2025 General Standard Revision — Context and Impacts

Your participation helps shape the most trusted Standard for GMO avoidance. Explore the context and potential impacts of topics under consideration, then use the Public Comment Form to submit your comment.

Important questions and feedback opportunities

Questions 1, 2 & 3 Reviewing typically unevaluated Inputs for prohibited substances
Question 1 Implementation factors: What practical factors could shape how the proposed Affidavit for Inputs typically excluded from the scope of evaluation is implemented?

Question 2 Differences by Input type: How might practical considerations vary by Input type, such as Processing Aids, Compost, Growth Media, or certain animal feed materials, when applying the proposed Affidavit?

Question 3 Update frequency and scope: Which implementation approach would be most effective for operationalizing the proposed Affidavit? Please rank the following options in order of importance, with 1 being the most important and 5 being the least important. If “I choose not to answer” is ranked as 1, the question will remain unanswered.

• I choose not to answer
• Update annually, Product level (one Affidavit per Product, renewed each year)
• Update annually, Portfolio level (one Affidavit covering all Products, renewed each year)
• Update at each Ingredient change, Product level (one Affidavit per Product, resubmitted when a formulation changes)
• Update at each Ingredient change, Portfolio level (one Affidavit covering all Products, resubmitted when a formulation changes)
Background and feedback from the first public comment period

This topic builds on Question 1 from the First Public Comment Period. The Project asked whether certain Inputs currently excluded from the scope of evaluation should undergo a limited check for prohibited substances. Under the current Standard, these Inputs may be used without such confirmation. Below, “excluded from the scope of evaluation” is shortened to “excluded from scope.”

Commenters expressed a mix of support and concern. Some supported stronger protections and greater transparency to ensure prohibited substances are not used, even indirectly. Others raised concerns about feasibility, citing limited visibility into upstream Inputs, confidentiality barriers, and the risk of repeating past challenges with Processing Aids and Micro Ingredients where it can be difficult to access detailed information, and time spent tracking small Inputs may detract from higher-priority evaluation work. Several emphasized that current Technical Administrator forms already collect declarations about prohibited substances and should remain the primary compliance tool. A few commenters requested clearer definitions and guidance for any limited evaluation. One commenter recommended eliminating all Micro Ingredient Exemptions. Most cautioned against introducing new burdens that could affect existing verifications.

What is proposed now

Redline Draft 2 introduces a light-touch requirement meant to support program integrity without drastically increasing burden. The proposal adds the following safeguard:

• Affidavit for excluded Inputs used upstream: When an Input that is excluded from scope is used to make another Ingredient or Input that is evaluated, the Participant provides an Affidavit confirming that no prohibited substances were used.
• No sourcing requirement or expanded review: These Inputs stay excluded from full sourcing or documentation requirements and do not become “in scope” under the Standard.
• Affidavit content is clearly defined: The Affidavit must state that no prohibited substances were used on purpose, and that the signer made reasonable efforts, such as due diligence, working with trusted suppliers, and accepting reasonable claims, to prevent their use.
What this would change

• Affidavit required in some cases: Inputs excluded from scope, including Processing Aids, certain Growth Media, fully composted materials, purified carbon dioxide, and Minor or Micro Inputs to livestock or poultry Rations, would require an Affidavit only when used to manufacture an Input or Ingredient that is currently evaluated under the Standard.
• Affidavit may be completed by an authorized entity: While submitted by the Participant, the Affidavit may be filled out by a contract processor or other party authorized to act on the Participant’s behalf during verification.
• Use would be clearly defined: Instructions would explain when the Affidavit is required, what it must include, and how often it must be renewed.
What this wouldn’t change

• No Non-GMO sourcing required for excluded Inputs: This update would not require Inputs excluded from the scope to meet Non-GMO sourcing requirements.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, Crop or Seed Producers, Livestock or Poultry Producers, Distributors, and Retailers may be affected, particularly those with Products evaluated under the Product Verification Program.
• Ingredient and Product considerations: Ingredients manufactured using Inputs excluded from scope, such as Processing Aids, certain Growth Media, mushroom cultivation substrates, Minor and Micro Inputs to Rations, purified carbon dioxide, and fully composted materials.
References
• Redline Draft 2 Sections 2.2.3, 2.2.4, 7.7

Question 4 Clarifying prohibitions on human and animal Biological Compounds
Question: Is sufficient information typically accessible to determine when an Ingredient such as collagen, ovalbumin, or lactoferrin must be sourced from a Non-GM animal, rather than produced using Biotechnology or cell-free systems? If challenges exist in identifying or sourcing compliant Ingredients, please explain.

Background and feedback from the first public comment period

This topic builds on Questions 2 and 3 from the First Public Comment Period. In Redline Draft 1, the Project proposed using the term “heterologous expression” to clarify that substances made by humans, but produced in other organisms using human genetic material, are not allowed under the Standard. This was meant to help people better understand an existing requirement about synthetic biology.

