Labeling Should Be Simple
Transparency is Natural

In light of current debates within the industry regarding labeling, it might be good to take a simple look at how GMOs could and should be labeled (without much fuss) through every step of the supply chain. Product and ingredient transparency may not necessarily result in higher prices or a major increase in manufacturing and distribution costs. Creating win/win solutions may be the answer for a united industry approach to consumer requests for clear product and ingredient labeling. Meeting consumer demand is an essential component to support a healthy, ethical and profitable industry standard.

Let's look at how GMO food and agricultural crops go through the supply chain and end up on the shelves and on the table. Accurate labeling is good business, i.e. product transparency is an upright, ethical business practice which can only bring good fortune to the growers and manufacturers involved.

It is important to note that the steps listed below do not address the concerns of organic consumers who wish to see GMOs prohibited and eliminated at all stages of production. However, it may be prudent to address the potential simplicity and negligible cost of mandatory GMO labeling for those requesting their "right-to-know" whether foods and related products contain GMOs.

There has been some confusion about what mandatory labeling means. It is not only non-GMO labeling. Mandatory GMO labeling means that every product which contains GMOs has this fact clearly printed on the label and within the ingredients list on each product. GMO produce also would have an accurate GMO label on each fruit and vegetable. Manufacturers who are hesitant to commit to mandatory labeling may wish to refer to the example of the many countries where GMOs have been banned. In an even greater number of countries GMOs are mandatorily labeled in all products so that consumers can make informed choices.

Here are the simple steps to facilitate accurate labeling of GMOs—seed to table.

Step 1: If the farmer chooses to buy or obtains GMO seeds, it is with the understanding that the seed source clearly labels their seeds as GMO before selling them to the farmer, so that the farmer knows that he is growing GMO crops.

Step 2: The farmer clearly labels his GMO crops as GMO, so that whoever purchases his crops knows that they are GMO. This is important because the farmer may be allocating fields to grow conventional, GMO and non-GMO crops in close proximity, with the intention of serving two or more markets through his agribusiness. With proper caution the crops and seeds will not be mixed, however one may have to account for both human and natural errors which could mix or contaminate the different types of crops. Assuming that there is no contamination, it should be possible for the farmer to sell his GMO crops labeled as such.

Step 3: The GMO crops may then be sent for processing or used in animal feed. Use of the GMO crops in animal feed could result in GMOs appearing in milk or food crops at a later time. Cows may be fed GMO feed and their manure may be widely used as a fertilizer for food crops. Alternately, the GMO crops are sold for processing, a step often involving milling or other kinds of pre-processing and refining necessary for the crops (such as oilseeds) to later be used as ingredients in foods, supplements, nutraceuticals, personal care products, cosmetics and more.

The processor clearly labels the processed product as GMO before it is sold to manufacturers. In all cases, the products are being labeled anyway. All that is required is to add the word GMO to meet the requests for product transparency.

All feeds containing GMO ingredients are clearly labeled as GMO feed. Farmers purchasing GMO feed are warned about GMOs ending up in the dairy supply and in the food chain through manure and composting. Manufacturers purchasing ingredients are also warned about ingredients sourced from crops or animal products where GMO feed is involved. In this case, testing may be required to verify if the ingredients contain GMOs.

Step 4: The processed GMO product, such as GMO soy lecithin, ground GMO corn, or GMO canola oil, is then sold to the manufacturer who in turn will convert it into a food product, a supplement, nutraceutical, personal care product, or cosmetic.

Alternately, the processor may sell it in bulk to food stores or food service. When the product is received, the Q/A director and whoever sources the ingredients for the manufacturing company checks to see that the ingredient is clearly labeled as GMO. The manufacturer has employees who as part of their job verify that the processed GMO ingredient is GMO and ensure that it is labeled this way (in-house) before, during, and after the final product manufacturing process. The products are being labeled anyway, so it should be very simple to add the word GMO accurately where applicable.

Step 5: Once the product manufacturer completes the product labels for the ingredients in the products, as normally required, the person responsible for the labels simply lists and labels the ingredients which have come through the supply chain as GMO. In other words, the product manufacturer has their labeling department list the ingredient as GMO on the label. Examples are GMO soy lecithin, GMO corn, GMO sugar beets, etc.

Step 6: The final product is then purchased by a distributor or directly by the stores. In the case of bulk products, they may be purchased in large quantities by food service, schools, restaurants, health institutions, and more. Once the products are on the shelf or on the menu, there may be a majority of consumers (surveys say 85% -90%) who wish to know if the products contain GMOs. Here is the opportunity for the industry to comply with consumer demand!

As a result the products appear on the shelf or on the menu with the ingredients simply and clearly labeled as GMO. This includes all ingredients derived from GMO seeds and crops that have already been clearly labeled without much trouble and without extra expense all through the supply chain! Examples include GMO canola, GMO cottonseed oil, etc.

Step 7: The growing number of consumers who have asked for full product transparency (i.e. they wish to know what is in their food, supplements, and other natural products) reflect growing global requirements for accurate labeling and full product and supply chain transparency as a necessity to maintain good health, protect the environment, promote sustainability in business and protect life on earth.

In this way, all GMO products are simply and clearly labeled. Tracing the prior six steps through the supply chain does not seem to require extra time, additional employees, or an increase in costs because GMOs were labeled at every step through the supply chain. Ingredient labels are being prepared already by those employees whose job it is to source products and ensure accuracy of product content and representation. It is only necessary to add the word GMO accurately where applicable.

The conclusion is that if overwhelmingly large numbers of consumers (the target market and recipients of all products, goods and services in the industry) want mandatory labeling of GMOs for all conventional and natural products in all categories, there is not much more that anyone needs to do other than to be alert and label the GMOs at every step in the supply chain process.

What About Products Already on the Shelves Which May Contain GMOs?

Addressing products that have already gone through the supply chain and manufacturing process, which may currently be on shelves or sitting in storage for future sale, is another important issue for the conventional and natural food and products industry. Greater thought may need to be given as to how to deal with these products in the transition stage.

Allergies

Clear and accurate labeling is already considered important in the food, supplement, and nutraceuticals industry especially in the case of foods and ingredients which may cause allergic reactions. GMO ingredients may be in this allergy alert category and as such accurate labeling and full transparency is a requirement to meet allergy labeling standards. This is especially important in the supplements industry.

Conclusion

The consumer base requesting mandatory labeling includes religious leaders, scientists, health professionals, educators, school children, expectant mothers, parents with families as well as environmentalists. Manufacturers and industry leaders can no longer ignore consumer sentiment about the importance of product safety, accuracy, and transparency when it comes to labeling ingredients. With valid health and environmental concerns, a growing number of consumers wish to see all contaminants to the food supply and natural products lines immediately and permanently removed 100% from the market, the agricultural supply chain, and the eco-system. However, in the interim, these simple and immediate steps to label GMOs could end the controversy and pave the way for current and future growers, processors, and manufacturers to (at the very least) label GMOs during the growing and manufacturing processes.

America is considered one of the most creative, affluent and innovative countries in the world and as such has a greater responsibility than ever to lead the world's food and products supply in a direction which ensures a sustainable and healthy future. Taking these very simple steps to label GMOs throughout the supply chain may be a viable solution.

Simi Summer, Ph.D. is an independent researcher, educator, and free lance writer. She is a strong proponent of organic consumer education and informed consumer choices.

Reference

Solving the Problem of Pesticides: Implications for Natural Products. Whole Foods Magazine Admin Blog, 6/5/15