On Monday, we heard from Jenica Rosen who raises important questions about the Non GMO Project. Jenica asks us to look into the companies that are supporting this initiative and consider their motives for doing so. Encouraging us to “follow the money,” she urges shoppers to dig deeper into any certification or labeling system and then make their own decisions about the products and the companies they support with their consumer dollars. Today, we hear from another Equal Exchange Sales Representative, Ellen Mickle, also based in our Portland, Oregon office. In her post below, Ellen reminds us that organic products cannot be certified as such if they contain GMO ingredients. Given this “gold” standard, she asks what, if any, value the Non-GMO labeling project adds in the market place. More concerning, Ellen questions whether the ever-increasingly ubiquitous butterfly seal might not be undermining the organic certification system, as well as attempts to enact legislation which would require mandatory labeling of foods containing GMOS (rather than voluntary labeling of those which do NOT contain GMOS). Finally, Ellen reminds us that many of the products which are showing up with the butterfly seal are on products for which there are actually NO GMO alternatives.
Voluntary Non-GMO Labeling: A Party Worth Joining?
Nowadays you can get your day started with Non-GMO Project Verified eggs, wheat toast and coffee – making it seem like industry, regulators, and consumers have united to carve out a brave new world in terms of our daily food choices. The only snag is; that world already existed. It’s called Organic, and this relatively new, voluntary Non-GMO Project Verified seal may be inadvertently undermining Organic, as well as attempts to enact legislation requiring mandatory labeling of foods containing GMOs.
Consumer trepidation about consuming genetically modified organisms (GMOs), or “an organism that has been changed by injecting it with genetic material from another species”[1] is at an all-time high, with 93% of consumers wanting the federal government to make GMO labeling mandatory[2]. Commercial production and sale of GMOs in the U.S. began with a short-lived and much maligned “flavr savr tomato” in 1994, and currently nearly 75% of processed foods on supermarket shelves contain GMOs[3], mainly via the “big four” processed food superstars: corn, sugar beets, soy and canola[4]. Consumers’ concerns about GMOs range from personal health to environmental pollution. Public concern is bolstered by a growing body of evidence that the technology is falling short of its promises, as weeds[5] and pests[6] evolve resistance to the crops that were engineered to out-compete with them.
How did we get here? In contrast to the European Union, with member nations among the 65 countries requiring mandatory labeling of GMOs, the U.S.’s regulatory agencies overseeing the safety of GMOs (FDA, USDA, and EPA) do not employ the precautionary principle toward GMO regulation, which in environmental law has authorized regulators to “assess risk rather than wait for proof or actual harm[7].” In my estimation this is largely due to the FDA’s decision that flavr savr tomatoes required no testing or labeling because they’re “substantially equivalent” to Non-GMO tomatoes.
There are myriad political, historical, and cultural factors behind why the U.S.’s path to regulating this technology differs from many developed countries. However, one cannot ignore the impact of the famous “revolving door” between regulators and industry. For example, Michael Taylor, current FDA Deputy Commissioner for Foods, also worked in FDA policy at the time the substantial equivalence policy set the groundwork for GMO regulation. Taylor then went on to work for Monsanto and a Monsanto-representing law firm in the intervening years[8] before he returned to the FDA as Deputy Commissioner for Foods.
So, in true American fashion, we take to the market to effect change and vote with our forks — when we’re not voting with our votes (lowest voter turnout since WWII, with two states’ mandatory labeling propositions on the ballot). The Non-GMO Project, a non-profit founded in 2005 that is “committed to preserving and building the non-GMO food supply, educating consumers, and providing verified non-GMO choices” began as a consumer-driven letter-writing campaign to food manufacturers to determine the “GMO status of products.”[9] It’s unclear to me why these consumers didn’t throw their weight behind supporting Organic from the beginning instead of creating a “cheaper alternative to organic.”[10] Most troubling to me is the preponderance of Non-GMO verified products that have no GMO counterpart in the marketplace (that coffee, egg, toast breakfast for instance), and also that opponents to mandatory labeling have used it as a defense, a la the “Portland Mercury” urging voters to strike down Prop 92 because, “if you really, really care about how your food’s produced, there are already labels for you[11].”
The Organic Trade Association (OTA) reminds us that we already have a gold standard of Non-GMO; “the USDA National Organic Standards prohibit the use of GMOs in all label categories (“100% Organic,” “Organic,” and “made with organic ingredients.)”[12] As we contemplate whether or not to pursue this label at our company we should account for whether it serves a need and serves our mission, and if not, should we put our energy towards educating ourselves and consumers about the continued relevance and importance of what we already have?
[1] https://www.ota.com/learn-about-organic/organic-and-gmos
[2] http://www.nytimes.com/2013/07/28/science/strong-support-for-labeling-mo...
[3] http://www.centerforfoodsafety.org/issues/311/ge-foods/about-ge-foods#
[4] http://www.centerforfoodsafety.org/files/shoppers-guide_final_24562.pdf
[5] http://grist.org/food/weed-wisdom-what-to-do-when-nature-outfoxes-herbic...
[6] http://www.nationalgeographic.com/foodfeatures/green-revolution/
[7] http://www.cfr.org/agricultural-policy/regulation-gmos-europe-united-sta...
[8] http://www.organicconsumers.org/articles/article_27143.cfm
[9] http://www.nongmoproject.org/about/history/
[10] http://www.npr.org/blogs/thesalt/2014/02/28/283460420/why-the-non-gmo-la...
[11] http://www.portlandmercury.com/portland/its-the-mercurys-endorsement-gui...
[12] https://ota.com/sites/default/files/indexed_files/OTA-Info-Card-GMO.pdf
December 3, 2014