The Project also asked whether this type of prohibition should apply more broadly. For example, should it include compounds like vanillin or dairy proteins that are made using Biotechnology to copy the structure or function of Ingredients that come from orchids or cows?

Most commenters supported the change related to human-derived compounds. Some said it would help to include examples, like human milk sugars or human-identical collagen. Others said the term “heterologous expression” was too hard to understand.

What is proposed now

After reviewing feedback and doing more research, the Project chose to focus this update on compounds that come from animals, including humans. Redline Draft 2 includes several updates based on public input:

• Simpler language: The term “heterologous expression” has been removed and replaced with more familiar terms already used in the Standard, such as Biotechnology.
• New methods now included: The update now clearly includes cell-free systems. These are production methods that use parts of cells, such as Enzymes or ribosomes, to make compounds outside of living organisms. Without this clarification, these systems and their outputs might have been incorrectly treated as Processing Aids or Non-Risk under the Standard.
• Clearer requirements about what is allowed: Ingredients that normally come from animals must come from Non-GMO animals. Even if a substance looks or acts like the original, it is not allowed if made using Biotechnology or cell-free systems.
• New definition added: A definition for Biological Compound has been added to Appendix A to support clear and consistent classification.
• Examples not included: While examples were requested, they are not included in the Standard itself. This avoids confusion if supply chains change or if people think the examples cover every possible case.
These updates are meant to help stakeholders understand what is allowed and apply the requirements more clearly.

What this would change

• No substitution with GM alternatives: Biological Compounds like proteins, sugars, and fats that have traditionally come from animals, such as collagen, ovalbumin, or lactoferrin, would need to continue being sourced from Non-GMO animals.
• Prohibited if made using Biotechnology: These compounds would not be allowed if produced using Biotechnology or cell-free systems, including through GM Microorganisms.
• Proof of process required: Participants would need access to information about how a compound was made to confirm compliance with the Standard.
What this wouldn't change

• No change to existing sourcing requirements: This update would not change the requirement that Ingredients from animals must come from Non-GMO animal sources.
• No impact on Enzymes: It would not affect when or how Enzymes can qualify for Micro Ingredient Exemption.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, and Research and Policy may be affected, particularly those manufacturing or sourcing Ingredients that are traditionally derived from animals.
• Ingredient and Product considerations: Products that include animal-derived Ingredients such as dairy proteins, collagen, or gelatin; Products where the source and method of production may be unclear or where substitutes made using Biotechnology or cell-free systems could be introduced unintentionally.
References

• Redline Draft 2 Section 2.2.1.e
• Redline Draft 2 Appendix A – Terms and Definitions: Biological Compound

Question 5 Reviewing Enzymes and Microorganisms Named in Text on the Principal Display Panel
Question: What kinds of packaging or label formats could create uncertainty about whether an Ingredient is intentionally Named in Text on the Principal Display Panel?

Background and feedback from the first public comment period

This topic continues from Question 4 in the First Public Comment Period. Redline Draft 1 proposed removing Micro Ingredient Exemption eligibility for Enzymes that are both listed on the Ingredient Panel and Named in Text on the Principal Display Panel (PDP). The PDP is the part of the package most visible to consumers, usually the front label where the Product name and key marketing claims appear.

Commenters expressed a range of perspectives. Some supported the idea of requiring Non-GMO sourcing for Enzymes promoted in marketing text. Others requested clarification that Enzymes listed on the Ingredient Panel but not named on the PDP would remain eligible for Micro Ingredient Exemption. Several raised concerns about small packaging formats where the PDP and Ingredient Panel appear on the same surface, noting that such designs might trigger ineligibility even when the Enzyme is not emphasized. Commenters also flagged differences in labeling laws across jurisdictions and potential impacts on existing Verified Products. One commenter recommended eliminating Micro Ingredient Exemptions altogether and adopting a zero-tolerance policy for trace Inputs and Ingredients.

What is proposed now

Redline Draft 2 builds on the original proposal by expanding the scope to include Microorganisms in addition to Enzymes. The update focuses on how Ingredients are presented to consumers rather than whether they are Functional or Viable in the final Product:

• Microorganisms now included in the labeling requirement: Although Microorganisms were not addressed in public comments, Redline Draft 2 applies the same Named in Text requirement to both Enzymes and Microorganisms to ensure consistency when Micro Ingredients are promoted in consumer-facing text.
• Presentation, not function, determines eligibility: The proposed change is not based on whether the Ingredient is active or Functional. It focuses on labeling, specifically, when an Ingredient is listed on the Ingredient Panel and also Named in Text on the PDP.
• Data shows minimal disruption: The Project reviewed existing verification records and found no evidence that the proposed change would negatively impact currently Verified Products.
• Same requirement for both groups: Under Redline Draft 2, both Enzymes and Microorganisms would need to be sourced Non-GMO if they appear on the Ingredient Panel and are also Named in Text on the PDP.
What this would change

