Non-GMO Standards

Certified Non-GMO Standards

Certified Non-GMO Standards (pdf)

Certified Non-GMO by AGW (CNGMO) represents the most transparent, practical standards for Non-GMO certification. The seal may be applied to raw materials and finished products only once a valid certificate has been issued.

The standards may be applied to the following: Products for human consumption such as crops, meat, eggs, and dairy; ingredients used in the production of food products such as processing aids, livestock feeds, and silage inoculants; ingredients intended for human use such as cosmetics and clothing.

For the purpose of these standards, gene editing and gene silencing are considered genetic modification and are prohibited.

CNGMO can be applied to two categories:

Category 1: Products that contain any animal product (All standards apply)

Category 2: Products that contain no animal products. (The following standards do not apply: 1.01, 1.02, 1.03, 1.04, 1.1.3, 1.1.7, 1.1.8)

Note: AGW reserves the right not to certify products that do not meet the overall aims of all the AGW programs.

Non-AWA livestock farmers are not permitted to apply to the CNGMO programme prior to AWA program application; however, applications may occur simultaneously.

For information on animal management, health care, pasture management, housing and shelter, transport and other requirements please see the AWA standards for individual species.

The CNGMO standards apply to all livestock that produce the meat, dairy, fibre and eggs that are to carry certification, the crop species that are grown on- and off the farm to feed them and the inputs used to produce both the crops and the animals.

Emerging biotechnology: In addition to genetic modification of organisms, AGW recognises biotechnology, including (but not limited to) gene editing and gene silencing, pose specific risks to our food system. Due to emerging biotechnology and breeding techniques such as meganucleases and clustered regularly interspaced short palindromic repeats (CRISPR), transcription activator-like effector nucleases (TALEN), zinc finger nucleases (ZFN), RNA interference (RNAi)—as well as other techniques— detection of these methods can be difficult. For the purpose of the CNGMO standards, all emerging biotechnology will be considered “GMO,” and as such, the CNGMO standards apply accordingly.

Ensuring Informative Labeling: While CNGMO is designed to differentiate non-GMO products from their GMO counterparts, AGW may consider certifying products or ingredients which are not known to be genetically modified under one or more of the following circumstances:

• There is a documented risk of supply chain or processing contamination. Any label use must be accompanied by a phrase indicating that while raw ingredients are not commonly genetically modified, AGW certification ensures no GMO contamination in processing.
• There is a need for consumer education or to provide accurate information about genetic modification in food. Any label use must be accompanied by a phrase indicating that the product in question is not known to be genetically modified.

1 GENERAL STANDARDS

 1.0 Eligibility

1.0.1      CNGMO products must be produced without the use of Genetically Modified Organisms (GMOs).

1.0.1.1 Ingredients and inputs must not be derived from GMO substrates.

1.0.2      CNGMO products must be free of contamination from GMOs.

Note: There must be no contamination with GMOs during production, processing, storage and transport of feed, inputs or ingredients.

1.0.3    CNGMO products containing or derived from animal ingredients must come from livestock certified to the Certified Animal Welfare Approved by AGW (AWA) species-specific standards.

Note: Derogation may be granted in cases where AWA animal ingredients are not available. See Logo Use Guidance for Certified Operators for more information.

2 LIVESTOCK AND CROPPING

2.0  Transition periods

2.0.1      CNGMO meat products from cattle, sheep, goats, pigs, deer and fish must come from animals whose mothers were managed to these standards from at least the last third of gestation onwards.

2.0.2      CNGMO dairy products must come from animals that have been managed to these standards for at least 12 consecutive weeks prior to certification.

2.0.3      CNGMO meat products from poultry must come from birds that were managed to these standards from hatch onwards.

2.0.4      CNGMO eggs must come from poultry that have been managed to these standards for at least 12 consecutive weeks prior to certification.

2.1 Inputs for livestock and crop production

2.1.1      For operators that raise non-GMO animals, but grow GMO crops, there must be documented commitment to transition the farm to a fully non-GMO operation within 3 years.

Note: Operators with complete segregation may be considered for derogation. 

2.1.2      Livestock must not be fed grains, concentrates, supplements, vitamins, minerals, feed additives and carriers containing GMOs.

2.1.3      If a CNGMO product contains fish as an ingredient, the fish must come from fisheries with a valid certificate of sustainability or from byproducts of fish or aquatic species intended for human consumption.

2.1.4      The use of fertilisers containing GMOs or their derivatives must not be used on crops, range or pastureland used for feeding and raising livestock that will produce CNGMO meat, milk or eggs or on land that will produce crops used in a CNGMO product.

Note: Examples of non-compliant fertilisers are plant-based fertilisers derived from GMO crops – e.g. oil cake from GMO canola.

Composts and manures derived from animals fed GMO feeds are not included in this standard.

