Non-GMO Verification in Dietary Supplements

Consumer demand for non-genetically modified organism (GMO) products is rising globally, alongside the emergence and growth of both mandatory and voluntary non-GMO labeling initiatives. The benchmark for these new programs was set in 2004 by Europe’s GM labeling regulations, BC 1829 and 1830, which gave rise to the Ohne Gentechnik, Nourri Sans OGM, and Gentchnik-Frei programs. North America’s non-GMO verification program is implemented and managed by the Non-GMO Project (NGP).

Global sales of non-GMO products are projected to increase dramatically over the next five years to encompass fully 15 percent of all global food and beverage retail sales in a market currently valued at over $800 billion. According to the Natural Marketing Institute (NMI), the package claim “No GM ingredients” plays a major role in consumer purchasing decisions. In fact, that claim was concluded to be more important to North American shoppers than “great tasting” and “nutritious.” Due to this sharp increase in consumer interest, NGP Verified has become one of the fastest growing labels in the natural products industry. To date, more than 20,000 products have been NGP verified, representing $7 billion in annual sales.

Along with national and global interest in non-GMO products comes an uneven playing field for non-GMO product manufacturers. Non-GMO standards and regulations, which focus on traceability, segregation, and the testing of high-GMO risk inputs, vary by country, region, and state. Some are process-based and investigate inputs and processing aids, while others are based on the finished product. The common feature across all countries with labeling laws is a requirement that products with GM-derived content that is not substantially equivalent to its conventional counterpart be labeled. For companies in the dietary supplement industry, meeting the core requirements of any non-GMO scheme can be very challenging. According to Kiren Israelsen of the United Natural Products Alliance, “The supplement industry lags behind the food industry on being non-GMO.”

Unlike the majority of food and beverage products, supplements commonly include long lists of ingredients. The bulk of these ingredients are high-GMO risk, being highly processed, animal derived, or sourced from high-GMO risk crops. Thus, demonstrating compliance for just one of this type of ingredient can be laborious. A manufacturer seeking NGP verification for a product containing lanolin derived D3 (cholicalciferol), for example, would have to secure documentation from their supplier that the sheep from which the lanolin was derived were not fed GM feed, which requires review of feed ration statements. Vitamins B12, B2, beta carotene, and ascorbic acid among other vitamins, amino acid and enzymes may also be manufactured using GM microorganisms, in which case, evidence that the microorganisms used to produce these ingredients are non-GMO would be required, along with evidence that the substrate with which the microorganisms were cultured was non-GMO. Other common GMO-risk ingredients found in supplements include solvents, enzymes, carriers/standardization materials, and gel caps/animal derived gelatins.

Adding to the inherent challenge of verifying long lists of ingredients as non-GMO is a lack of transparency in supply chains and subsequent difficulty in procuring the necessary documentation from ingredient suppliers. These documents include: disclosures of formulation percentages (for high GM-risk ingredients); process flowcharts to identify raw material sources; non-GMO declarations of enzymes and fermentation organisms; country of origin information for raw material sources and production processes; and traceability and segregation practices. Acquiring this level of detail from what is oftentimes a large international manufacturer with proprietary processes can be a stretch for supplement producers.

However, many efficient pathways through verification have been developed. For example, FoodChain ID, the founding technical administrator to NGP, has developed guidelines, ingredients forms, and absence declarations, and, in addition provides consulting to help participants in the evaluation of supplement products.