If adopted, the proposal would limit the use of Micro Ingredient Exemptions when Enzymes or Microorganisms are promoted in consumer-facing text:

Enzymes
• Enzymes Named in Text would no longer qualify: Enzymes that are listed on the Ingredient Panel and also Named in Text on the PDP would newly require Non-GMO sourcing, even if they are non-Functional.
• Existing requirements would still apply in all other cases: Enzymes not Named in Text on the PDP would remain eligible for Micro Ingredient Exemption. They would require sourcing based on whether they are Functional and whether they are listed on the Ingredient Panel, in line with existing requirements.
Microorganisms

• Labeling would affect eligibility for non-Viable Microorganisms: Non-Viable Microorganisms that are both listed on the Ingredient Panel and Named in Text on the PDP would newly require Non-GMO sourcing and would no longer qualify for Micro Ingredient Exemption.
• No change for Viable Microorganisms: Viable Microorganisms already require Non-GMO sourcing and would not be affected by this update
What this wouldn’t change

• No change to broader Micro Ingredient Exemption eligibility: The update would not remove Micro Ingredient Exemption eligibility for all Enzymes or Microorganisms, only those that are both listed on the Ingredient Panel and Named in Text on the PDP.
• No impact on Products without Named in Text labeling: Products that include Enzymes or Microorganisms but do not name them in marketing text would continue to be evaluated under existing Micro Ingredient Exemption criteria.
• No change to treatment of flavors: Artificial and natural flavors would not be subject to the Named in Text requirement. They would remain exempt from this provision, consistent with existing requirements.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, Distributors, and Retailers may be affected, particularly those responsible for sourcing or labeling Products that include Enzymes or Microorganisms.
• Ingredient and Product considerations: Products that contain Enzymes or Microorganisms Named in Text on the PDP (the part of the package most visible to consumers, usually the front label); Products sold in small packaging formats where the Ingredient Panel and PDP appear on the same surface.
References

• v16.1 Sections 3.1.3.a.v, 10.2.4, 10.2.5
• Redline Draft 2 Sections 3.1.3.a.v, 10.2.4, 10.2.5

Questions 6, 7 & 8 Verified Ingredients: Chain of Custody Requirements and Minor and Micro Compliance
Question 6 Chain of Custody requirements: What should be required to ensure Chain of Custody for Verified Ingredients used in Products?

Question 7 Risk-based Chain of Custody requirements: What should be considered when determining whether Chain of Custody requirements should differ for Verified Ingredients classified as Low Risk versus High Risk?

Question 8 Minor and Micro compliance: What would make a Certificate of Compliance valuable for Ingredients that are typically used at Minor or Micro levels in a Product?

Background and feedback from the first public comment period

This topic builds on Question 6 from the First Public Comment Period, which asked about the value, accessibility, and use of Verified Ingredients. In Redline Draft 1, the Project proposed reclassifying “Verified” as a compliance pathway rather than a Risk Status. The goal was to reduce unnecessary documentation when an Ingredient has already been evaluated earlier in the supply chain. Redline Draft 2 retains this reframing.

Commenters expressed a mix of support, concern, and requests for clarification. Some affirmed the importance of Verified Ingredients and offered appreciation for the role they play in protecting the integrity of Verified Products. Others questioned whether sourcing Verified Ingredients provides meaningful benefit for Low- and Non-Risk Inputs, especially if it increases documentation or Chain of Custody expectations.

Several commenters described variation in how Verified Ingredients are assessed in different verification contexts, particularly when used in compound blends. Some noted that additional documentation requests in certain cases may discourage the use of Verified Ingredients. Recommendations included aligning expectations to support broader use and reduce administrative burden.

A few commenters asked whether food safety certifications, such as FSMA-compliant or GFSI-benchmarked audits, could reduce the need for additional inspections under the Standard. Some also shared challenges accessing Certificates of Verification (COVs), especially when not purchasing directly from the Verified Ingredient’s manufacturer.

