Understanding Low and High Risk

PRODUCT VERIFICATION: UNDERSTANDING LOW AND HIGH RISK

The Non-GMO Project Product Verification Program is North America’s only third-party verification for non-GMO food and products. Third-party verification is the highest quality system when it comes to product labeling and certifications because it ensures products have been comprehensively evaluated by an independent party, called a technical administrator, for compliance with the Non-GMO Project Standard, which is developed by industry experts and stakeholders.

What are high-risk/monitored inputs? 

One of the elements that sets the Non-GMO Project Standard apart from other non-GMO claims is the requirement to test major high-risk inputs, or ingredients1, of Verified products when testing is available to quantify GMO contamination. 

The Non-GMO Project uses a risk matrix to determine which inputs or ingredients should be included on the Standard’s high-risk list. As GMO crops and other inputs become more commercially available, they are entered into the matrix; when their total risk score reaches a predetermined threshold, they are recommended for addition to the high-risk list. 

Ingredients and inputs for which genetically modified counterparts are in the research and development stages, which have been developed but are not widely commercially available, or for which known GMO contamination has occurred are closely tracked and monitored by the Non-GMO Project, and thus are considered to be “monitored risk.” For more information about the high-risk and monitored-risk lists, please visit our website and review the Non-GMO Project Standard. Frequently asked questions about the Project’s risk classifications and GMOs can also be found here.

Low-risk inputs, and why we verify

“Low-risk” ingredients, on the other hand, are inputs or ingredients that are at a low risk of being produced through genetic engineering or from genetically modified organisms (GMOs). One of the most common questions we get at the Non-GMO Project is why we verify products that are categorized as “low-risk.”

For example, while it may seem strange to have Non-GMO Project Verified orange juice, flavored water, or salt, there are several important reasons why we verify all types of products — including those for which genetically modified versions have not yet been commercialized (i.e., monitored-risk inputs) and even those considered to be “low risk,” as further discussed below.

Hidden high-risk ingredients

Some products that seem low-risk may actually contain less-visible high-risk ingredients, including “micro” ingredients or inputs that may be present at less than 0.5% of the finished product. Take, for example, dried fruit. Products like raisins and prunes are sometimes coated with a small quantity of an oil to keep them moist. The oils used on dried fruit are often produced from crops or inputs on the Standard’s high-risk list (i.e., the oils are often produced from genetically modified soybeans or canola). If these ingredients are used in very small amounts they may not be required to be listed on a product’s ingredient panel. However, prior to use in a verified product, all ingredients — even those that are not required to be listed on an ingredient panel — must be evaluated to ensure they meet the requirements of the Non-GMO Project Standard.

“Sugar” is also a good example of a potential hidden high-risk ingredient. While cane sugar is considered to be a low-risk input (i.e., there is no known commercially available GMO cane sugar), GMO sugar beets, as discussed in more detail below, are high-risk inputs that are widely commercially available and often used to sweeten a variety of products. However, many products will simply list “sugar” on an ingredient panel without further information as to the source of the sugar. By looking for products with the Non-GMO Project Verified mark, consumers seeking to avoid GMOs can quickly and reliably choose products that meet the Non-GMO Project’s Standard, even when the ingredient panel is silent as to the true source of the ingredient.

Consumer knowledge about GMO ingredients

Verifying only high-risk products would put a burden on consumers to know what crops are currently being genetically engineered and which ingredients are derived from these GMOs. Every year we see new GMOs enter the marketplace and it can be challenging to discern which ingredients might be derived from a genetically engineered crop. The Non-GMO Project wants to make it as easy as possible for shoppers to know whether the products they are buying meet the requirements to be Non-GMO Project Verified.

For example, there are GMO varieties of crops, such as wheat and rice, that are closely monitored by the Non-GMO Project, but are currently not being used commercially. Consumers, however, may not have the information readily available to know whether or not a certain ingredient, such as wheat, is currently being used in commercial products. Whether or not GMO wheat has been commercialized, consumers can rest assured by the Non-GMO Project verification mark — as the Butterfly ensures that the product meets our regularly updated standard. 

