Over the past few months, there have been several big stories on the labeling of GMOs: Chipotle, a chain of restaurants popular in the United States declared that they were going to eliminate GMOs from their menu. A perhaps more interesting story is that the USDA stated that they would start providing a verification program for companies whose products are non-GMO.
In writing and researching GMO labeling bills proposed in different states and nations as well as looking into companies that have decided to take the non-GMO plunge, the one factor that stands out more than any other is what each of these entities choose to define as “GMO”. I use the word “choose”, because that’s what it boils down to. There’s no single definition on what is or is not a GMO, so companies and legislators get to decide how to define it. From a molecular biology perspective, a transgenic animal or crop is one where a gene from an unrelated species is added to another. But the term “GMO” as used in the current debate doesn’t have a clear definition.
For example, is milk derived from a cow that is fed GM-grain a GMO? According to the Non-GMO Project, an organization that certifies ingredients as non-GMO, milk from a cow fed GM-grain cannot be certified as non-GMO. GMO Inside, one of the organizations leading efforts to label, also abides by this definition. The USDA’s Organic label also adheres to these standards. The Food Babe used the same criteria in her campaign against “Monsanto Milk” in Starbucks beverages. However, Ben & Jerry’s, an ice cream company and one of the first large organizations to declare that it was going GMO-free and supports labeling, sources its milk from cows fed GM-grain. Ben & Jerry’s website explains their criteria for GMOs by stating “if you eat a corn chip containing GMO corn, it doesn’t make you a genetically modified human.”
What about sugar that is derived from a GM-beet? As Dr Kevin Folta outlines in this graphic, sugar is sugar. There’s no protein and no DNA in what we buy at the store. As such, it cannot be distinguished from sugar derived from non-GM beet. To obtain Non-GMO Project certification, this is resolved by looking at the supply chain (see bullet 18.104.22.168.4). But Australia and New Zealand labeling standards define a GM-ingredient as one that contains novel DNA or protein, so sugar from GM-beet would be exempt from labeling.
The definition even changes from one state to the next. In Vermont, the labeling bill states that you don’t need to label if the amount of GM material makes up less than 0.9% of the total weight of processed food, but in California‘s proposed (and failed) bill the cutoff was set at 0.5%. Perhaps GMOs have more GMOiness in California so the state can’t handle as much of it. Colorado’s proposed (and failed) bill stated that chewing gum was exempt from labeling. In Colorado, Vermont, and California, alcoholic beverages were exempt, but I could find no such exemption in the bill from Connecticut.
Some may argue that it’s better that we just start somewhere. Anywhere. They will argue that any form of labeling is better than none. But the immediate consequence of a labeling bill that does not meet everyone’s requirements is the fact that the number of labels and verification-criteria will explode. Certifiers will try to sell consumers on the purity of their criteria and benefits of their definition of a GMO. Here’s an example: as you may know, the USDA’s organic label excludes GMOs and is often used by those who wish to avoid GMOs in their diet. However, according to GMO-awareness.com, the USDA’s organic label isn’t stringent enough because there are a handful of exemptions, so the organization embraces the Non-GMO Verified seal.
Personally, I like Australia and New Zealand’s criteria. The difference between a GMO and a non-GMO crop is the DNA for the gene that has been added and the protein(s) that it produces. So if the very thing that make a crop a GMO cannot be detected in a food product, then it shouldn’t be labeled. Australia and New Zealand extend their labeling criteria to foods that are designed to be different from their non-GMO counterparts, such as high oleic soy or the Innate potato: these must be labeled as genetically engineered.
But that’s my personal opinion, and it probably would not meet the demands of most GMO-labeling proponents. Since there’s no hard rule each person can have their own criteria, which will probably lead to a bureaucratic nightmare where lobbying groups for different foods and ingredients will argue as to why their product should or should not qualify as a GMO. And who’s to say they’re wrong?
Here’s a list of common ingredients whose classification as “GMO” is debatable:
- Vitamin and nutritional additives produced through genetic engineering, commonly used in fortified foods. Vitamin C, for example, can be made through fermentation of corn (which could be a GMO). Riboflavin can be synthesized by a GM-bacteria.
- Oils, sugars, and starches, which have no trace of protein or DNA
- Animal products from animals fed GMO grain (i.e. eggs, milk, meat, etc).
- Animal products from animals who have received GE vaccines
- Cheese, yogurt, and other dairy products whose production may use GE bacteria
There’s also the all important topic of “cut-off”. How much GMO is acceptable in a product? Some would argue that it should be 0.0%, but that’s not realistic considering the fact that equipment is often shared in the supply chain. How do we decide whether it is 0.5% (California’s criteria) or 0.9% (Vermont’s criteria) that makes a food item a GMO? There’s no scientific answer, so again, it will have to be decided via politics and lobbying.
I don’t have an answer here, and I write this only to highlight the many nuances that are perhaps ignored, and the bureaucratic disaster that a poorly designed federal, or worse yet state-level, labeling bill could turn into. Feel free to comment on what ingredients you think should be labeled in a federal voluntary or mandatory labeling law.