What input is requested now

Redline Draft 2 does not introduce new redline language related to Verified Ingredients, but the Project invites focused stakeholder input on several areas:

• Chain of Custody expectations: What documentation, systems, or other measures should be required to ensure that a Verified Ingredient remains properly sourced, handled, and transferred as it moves through the supply chain.
• Risk-based Chain of Custody: Whether Chain of Custody requirements should vary depending on whether a Verified Ingredient is classified as High Risk or Low Risk.
• Minor and Micro Ingredients: Whether a Certificate of Compliance could help demonstrate conformance for Ingredients typically used at Minor or Micro levels without requiring full verification.
What is currently reflected in Redline Draft 2

Redline Draft 2 does not introduce new language for Verified Ingredients, but the proposals from Redline Draft 1 remain under review:

• "Verified" status reframed as a compliance pathway: Table 3-2 retains the proposed reframing of Verified as a compliance pathway rather than a Risk Status. This approach is intended to reduce documentation requirements when an Ingredient has already been evaluated earlier in the supply chain. Stakeholder feedback will inform how the requirements in this table evolve.
• Inspection requirement under consideration: Section 5.1.2 retains a proposed requirement for annual inspections at facilities where the final Product is made, packaged, or labeled for sale. This includes locations where Inputs and Ingredients are combined to create the finished Product or where bulk Product is prepared for final sale.
  

  Under the proposal, these facilities would be subject to inspection if they handle Verified Ingredients that consist of a single Ingredient derived from a High-Risk crop. The goal is to reduce the risk of commingling in environments where both Verified and conventional versions of the same Ingredient may be processed.

  For example, if a facility receives both Verified and conventional cornstarch, this would not trigger an inspection under v16.1. Under the proposed update in Section 5.1.2, the facility would require an inspection even though the cornstarch is Verified, because the risk of commingling at the facility level remains.
The Project is continuing to evaluate whether this approach appropriately balances oversight and feasibility.

What this wouldn't change

• No automatic recognition of food safety audits: The proposal would not recognize third-party food safety certifications as substitutes for requirements under the Standard.
• No finalized requirements for Verified Ingredients: The requirements for Verified Ingredients are still under review and may evolve based on stakeholder feedback during this comment period.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, Crop or Seed Producers, Livestock or Poultry Producers, Distributors, and Retailers may be affected, particularly those that use or supply Verified Ingredients or manage sourcing and handling at the facility level.
• Ingredient and Product considerations: Products that include Verified Ingredients derived from High-Risk crops; Products manufactured at the same facility where conventional versions of those Ingredients are also handled (such as facilities where Products are produced, packaged, or labeled for final sale).
References

• Redline Draft 2 Table 3-2
• Redline Draft 2 Sections 4.1, 5.1, 10.1.2

Question 9 Definitions: Input and Ingredient
Question: In what ways might the phrase “at any point in the supply chain” improve or complicate how the Standard is understood or applied?

Background

This is a new proposal introduced in Redline Draft 2. It was not part of the First Public Comment Period. Earlier versions of the Standard defined Input and Ingredient, but the relationship between these terms and Product was not fully clear. Some sections used alternative terms for Product inconsistently, which led to confusion about how Inputs and Ingredients relate to the unit of verification.

What is proposed now

Redline Draft 2 updates the definitions of Input and Ingredient in Appendix A to clarify their relationship to Product and align terminology across the Standard:

• Input: Any material used in the production of a Product at any point in the supply chain.
• Ingredient: An Input that becomes part of a Product during its creation and is present in the final Product in either its original or altered form.Update annually, Product level (one Affidavit per Product, renewed each year)
These definitions reinforce the Product as the unit of verification and clarify the hierarchy between Inputs and Ingredients.

What this would change

• Clear hierarchy: It would clarify that all Ingredients are Inputs, but not all Inputs are Ingredients.
• Consistent structure: It would reinforce the Product → Ingredient → Input structure already used in the Standard.
• Explicit upstream scope: It would confirm that the Input definition includes materials used earlier in production.
What this wouldn't change

• No change to evaluation scope: It would not expand or reduce the scope of evaluation.
• No new compliance requirements: It would not introduce any new documentation or sourcing expectations.
• No change to verification decisions: It would not alter how eligibility or risk classification decisions are made.
Who may be affected

• Stakeholder categories: None anticipated.
• Ingredient and Product considerations: This proposal would clarify terminology and structure only. It would not change evaluation scope, documentation requirements, or verification eligibility.
References

• v16.1 Appendix A – Terms and Definitions: Ingredient, Input
• Redline Draft 2 Appendix A – Terms and Definitions: Ingredient, Input

Other proposed changes

Clarifying treatment of controlled and illegal substances

Current state

Under Version 16.1 of the Standard, controlled and illegal substances are grouped together with other prohibited Inputs and Ingredients in a single section (Section 2.1.2.a). This section names only U.S. and Canadian law. While it makes clear that Products containing controlled or illegal substances are not eligible for verification, the bundled language can reduce clarity about what is included and why.