2.1.5      The use of pesticides containing GMOs or their derivatives must not be used on crops or range/pastureland used for feeding and raising livestock that will produce CNGMO meat, milk or eggs or on land that will produce crops used in a CNGMO product.

Note: An example of a GMO pesticide is modified Bacillus thuringiensis.

2.1.6      The use of inoculants containing GMOs or their derivatives is prohibited for any input used in the production of CNGMO products (e.g. milk, eggs or meat cannot be produced from livestock fed a GMO-inoculated crop).

Note: Inoculants for hay, silage and haylage and rhizobium inoculants may contain GMOs.

2.1.7      Knowingly using veterinary and health care products containing GMOs or their derivatives is prohibited. This includes the use of medicines, vaccines, and parasiticides.

2.1.8      If there is no alternative to the use of a veterinary or health care product that contains GMOs or their derivatives, the animal must be treated, the treatment must be recorded and the meat, milk, eggs or fibre from that animal must not be sold under the CNGMO label.

2.1.9   Records of livestock and cropping inputs (e.g. feed and seed purchases) must be kept.

Note: AGW recommends retaining records for three years.

2.2 Land where GMO crops have been or are grown

2.2.1      New applicants must inform AGW if any GMO crops have been grown on any part of the farm in the last three years.

2.2.2      To prevent contamination, GMO and non-GMO crops of the same species cannot be grown on any part of a farm or group of farms seeking certification.

2.2.3      Any GMO crops grown on any part of a farm or group of farms owned or managed by the operator must be declared annually to AGW.

2.2.4      AGW must be informed if the operator is aware of any GMO crops of the same species as their non-GMO crops being grown on neighbouring land.

Note: The wind and bees may carry GMO pollen that can cross-contaminate non-GMO crops of the same species (See Appendix 1).

2.2.5      Corn for use (e.g. as animal feed) for any CNGMO product must not be grown alongside any known crops of GMO corn.

Note: The definition of “alongside” for this standard is a field that shares a boundary with any field used to grow GMO corn.  Planting schedules must be developed to prevent cross-pollination either by distance, planting cycles, or barriers.

2.2.6      Corn for any CNGMO product should be grown a minimum of two miles from any known crops of GMO corn.

Note: Pollen from GMO corn can travel a long way and non-GMO corn crops should be grown as far away from GMO corn crops as possible.

2.2.7      Corn for use for any CNGMO product should be planted at least a week apart and preferably three to four weeks apart from any known GMO corn crops so pollination takes place at different times.

2.2.8      Soya for use (e.g. as animal feed) for any CNGMO product must be grown a minimum of 50 ft. from any known crops of GMO soya.

Note: Soya is considered a low-risk candidate for contamination, as it is a self-pollinating crop. In addition, pollen from soyabeans is too heavy for wind transport.

2.2.9      Any volunteers, feral populations, and/or wild relatives of CNGMO crops must be controlled when these occur in proximity to the non-GMO crop.

2.2.10    When pollinators are rented, CNGMO farms should ensure that these have not previously been used in proximity to fields where GMO crops were grown within the past 24 hours.

2.2.11   The crops and location of wild harvested crops intended to carry the Certified Non-GMO by AGW logo must be declared annually.

2.2.12   For wild-harvested crops, the crop collected must not be listed as endangered or threatened.

3 SEGREGATION FOR ALL OPERATORS

3.0 Avoidance of cross-contamination

3.0.1      Dedicated non-GMO equipment and facilities for harvest, cleaning, receiving, production, processing, storage and transport must be used when available.

3.0.2      If dedicated non-GMO equipment and facilities for harvest, cleaning, receiving, production, processing, storage and transport are not available, there must be documented cleaning procedures including the quantity of product required for bleed or purge runs if appropriate between use for GMO or potential GMO inputs and use for CNGMO products. A record of cleaning must be kept.

3.0.2.1 A risk assessment must be carried out to demonstrate lack of contamination (e.g. cleanliness). If contamination is found, action must be    taken to mitigate risk.

3.0.3     Products certified under the CNGMO programme must not be mixed and must be identifiable in storage.

Note: Storage standards apply to unprocessed and processed products in all programmes.

4.0 TRAINING

4.0.1      Employees handling CNGMO products must be fully trained for the tasks they are carrying out. Records of the training must kept.

4.0.1.1 At minimum, employees must receive initial and annual refresher training.

4.0.2      Employees handling CNGMO products must be aware of these standards and understand the importance of maintaining traceability of AGW products through the production cycle.

5 FURTHER PROCESSING

5.0  Recordkeeping

5.0.1      There must be records to demonstrate the non-GMO status of ingredients and these must cover all stages of distribution and processing.

5.0.2      Records must ensure that AGW-certified products can be traced from arrival at the brand, distributor or processor’s site through processing to their final destination.

