The Non-GMO Project uses a set of criteria to determine the Standard’s High-Risk List, which is a list of crops and inputs that are highly likely to be genetically modified (GM). As genetically modified organisms (GMOs) enter the market, we evaluate the risk they pose to the non-GMO supply chain, taking into account key criteria including:
- The number of acres planted
- Commercial availability
- The crop’s presence in the supply chain
- How the crop is currently used
- How the crop could be used (eg., as human food or as animal feed)
For example, corn is on the High-Risk List because 92% of corn grown in the U.S. is genetically modified, and GM corn is widespread in the marketplace. Because of these factors, the chance that corn-based ingredients in food found on the average grocery store shelf come from genetically modified corn are high.
Testability of high-risk crops
The Non-GMO Project Standard is unique among non-GMO claims because of testing requirements for high-risk inputs and ingredients.
To meet the requirements of the Non-GMO Project Standard, a major input or ingredient that is made from a testable high-risk crop must be traced back to the raw source material, which is tested to prove that it is non-GMO. For example, to confirm that soybean oil meets our Standard, the raw soy must be tested before it is crushed into oil. Testing raw materials — not processed materials — improves the reliability of the test results, as the genetic material is still intact in the crops’ unprocessed state.
Testable high-risk crops are:
- Corn (except popcorn)
- Sugar beet
- Zucchini and yellow summer squash
As new GMOs enter the market, not all are detectable by current tests. However, a non-testable GMO is still a GMO, and we work to exclude them from our Verified products. In recognition of the potential for non-testable GMOs to contaminate the non-GMO supply chain, the Non-GMO Project Standard requires legally-binding affidavits for non-testable high-risk crops, inputs, and ingredients attesting that they have not been genetically modified.
Currently, non-testable high-risk crops are:
- Apple (effective January 1, 2022)
- Eggplant (effective January 1, 2022)
- Pineapple (effective January 1, 2022)
Two notable high-risk crops — canola and soy — may be testable or non-testable, depending on the genetic engineering methods used to produce them.
Animal-derived inputs and ingredients
Animal derivatives — such as meat, eggs, milk and honey — are considered high-risk inputs and ingredients due to the prevalence of GMOs in animal feed. As such, animal derivatives are evaluated by reviewing the animals’ feed and requiring that the testable and non-testable high-risk major inputs to that feed be non-GMO. Genetically modified animals — including cloned animals and their offspring — are prohibited.
Animal-derived inputs and ingredients include:
- Livestock and poultry feed
- Bee forage and feed
- Fish and other aquatic animal feed
- Any other materials or substances originating from animals
Microorganisms — such as algae, bacteria, and yeasts — are fed growth media that contains testable and non-testable high-risk inputs. In most cases, the Non-GMO Project Standard requires that the microorganisms themselves be non-GMO. It also requires that testable high-risk major inputs to the growth media are tested when the microorganism or microbial product is a major input or ingredient in a Verified product. Just as both the cow and her feed are evaluated to the Standard when milk is Verified, so are the microorganisms and their growth medium evaluated to the Standard when microorganisms and microbial products are Verified.