What is proposed now

Redline Draft 2 introduces revisions intended to improve clarity and support consistent application:

• Separate clauses for clarity: Redline Draft 2 splits the current language into two clauses, one covering controlled and illegal substances, and one covering other prohibited Inputs and Ingredients.
• Prohibition repeated for Inputs and Ingredients: The same prohibition appears in Section 2.2.1.a to ensure that it applies both to Product eligibility and to the use of Inputs and Ingredients during production.
• Reflects broader legal expectations: The updated language no longer refers only to U.S. and Canadian law. It reinforces that Participants are expected to follow applicable laws in all jurisdictions where a Product is made or sold, such as Mexico and other markets.
• Clarifies treatment of substances with unclear legal status: The change also helps address Inputs and Ingredients that may be under legal review or fall into gray areas, such as kratom, cannabidiol (CBD), or Delta-8 THC.
What this would change

• Clearer language, same outcome: Products and Ingredients that contain controlled or illegal substances would remain ineligible for verification. The proposed revisions make this ineligibility easier to identify earlier in the review process.
• Applies to substances under legal review: The updated language would also apply to Inputs and Ingredients that are being reviewed for legality or fall into regulatory gray areas.
What this wouldn't change

• No change to existing obligations: The proposal does not introduce new compliance burdens. All Participants are already required to comply with applicable laws under the License Agreement and Program Rules and Procedures.
• No change to legal Inputs: It would not restrict the use of Inputs or Ingredients that are currently legal and eligible under the Standard.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, Distributors, and Retailers may be affected, especially those working in categories where substances with uncertain legal status are more common.
• Ingredient and Product considerations: Products that include Inputs or Ingredients with unclear or evolving legal status, such as kratom, cannabidiol (CBD), or Delta-8 THC, are already considered prohibited under the Standard. This update would clarify that status earlier in the evaluation process.
References

• v16.1 Section 2.1.2.a
• Redline Draft 2 Sections 2.1.2.a, 2.1.2.b, and 2.2.1.a

Streamlining the Risk Status Framework: Removal of Monitored Risk
Current state

Version 16.1 of the Standard recognizes five Risk Statuses, including Monitored Risk. This category was originally created to flag organisms where GMO counterparts were thought to be emerging, not yet widely available, or sometimes associated with contamination. In practice, Monitored Risk has the same compliance requirements as Low Risk, which means it no longer provides a distinct compliance function. Since animals and Microorganisms are already addressed under High Risk, only crops remain eligible for Monitored Risk.

What is proposed now

Redline Draft 2 introduces a change intended to simplify the Risk Status framework and improve clarity:

• Monitored Risk removed throughout the Standard: Redline Draft 2 removes Monitored as a Risk Status and strikes all related references, including Appendix C. This change eliminates a category that no longer provides unique compliance value.
What this would change

• Crops reclassified: All crops previously listed as Monitored are reclassified as Low Risk, except for sugarcane, which is proposed as High Risk.
• Transition to a dynamic external resource: Instead, the Project intends to develop a new, interactive, publicly available resource for tracking GMO developments in crops contextualized within their common usage and regulatory status.
What this wouldn't change

• No new obligations: This update would not introduce new compliance obligations for crops reclassified as Low Risk
• No change to current requirements: It would not alter requirements for any current Inputs or Ingredients.
• No reduction in GMO tracking: It would not reduce the Project’s ability to identify or monitor emerging GMOs. Instead, it shifts the function of Monitored from a compliance category within the Standard to an informational tool available outside of it.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, Distributors, and Retailers may be indirectly affected, primarily through internal documentation and terminology updates.
• Ingredient and Product considerations: Products containing Ingredients previously classified as Monitored Risk; supply chains that reference Risk Status terminology in verification systems, specifications, or communications.
References

• v16.1 Table 3-2: Monitored Risk
• Appendix C – Monitored-Risk List
• Redline Draft 2 – Proposal to remove Monitored Risk throughout

Clarifying evaluation of mushroom cultivation substrates
Background and feedback from the first public comment period

This topic was raised during the First Public Comment Period. While mushrooms are already treated as Inputs and Ingredients under the Standard, commenters said it was unclear how their cultivation substrates should be handled. Substrates are the materials used to grow mushrooms, often composted plant matter, wood chips, or straw, that provide the nutrients mushrooms need to develop. Some stakeholders said the lack of clarity about how these substrates are treated had led to unexpected documentation requests or supply chain disruptions. These comments highlighted the need for clearer information on when and how substrates are evaluated.