5.0.2.1 Records ensure an input/output balance can be carried out on CNGMO products.

5.1 Receipt of goods

5.1.1      A list of current suppliers along with current copies of their Certified Non-GMO by AGW, equivalent certificate or non-GMO declaration must be held on file.

5.1.2     Goods received must be verified at the point of delivery.

5.1.3     Products bearing the logo must be listed on the AGW certificate.

5.1.4     Records of goods received need to include invoices, delivery notes, supplier details, product details, quantities, date and batch code. They must be clearly identified as CNGMO.

5.2 Processing

5.2.1      Processing records must be kept and show ingredients, quantities, date, batch code, and show the amounts of finished product produced.

5.2.2      Finished products must be clearly identified as CNGMO.

5.3          Dispatch

5.3.1      Dispatch records must show product details, quantity, destination, date of dispatch and batch codes.

5.3.2      Invoices and packing slips must show that products are AGW certified.

5.4  Food safety and other regulation

5.4.1      Food safety protocols must be in place and implemented.

5.4.2      If any food safety issues are recorded with AGW products e.g. from microbiological testing, the supplier and the AGW office must be informed immediately.

5.4.3     Recall procedures must be in place.

5.5 Approving processed products

Approval of logo use is guided by AGW’s Logo Use Guidance for Certified Operators, available in the AGW Policy Manual.

5.5.1      The specification for processed AGW certified products must be approved before production begins.

5.5.1.1   The specification must include the supplier, product name, ingredients, additives, processing aids, the AGW status of the ingredients and details of the production process.

5.5.2      If the product specification changes, such as using a new supplier or a different ingredient, an updated specification must be approved by AGW before production begins.

5.5.3      If 100% of the ingredients or fibres used in a finished product are from certified sources, the relevant logo(s) can be used on the label and the entire product can be marketed as certified with no qualifiers.

Note: All single ingredient processed products must be approved by AGW prior to logo use. A Single Ingredient Specification Form must be on file with AGW.

5.5.4      Further processed products labeled as CNGMO must not contain any GMO ingredients, flavourings, seasonings, colourings, additives or any other substance present in the final product.

5.5.5     A further processed product must not make any logo claim to contain CNGMO products unless the entire finished product is CNGMO.

Note: All multi-ingredient processed products must be approved by AGW prior to logo use. A Multi-Ingredient Specification Form must be on file with AGW.

5.5.6      Ingredients purchased must either be accompanied by a non-GMO declaration from

the supplier or carry a non-GMO certification from a programme at least equivalent with the requirements of the CNGMO programme.

6 TESTING AND RISK

6.0 Testing for High Risk Products

6.0.1      If there is a risk that inputs or ingredients used to produce CNGMO products are GMO or are contaminated by GMO material, samples must be tested.

Note: This could include products that are otherwise classed as “low-risk” that have (for example) come from sources with previous contamination incidences.

If a viable commercial test is not available, other forms of validation may be considered on a case-by-case basis.

AGW recognises testing of finished product may not effectively identify all cross- contamination events. AGW may accept valid documentation in lieu of testing samples on a case-by-case basis.

6.0.2      Polymerase chain reaction (PCR) testing must be used for high-risk inputs and ingredients used in the production of CNGMO products.

6.0.3      If PCR tests are used, they must be conducted using equipment where the limit of detection is 0.01%.

6.0.4      If qualitative PCR tests prove positive, the samples must be submitted for quantitative PCR testing.

Note: Quantitative tests provide an assessment of the level of GMO DNA in a sample.

6.0.4.1 For quantitative PCR analysis, laboratory test results must indicate sufficient DNA presence of the high-risk input or ingredient for test results to be valid.

6.0.5      Testing of high-risk inputs, ingredients or products containing high-risk inputs when those are accompanied by valid non-GMO documentation must occur at least quarterly. See standards 5.1.1 and 5.1.2.

6.0.6      Testing of high-risk inputs, ingredients or products containing high-risk inputs that are not accompanied by valid non-GMO documentation must occur with every batch bought.

Note: If no high-risk inputs are used routine testing is not required. (See 6.0.1)

6.0.7      High risk products must be tested at least annually by an ISO 17025 accredited laboratory, using methods within the scope of that accreditation.

Note: The auditor will collect random sample(s) at initial or annual audit, spot audit or other unannounced visits and submit these for laboratory testing. The number of samples will depend on the number of risk ingredients and storage points on farm.

6.0.8      If high-risk products are used, whether as individual products or as part of a blend, a non-GMO declaration or valid non-GMO certificate must be provided by the supplier.

Note: A non-GMO declaration does not replace the requirement to test.

6.0.9      Operators must accept the risk rating as determined by A Greener World and conduct applicable testing.

6.0.10    For crops, every at-risk seed lot should be tested annually via a PCR test done on a representative sample as determined by the ISO 17025 accredited laboratory.

