The Non-GMO Project uses a risk matrix to determine the Standard’s High-Risk List, which is a list of organisms that are highly likely to be or be derived from a genetically modified organism (GMO)1. As monitored GM crops/inputs become more available, they are entered into the matrix; when their total risk score reaches a predetermined threshold, the corresponding crops/inputs are recommended for addition to the High-Risk List. The risk matrix focuses on key criteria, including: the number of acres planted; commercial availability; the presence in the supply chain; usage; and its potential use in human food or as animal feed.
For example, corn is on the High-Risk List because GM corn is prevalent in the marketplace and the chances that the corn ingredients in food on the average grocery store shelf come from GM corn are high.
|Testable High-Risk||Non-Testable High-Risk|
|One of the elements that sets the Non-GMO Project Standard apart from other non-GMO2 claims is the requirement to test major high-risk inputs and ingredients to verified products when testing is available to quantify GM contamination.
To meet the requirements of the Non-GMO Project Standard, an input or ingredient derived from a testable major high-risk crop will need test results from the raw source material to validate that it is non-GMO. For example, in order to prove that soybean oil meets our standard, the raw soy must be tested before it is crushed into oil.
|Not all GMOs on the market are detectable by current tests. In recognition of the potential for non-testable GMOs to contaminate the non-GMO supply chain, the Non-GMO Project Standard requires declarations for major and minor high-risk crops, inputs, and ingredients attesting that they have not been genetically modified through the application of biotechnology3|
The following crops are high risk:
Testable and Non-Testable High Risk Crops
|Apple||Beginning January 1, 2022|
|Corn (except popcorn)||x|
|Eggplant||Beginning January 1, 2022|
|Pineapple||Beginning January 1, 2022|
|Zucchini and Yellow Summer Squash||x|
Canola and soy are identified as both “testable” and “non-testable” high-risk as different techniques may be used to genetically modify these inputs, only some of which are detectable by current test methods.
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 more specifically, by testing the testable major high-risk inputs to that feed. Genetically modified animals, including cloned animals and their progeny, are prohibited for use in verified products.
Animal-derived Inputs and Ingredients
|Meat, dairy, eggs, wool, hides, honey, seafood, and any other materials or substances originating from animals||x||x|
|Livestock and poultry feed||x||x|
|Bee forage and feed||x||x|
|Fish and other aquatic animal feed||x||x|
Microorganisms such as algae, bacteria, and yeasts are fed growth medium 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, and it also requires that testable major high-risk inputs to the growth medium are tested when the microorganism or microbial product is a major input or ingredient in a verified product. Much like Non-GMO Project Verified milk must come from cows fed non-GMO feed, microorganisms and microbial products in verified products may be required to be fed a non-GMO growth medium.
Microorganism and Enzyme Inputs and Ingredients
|Microbial cultures and starters||x|
1. An organism to which Biotechnology has been applied and derivatives of such an organism; cloned animals are included within this definition. ↩
2. An organism to which Biotechnology has not been applied and derivatives of such an organism. ↩
3. Biotechnology – the application of:
….. a. in vitro nucleic acid techniques, including recombinant deoxyribonucleic acid (DNA)
and the direct injection of nucleic acid into cells or organelles; or
…. .b. fusion of cells beyond the taxonomic family, that overcame natural physiological,
reproductive, or recombination barriers and that are not techniques used in
traditional breeding and selection. ↩