What is proposed now

Redline Draft 2 proposes a new section (Section 9.4) to clarify how mushrooms and their substrates are treated under the Standard:

• When mushrooms are used as Major or Minor Ingredients: Their substrates are evaluated if the mushrooms make up 0.5% or more of the Product.
• Composted substrate exclusions: If the substrate is composted, it may be excluded under existing Compost provisions.
• When mushrooms are used as Micro Ingredients: If mushrooms make up less than 0.5% of the Product, their substrate is excluded from the scope of evaluation, even if it was not composted.
What this would change

• Clearer evaluation criteria: The update would explain when mushroom substrates are included in evaluation.
• Aligned treatment with Compost: Composted substrates would be treated the same as in other parts of the Standard
• Composting as transformation: Composting would count as a process that removes the substrate from evaluation.
• Consistent by Ingredient level: The update would apply a clear approach based on whether mushrooms are Major, Minor, or Micro Ingredients.
What this wouldn’t change

• No change to broader Micro Ingredient Exemption eligibility: The update would not remove Micro Ingredient Exemption eligibility for all Enzymes or Microorganisms, only those that are both listed on the Ingredient Panel and Named in Text on the PDP.
• No impact on Products without Named in Text labeling: Products that include Enzymes or Microorganisms but do not name them in marketing text would continue to be evaluated under existing Micro Ingredient Exemption criteria.
• No change to treatment of flavors: Artificial and natural flavors would not be subject to the Named in Text requirement. They would remain exempt from this provision, consistent with existing requirements.
What this wouldn’t change
• No change to mushroom classification: Mushrooms would still be treated as Inputs or Ingredients.
• No change to Compost requirements: The update would not expand how Compost is evaluated.
Who may be affected
• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, and Crop Producers may be affected, especially those that source or handle mushrooms at different Ingredient levels.
• Ingredient and Product considerations: Products that include mushrooms as Major or Minor Ingredients, where substrate documentation may be needed; Products using mushrooms at Micro levels, where substrate evaluation is excluded.
References
• v16.1 Section 2.2.2.c
• Redline Draft 2 Sections 2.2.2.b, 2.2.3.c, 9.4

Assessing the risk of GM cane sugar in the Non-GMO supply chain
Background and feedback from the first public comment period

This topic builds on Question 8 from the First Public Comment Period. Redline Draft 1 proposed adding sugarcane to the High-Risk List. This is due to the emergence of a Genetically Modified counterpart and concerns about potential commingling. Redline Draft 2 retains this proposal.

Most commenters supported the proposed change. They cited data from Brazil showing the expansion of GM sugarcane cultivation. They emphasized that documentation is especially important for cane sugar, which cannot be tested in its refined form. Four commenters opposed a universal classification. They asked the Project to apply the High-Risk designation only to sugarcane grown in countries where GM cultivation is known to occur. Two supporters of the proposal also recommended reducing the frequency of required documentation updates, such as Affidavits. This is due to the scale of sugarcane use across supply chains.

What is proposed now

Redline Draft 2 retains the proposal from Redline Draft 1 to classify sugarcane as High Risk. This reflects its status as a crop with a commercially available GM counterpart. It also reflects a growing presence in the global supply chain. No changes have been made since Redline Draft 1 in response to public comment.

What this would change

• All sugarcane and cane sugar derivatives would be treated as High Risk under the Standard: To confirm Non-GMO sourcing, annual Non-Testable Affidavits would be required unless compliance is demonstrated through the Country of Origin documentation pathway.
• Consistent treatment with other High-Risk crops: This approach mirrors the treatment of other widely traded High-Risk crops, such as corn and soy, where commingling is a known concern
• Documentation requirements would expand: While this would expand documentation requirements for some stakeholders, particularly those working with many sugarcane-containing Ingredients, the Project considers these Affidavits to be a meaningful and necessary compliance tool, especially when testing is not permitted.
What this wouldn't change

• No geographic exemptions: The update would not exempt sugarcane based on where it was grown.The High-Risk List applies globally. The Standard allows alternatives to testing and Non-Testable Affidavits in some cases when crops come from countries that don't cultivate the GM version of that specific crop.
• No change to update frequency: The update would not reduce how often Affidavits must be updated. Annual documentation remains a requirement for Non-Testable High-Risk crops.
• No testing requirements for refined sugar: The update would not require testing of refined sugar, which is not permitted under the Standard.
Who may be affected

• Stakeholder categories: Brand Owners, Contract Processors, Processors/Mills, Distributors, and Retailers may be affected, particularly those sourcing, formulating, or selling Products that contain cane sugar.
• Ingredient and Product considerations: Products that include cane sugar as an Ingredient in any amount; facilities that handle cane sugar alongside other Ingredients and require Parallel Processing controls; supply chains using cane sugar in Inputs such as Growth Media or other indirect materials.
References

• v16.1 Section 7.4 and Appendix B.1.1
• Redline Draft 2 Appendix B.1.1

Proposals retained from Redline Draft 1

The table below highlights proposals first introduced in Redline Draft 1 that are still under consideration in Redline Draft 2. These proposals have not changed substantially, though minor edits were made for clarity and consistency. For background on earlier proposals, see resources from the First Public Comment Period.

Table showing proposals from Redline Draft 1 that are unchanged in Redline Draft 2, with summaries of each update and current status.