Providing a level playing field for all non-GMO products

Only labeling products that are either at high risk of being GMO or at high risk of being contaminated with GMOs may potentially confuse consumers and create an unfair competitive advantage. Sugar, again, is helpful in illustrating this concept. Picture a shopper in the grocery store aisle looking at two jars of raspberry jam. As previously discussed, both may simply list “sugar” on the ingredient list, but one may be sweetened with beet sugar (95 percent of U.S. sugar beets are genetically modified) and one may be sweetened with cane sugar (GMO versions are in development, but not on the market yet). If we only allowed high-risk products to carry the trusted Butterfly mark, only the jar sweetened with non-GMO beet sugar could be eligible for Non-GMO Project verification. The cane sugar product would not be eligible in this scenario, though it too would be non-GMO. The average shopper may have little insight as to why one of the jams may be eligible for verification and not the other. By allowing both products to carry the Non-GMO Project verification mark, we feel we’re serving both food manufacturers and consumers who are looking for convenient and reliable ways to determine if a product meets the Non-GMO Project’s Standard. 

Building and maintaining a non-GMO food supply

The Non-GMO Project’s mission is to preserve and build a non-GMO food supply. By verifying low-risk products, the Non-GMO Project continues to work to build consumer interest and industry investment in non-GMO food production. In contrast, biotech developers are also constantly working to patent and commercialize new organisms (e.g., apples, bacteria, cows, salmon, wheat, etc.). The persistent lack of regulation and oversight for GMOs — including unapproved variety trials conducted in open-air fields at undisclosed locations — means there are ongoing and serious risks of contamination from experimental varieties. Contamination has happened on numerous occasions, such as the recurring discovery of unapproved GMO wheat. The Non-GMO Project is poised to proactively respond and coordinate surveillance testing strategies to help assess the extent of the contamination. By including low-risk products in the scope of our program and databases, we are able to identify at-risk products and incorporate changes to our Standard as necessary.

Additionally, companies are now actively seeking the Non-GMO Project Verified mark to demonstrate their non-GMO commitment and setting the bar for the future of food production. Every day consumers learn about our mission through the more than 60,000 products that carry the Butterfly, and engage through our websites and social media to find out more. 

To dive further into the issue, here are a couple of examples of ingredients and products we receive questions about:

Salt

While not an organism, many table salts or salt products on the market today have minor amounts of other ingredients — such as the anti‑caking agent dextrose — which can be derived from genetically modified corn. Although 100% salt does not have a GMO counterpart, products that are sold as “table salt” or “ sea salt” may contain other inputs with GMO counterparts. In other words, because not all salts are 100% salt (with no other inputs), the Non-GMO Project verification mark allows consumer discernment in selecting a salt that does not have any GMO additives. Our rigorous verification process tracks down GMO risks that might not be obvious to the consumer. For those consumers who avoid GMOs, the Project’s verification mark enables them to quickly identify whether a product has been Non-GMO Project Verified, without having to review the ingredient list, and can also help educate shoppers about the multitude of minor or micro inputs that may exist in common products that seemingly have no connection to GMOs.

Orange Juice

Genetically modified oranges have been developed in test plots, but they are not yet commercially available to growers. Oranges, and many other crops, are included on the Standard’s Non-Testable Monitored-Risk Inputs and Ingredients List. Non-GMO Project Verified oranges and other verified low-risk ingredients can help shed light on the issues of new novel organisms that are constantly being created in labs. Consumers may not have the information readily available to know whether or not certain monitored-risk and low-risk crops, such as oranges, are currently commercially available in GMO form. Also, similar to table salt, minor amounts of other ingredients in orange juice could have originated as GMOs — citric acid, vitamin D and many other supplements begin as a substrate or derivative of genetically modified corn. Our seal provides assurance that the entire product was evaluated for compliance with our Standard. Further, our rigorous Standard can put pressure on companies to change their ingredients to non-GMO sources.

Conclusion

The USDA estimates that up to 80 percent of groceries in North America contain GMOs and GMO derivatives, which reflects the fact that more than 90 percent of our farmland is planted in GMO commodity crops. Corn and soy alone provide an almost infinite number of ingredients and additives found in many processed foods. This is why consumers know, trust, and seek out the Non-GMO Project Verified mark in every aisle at the grocery store. Consumers know that preserving and building the non-GMO supply chain is a critical step of transitioning toward a non-GMO food supply for future generations.