As the EU debates deregulating non-genomic techniques (NGTs), a growing chorus of watchdogs warn that an absence of mandatory labeling of NGTs and detection methods can have serious implications for multiple stakeholders, including organic farmers, non-GMO F&B businesses and consumers. 

The European Commission’s (EC) latest proposal to deregulate NGTs distinguishes plants into two categories: 1 NGT and 2 NGT.

The proposal considers the less-modified 1 NGT category equivalent to conventionally bred plants and suggests fewer controls for health risk assessments, labeling and verification. Additionally, it advocates for 2 NGT plants to undergo checks for GMOs, although with simpler timelines and risk assessment criteria.

Food Ingredients First sits down with Alexander Hissting, managing director of the German Association Food without Genetic Engineering or VLOG, to unpack the implications of such deregulation on stakeholders and how non-GMO labels could evolve in response.

Consumer trust and transparency

Hissting says consumers increasingly seek more information about food products, citing data that even consumers who are not against GMOs demand GMO labeling in opinion polls.

“If food aspects are kept non-transparent, they cause mistrust, so not labeling NGTs might turn out to be a blow against a very complex and lengthy process of building trust in the food industry,” he cautions.

“Efforts of many years might become worthless, and for what? The food industry does not profit from NGT cultivation at all. So, it is in the food industry’s interest to prevent such a case. On the other hand, companies that can exclude NGTs might be profiteers if they can advertise the exclusion of NGTs in their products.”

Challenges for organic farmers

Key F&B stakeholders have voiced fears that the absence of rigorous labeling rules and risk assessment checks could threaten the existence of organic and non-GMO industries.

While the legislation has not been finalized yet, Hissting envisions a “worst-case scenario” in which 1 NGT is not labeled, and there is no analytical testing or cultivation register in Europe. Such a scenario would be “challenging” for organic farmers, who he says can protect their crops from unintended contamination in several ways.

“I would advise them to talk to their conventional neighbors and find an agreement that they do not cultivate NGT directly next to your fields. If you have fields next to a road wher conventional harvests might be transported, you might want to plan a non-cultivated strip along the roadside.”

“If you convert conventional fields to organic, you have to pay attention to unintended germination of seeds left over from previous harvests and weed them before they flower.”

He suggests applying thorough cleaning protocols for organic farmers who share machinery with their conventional counterparts to avoid cross-contamination. However, his strongest advice is to stay politically engaged as the legislation is not yet in its final stages.

“The main demand toward politics would be to demand full labeling and traceability of all NGTs that also includes binding coexistence rules. Companies that place NGT on the market have to supply detection methods. That’s crucial. Ask for liability rules that protect you as a non-GMO or organic grower from GMO contamination.”

Smaller non-GMO firms could benefit

Earlier this month, VLOG and 370 businesses called for robust detection methods and EU-wide mandatory, nationally and regionally localized coexistence measures between GMO and non-GMO industries in an open letter to the EU Agriculture and Fisheries Council.

Hissting notes that as the EU works on a consensus around deregulation, it is fair to think that the financial burden of maintaining non-GMO standards will increase, particularly for smaller non-GMO enterprises. But opportunities are plenty.

“The burden for smaller companies per product unit might be higher than for large businesses, just with almost any other measurement.”

However, he proposes that this might be a chance for smaller companies to “differentiate” themselves from large corporations.

“Maybe those larger corporations do not want to take the effort and exclude NGTs from their production chains because they supply the mass market and are very much tuned toward offering low-price products. Smaller companies are better able to source ingredients locally and have short production chains, which would be favorable to exclude NGTs. So it’s not very clear how it will turn out. Even in unfortunate developments, there’s always a chance that you might profit from them.”

Safeguarding non-GMO label relevance

Under EU law, NGTs are considered GMOs. Hissting says another challenge will be to ensure that non-GMO labels evolve to exclude NGTs.

“NGTs are GMOs by science and by legal definition. If NGTs are not labeled after deregulation, organic and non-GMO certification might be the only production systems that can provide information on the absence of NGT in production chains and products. So consumers, and as a reaction, food businesses, might be troubled by the idea that their products are produced with or contain NGT without their knowledge, which harbors an opportunity for organic and non-GMO businesses.”

Agriculture ministries in member states are divided on the regulations surrounding the import and export of NGT products. Some favor deregulation, while others demand stricter measures.

When asked whether this could pose challenges for EU trade when the time comes to pick a side, Hissting says: “That would be a nightmare for the food and feed industry, but it won’t happen. GMO legislation is EU law and will apply to all member states equally. That is currently the case and will be the same.”