Topic	Summary of Proposed Update	Status
Clarifying the use of "shall" instead of "must" in the Standard	Replace “must” with “shall” throughout for consistency and alignment with other standards	Retained without change; editorial refinements only
Probiotics – Refinement of terminology	Added definition of “Probiotics,” removed future review note, and clarified “Product” language	Retained without change; editorial refinements only
Vitamins and supplements – Removal of language on future exemption review	Removed note about revisiting exemption in future Standard revisions	Retained without change; editorial refinements only
Clarifying the definitions of Testable and Non-Testable	Clarified definitions in Appendix A to better align with real-world testing practices	Retained without change
Clarifying the inspection exemption for contract processors	Removed reference to reconsidering the exemption in future; exemption remains in place	Retained without change
Clarifying the use of "Product" in relation to Ingredients and Inputs	Removed redundant mentions of “Product” in compliance contexts	Retained without change
Revising compliance structure - Separating Product and Participant requirements	Moved Participant compliance requirements from Standard to Program Rules and Procedures	Retained without change

Summary of other feedback from the First Public Comment Period

Strengthening access to Certificates of Verification
Summary

In Question 5 of the First Public Comment Period, the Project asked stakeholders to rank three ideas for improving access to Certificates of Verification (COVs). A COV is an official document that confirms a Product has been evaluated and meets the requirements of the Product Verification Program (PVP). It is renewed each year and includes agreements with the Project and, if applicable, a Technical Administrator.
The proposed improvements were: extending how long a COV remains valid, setting up automated digital access, and allowing Participants to request COVs directly from the Project. Structured rankings were submitted by stakeholders from different groups.

Key Themes

All three proposed improvements, extending COV validity, enabling automated access, and allowing Participant-initiated requests, were identified as priorities by different stakeholder types. Preferences varied, with Brand Owners favoring extended validity, certification bodies emphasizing digital access, and some stakeholders highlighting the need for more direct request options. This range of preferences reflects the different roles and needs within the PVP.

Outcome

No Standard change is proposed at this time. Feedback was reviewed and shared with relevant internal teams for continued operational improvement. No further action is planned within the scope of the Standard revision.


Assessing Chain of Custody requirements
Summary

In Question 9 of the First Public Comment Period, the Project asked how Chain of Custody (CoC) requirements could be enhanced, refined, or streamlined. CoC refers to the documentation and systems that help track how Inputs and Ingredients are handled as they move through the supply chain, ensuring traceability and preventing mixing with non-compliant materials. Stakeholders shared ideas for improving clarity, reducing redundancy, and supporting more consistent practices.

Key Themes

Recognition of third-party certification systems: Some commenters recommended that third-party certifications, such as Organic or food safety certifications, be accepted as evidence of CoC compliance. This could help reduce duplicate documentation while maintaining segregation and traceability standards.

Clarified scope of CoC requirements: One commenter asked the Project to confirm that CoC requirements apply to both finished Product facilities and Ingredient manufacturers, especially if “Verified” is treated as a compliance pathway.

Improved consistency across verification contexts: Commenters recommended developing tools such as SOP templates, checklists, or standardized guidance to reduce documentation burden and support more consistent expectations throughout the verification process.

Exploration of digital solutions: One commenter suggested operational improvements like e-signatures or electronic documentation to streamline internal processes.

Outcome

No Standard change is proposed at this time. Feedback has been reviewed and shared with internal teams for further exploration.

General Comments
Summary

Several commenters shared general feedback that did not respond to a specific question in the First Public Comment Period. These comments covered a wide range of topics, including requests for greater clarity in the Standard, improvements to verification processes, and broader access to Verified Products. While not all suggestions can be addressed through the current revision, the feedback highlights areas for future research and consideration.

Key Themes

mRNA technology and Biotechnology clarity: Some commenters recommended that the Standard explicitly prohibit mRNA-derived Inputs and Ingredients, citing health concerns, misalignment with Organic standards, and the need for clear alternatives. While mRNA is already considered Biotechnology under v16.1, commenters requested stronger clarity and enforcement.

Expanded access and inclusion: Commenters urged the Project to improve accessibility for underserved populations and culturally specific food systems. Suggestions included supporting verification of wild fish, sheep cheese, and making the program more affordable for low-income consumers and people in institutional settings.

Process clarity and burden reduction: Feedback described documentation challenges with Inputs like Certified Organic materials and Compost for mushroom cultivation substrates. Commenters also raised concerns about renewal timelines and inconsistent documentation expectations. Suggested improvements included standardizing practices, clarifying requirements, and reducing redundancy.

Clarity and structure of the Standard: Multiple commenters requested greater consistency and professionalism in the Standard's language. Recommendations included separating unrelated topics, clarifying inspection triggers, and improving overall readability.

