation to a non-GMO future, requirements developed by the Standard Committee must be consistent, uniform, meaningful and achievable while adhering to international protocols for credible standard setting.
Ingredients for change: transparency, rigor and accountability
The Product Verification Program — which brings the Butterfly seal to food and personal care products on the shelves — operates on the principles of transparency, rigor and accountability.
The process of Standard revision occurs with full transparency to the public eye, through the solicitation and disclosure of public comments, the changes made to the Standard and the rationale behind those changes. The Standard Committee's collective expertise allows them to rigorously examine the supply chain from various vantage points.
Brands seeking verification for their products are held accountable through the work of independent, third-party technical administrators. In the coming weeks, we'll introduce you to the four technical administrators we work with, providing another level of transparency to the verification process. Reliable and independent technical administrators are the backbone of a rigorous certification system. They work to preserve the integrity of our most trusted clean food labels.
If you are concerned about our food system and looking to avoid GMOs, the Butterfly has you covered. You are invited to peruse the Standard for as much detail about product verification as you want: If you have a question or a comment, let us know and we'll work with you to get the answer. We believe that everyone has the right to decide whether or not to consume GMOs, so that you can make the best choices for yourself and your family. At the Non-GMO Project, our role is to make sure you have full confidence in what those choices mean — for people and the planet.
The Newest Non-GMO Project Standard is Out Now!
You already know that the Non-GMO Project is a nonprofit organization committed to preserving and building sources of non-GMO products, educating consumers, and providing verified non-GMO choices. We believe everyone has a right to know what is in their food and deserves access to non-GMO choices and we work hard to give families the power to change the way their food is grown and made just by making informed choices in the grocery store.
Efficient supply chain transformation requires consistent, uniform standards. That’s why we created our Product Verification Program and the Non-GMO Project Standard. The Standard sets the rules for what it means to be non-GMO and what it takes to get Non-GMO Project Verified. Every product is subject to the same set of rules and products must meet all of the compliance requirements laid out in this document in order to use our butterfly mark. These requirements center on three foundational ideas: testing, affidavits, and segregation.
Testing: Major, testable, high-risk inputs need to be tested in a lab before they can become part of a Non-GMO Project Verified product. These tests are usually quantitative. Not only can they tell whether there is GMO DNA in a sample, but these tests can also tell exactly how much contamination occurred.
Affidavits: There are some GMOs that laboratories can’t test for yet. When testing is not a feasible way to prove something is non-GMO, the Project uses a process-based approach that includes comprehensive affidavits as an alternate validation tool.
Segregation: Non-GMO inputs need to be kept completely separate from GMOs all the way through the supply chain in order to prevent commingling. This means food producers need to have systems in place for cleaning out equipment and keeping non-GMO inputs pristine.
Why Does the Non-GMO Project Standard Change?
The Non-GMO Project Standard is a living document. It changes biennially in order to remain current and address new threats to the supply chain. As new types of GMOs emerge, we update the Standard and its High-Risk List to make sure we are positioned to protect our food supply most effectively. For example, Version 15 tightens up rules for products that are derived from microorganisms such as yeast and bacteria. Genetically modified microorganisms are common, and new types of them are entering the food supply all the time. The Non-GMO Project Standard changes to stay ahead of emerging GMOs like these.
The Standard must be both meaningful and achievable in order to effectively build a non-GMO food supply. If it were too easy to get Verified, the supply chain wouldn’t be forced to change enough. If it were impossible to meet our Standard, then no products would get Verified and suppliers would have very little incentive to switch to non-GMO sources. Revising the Standard helps the Non-GMO Project make sure that this delicate balance is always achieved.
Regular updates also allow the Standard to be as collaborative as possible. We couldn’t have made North America’s most rigorous Standard for GMO avoidance in a vacuum—we needed input from farmers, food producers, legislators, brand partners, technical experts, and shoppers. You can help too! We always want to know what you think about the Non-GMO Project Standard. The more specific your feedback is, the more helpful it is. Submit a comment online any time.
The Same Butterfly You Know and Trust Just Got a Little Bit More Rigorous.
The Butterfly won’t look any different when you see it on your favorite products, but now you can rest assured that North America’s most trusted label for GMO avoidance is even better. The Non-GMO Project Standard is available online for free. You can read it in its entirety anytime you want! You can also check out the new Summary of Changes to find out what’s different this time around.
Have questions about the Non-GMO Project Standard? Post them in the comments!
The updated Non-GMO Project Standard offers North America’s most meaningful system for GMO avoidance
Contact: Hans Eisenbeis
Phone: 360-255-7704 x107
Bellingham, WA—July 26, 2019—The Non-GMO Project published the fifteenth version of the Non-GMO Project Standard today. The most rigorous standard of its kind, the Non-GMO Project Standard is a consensus-based document crafted with insight from dozens of industry experts, reflecting a dynamic range of perspectives. As new GMOs continue to enter the supply chain at an increased rate, the Non-GMO Project Standard remains current through a robust biennial revision process.
The Non-GMO Project Standard v15 was created with broad stakeholder input gathered across three public comment periods. Commenters submitted feedback on critical topics, notably including proposed changes to the compliance requirements for livestock and poultry feed rations as well as proposed changes to the testing and affidavit sections. Accordingly, Standard v15 includes updated requirements for feed rations, sampling and testing, affidavits, inputs derived from microorganisms, and overall product evaluations. Version 15 also features improved organization and numbering, making it the most accessible Standard yet.
“Maintaining a balance between meaningfulness and achievability is a complex process that requires input from a wide range of industry partners,” said Non-GMO Project Executive Director Megan Westgate. “The newest Standard includes improved specifications for affidavit pathways, which complement the comprehensive testing requirements.”
The board-appointed Standards Committee addressed all comments from stakeholders and proposed changes to the Standard. The Non-GMO Project then held two further open comment periods to allow for comments on proposed revisions. “The Non-GMO Project is fully committed to equity and transparency throughout the revision process,” Westgate said. “We want to ensure the Standard is as collaborative as possible.”
As products of new genetic engineering techniques begin to enter the supply chain, the Non-GMO Project will continue to update the Standard to efficiently preserve and build sources of non-GMO products. The updated Standard, Information about the Standard revision process, and an outline of changes from v14.3 to v15 can be found on the Non-GMO Project website.
ABOUT THE NON-GMO PROJECT
The Non-GMO Project is a nonprofit organization committed to preserving and building sources of non-GMO products, educating consumers, and providing verified non-GMO choices.