Evaluation of cultivated meat: One commenter proposed expanding the Standard to include cultivated meat, poultry, and seafood under a framework similar to the one used for Microorganisms in Section 9.3.

Support and alignment with Project values: Some commenters expressed praise for the Project and trust in the Non-GMO Project Verified label. These comments reflected strong consumer alignment with the Project's mission and overall approach.

Enforcement and credibility concerns: A few commenters raised concerns about the misuse of the Butterfly logo and whether current verification tools are being applied consistently. These concerns included labeling accuracy and questions about testing sufficiency.

Outcomes

Changes made in Redline Draft 2

• Clarified treatment of mushroom cultivation substrates: Concerns about documentation requests and unclear substrate evaluation helped inform the addition of Section 9.4 in Redline Draft 2, which clarifies how mushroom cultivation substrates are treated under the Standard.
• Operational follow-up on label use: Comments about improper use of the Butterfly label and Verified claims were shared with internal teams for review and response.
Ongoing consideration

The following topics did not result in direct language changes in Redline Draft 2 but remain under ongoing consideration as the Standard continues to evolve:

• Clarified treatment of mushroom cultivation substrates: Concerns about documentation requests and unclear substrate evaluation helped inform the addition of Section 9.4 in Redline Draft 2, which clarifies how mushroom cultivation substrates are treated under the Standard.
• Language simplification: Suggestions to further simplify language, align documentation expectations, and reduce verification burden were considered in developing Redline Draft 2 and will guide future revisions.
• Expanded access and product eligibility: Proposals to expand verification to new categories or improve accessibility for underserved populations currently fall outside the scope of Standard revisions. However, the Project's Equitable Transfer Program supports BIPOC-led businesses in accessing verification.
• Mission alignment feedback: Comments expressing appreciation for the Butterfly label and the Project's mission were acknowledged and shared with staff.
Thank you – Sincerely, Project Staff ❤️

Guide to writing comments

What is the purpose of the comment?

• Suggestion for Improvement – Recommend changes to enhance clarity, accuracy, or usability. Specify the section, explain the issue, and propose concrete improvements.
• Proposal for New Content – Suggest adding new material or topics not currently covered. Clearly state what’s missing, why it’s important, and how it improves the Standard.
• Identification of Errors – Report mistakes, inconsistencies, or inaccuracies. Specify the issue, provide reasoning or evidence, and suggest corrections if possible.
• Request for Clarification – Ask for further details to better understand the content. Identify what’s unclear, explain the confusion, and suggest how clarity can be improved.
• General Dissatisfaction – Express concerns about the content. Clearly describe the issue and its impact, and, if possible, suggest ways to address it.
• Praise – Highlight aspects of the content that work well. Explain why they are effective and how they contribute to the Standard’s clarity or usability.
• Regulatory/Legal Compliance Concern – Identify potential conflicts with external regulations or policies. Reference specific laws or guidelines, provide context, and explain the compliance risk.
• Request for Exception/Exemption – Seek an exception to a specific requirement. Explain why the exception is needed, how it aligns with the Standard’s intent, and any mitigating factors.
• Neutral Observation – Share relevant observations without suggesting changes, criticism, or praise. Provide context on why the observation is important.

What type of edit is being proposed?
• Technical Accuracy – Propose corrections to factual errors, technical inaccuracies, or incorrect details. Clearly identify the issue and suggest accurate revisions based on evidence or expertise.
• Grammar/Formatting – Point out grammatical, punctuation, or formatting issues and recommend improvements to enhance readability and consistency.
• Conceptual Clarity – Suggest edits to improve the presentation of ideas or concepts, making them easier to understand. Identify areas of confusion and propose clearer wording or structure.
• Scope or Applicability – Recommend changes to adjust the content’s relevance to its intended audience or context. Explain how to refine the focus or broaden applicability as needed.
• Tone or Language Use – Recommend changes to improve professionalism, consistency, or inclusivity in language. Identify areas where wording may be biased, unclear, or inconsistent with the Standard’s tone.
• Reject the Proposed Change – Explain why the proposed change should not be implemented. Provide reasoning to support the position and suggest alternatives if applicable.
• No Edit Proposed – Indicate that the comment does not suggest a specific text change, such as praise, observations, or general feedback. Use this when offering feedback without recommending edits.

How important is this comment?
Critical, High, Medium or Low?

This content of this webpage is for informational purposes only and is not normative. The content herein holds no authority over the interpretation or implementation of the Non-GMO Project Standard and does not establish or modify any product categories, criteria, or requirements set forth within the Non-GMO Project Standard; Rules and Procedures Document; The Non-GMO Trademark License and Program Participation Agreement; or the Trademark Usage Guide. This document serves merely as a supplementary guiding resource and should not be regarded as an official or definitive source for the Standard or its associated product categories.