6.0.11    Where the presence of GMO material is adventitious or technically unavoidable the          action thresholds must not be exceeded. The action thresholds are as follows:

• Seed 0.1%
• Animal feed and supplements 5.0%
• Food ingredients 0.9%

Note: If the presence of GMO material is deliberate or could have been avoided, there is no tolerance for any contamination.

6.0.12 Documentation of disposition of non-compliant product must be kept.

6.0.13    AGW must be notified of any test result exceeding the action threshold(s) and the corrective actions taken. (See Standard 5.0.8)

6.0.14    Anyone carrying out testing must be trained and demonstrate proficiency in the method of testing by a qualified expert.

6.1 Testing protocols

See appendix for lists of high and moderate risk crops/feeds.

6.1.1      Each operation must have an implemented, written testing protocol.

6.1.2      The protocol must cover high risk inputs and ingredients and must include:

6.1.2.1 A risk analysis of all inputs and implemented procedures to mitigate risk (See Appendix 1 to determine risk).

6.1.2.2 The ingredients used by the facility in the production of CNGMO products.

6.1.2.3 The types of testing used by the facility (e.g. qualitative PCR, quantitative PCR) and which tests are used for which products and why.

6.1.2.4 The frequency of testing.

6.1.2.5 The tolerances for detection of GMOs and the action taken when samples exceed these.

6.1.2.6 The volume and use of high-risk products.

Note: Facilities that only feed or process low-risk inputs or ingredients do not need to have a testing protocol.

6.1.3      The testing protocol must be reviewed and revised as necessary, at least annually.

6.1.4      The protocol must detail the process that is followed when these thresholds are exceeded.

7.0 LABELING

7.0.1      Products approved under the CNGMO module can be labeled as Non-GMO* or Non-GE*.

7.0.2      The phrases “no GMOs”, “no GEs,” contains “zero GMOs,” and contains “Zero GEs” must not be used.

7.0.3      If there is a need for consumer education or to provide accurate information about genetic modification in food, a phrase indicating that the product in question is not     known to be genetically modified must be clearly legible somewhere on the packaging.

8.0 TRACEABILITY

8.0.1      Producers must use the applicable logo on certified products unless otherwise agreed with AGW.

8.0.2      Records must ensure an input/output balance can be carried out on a product with an AGW logo and must be retained for at least two years.

8.0.3      AGW must approve logo use prior to certified sales.

9.0 COMPLAINTS

9.0.1      A complaints record relating to complaints about CNGMO certified livestock or products must be maintained and be available at annual inspection. The record must list both the complaint and the action taken by the farm or business.

Note: CNGMO is accredited to ISO 17065 and it is a requirement of our certification that those within the programme maintain a record in the rare event that any complaint is made. AGW does not expect that farms or other businesses in the programme will receive complaints about their certified livestock or products, but if any are received they must be recorded along with the response from the farm or business.

Appendix 1 – High, Moderate and Low Risk Products

High-risk products are those products that are genetically modified and grown on a large scale. High-risk products include the following crops that are commonly found in animal feeds either as the harvested crop or as a by-product.

• Soy (and soy products)
• Maize and Sweet Corn
• Canola
• Beets (which may be used for molasses based mineral licks and tubs)
• Alfalfa
• Cotton (and cotton products)
• Creeping Bentgrass
• Kentucky Bluegrass
• Papaya
• Zucchini and yellow summer squash
• Eggplant
• Rice

High-risk products also include the following, though these are much less likely to be found in feed or other inputs or additions to CNGMO livestock products.

• Salmon
• Orange
• Sugarcane
• Tomato
• Potato
• Pineapple
• Apple
• Mushroom
• Spider Silk
• Cowpeas
• Pigs (GalSafe)
• CRISPR gene-edited pigs (PRRS virus)
• Cattle (PRLR-SLICK)
• Purple (Galaxy) Tomato
• Banana (QCAV-4)
• Firefly Petunia
• Brown Mustard
• Hemp (Badger G)
• K. rhaeticus

Products otherwise listed as low or moderate risk will be considered high-risk if imported from the following countries:

• China
• Egypt
• Kazakhstan
• Moldova
• Russian Federation
• Turkey
• Ukraine
• Vietnam

Moderate risk products include the following:

• Camelina (false flax)
• Flax
• Beta vulgaris,(e.g., chard, table beets)
• Brassica napa (e.g., rutabaga, Siberian kale)
• Brassica rapa (e.g., pak choy, mizuna, Chinese cabbage, turnip, rapini, tatsoi)
• Curcubita pepo (e.g., acorn squash, delicata squash, patty pan squash, pumpkin, and spaghetti squash)
• Banana
• Hemp
• Cannabis
• Lettuce
• Peanuts
• Wheat
• Oats

Low risk products are those for which no genetically modified version is known, or where the only genetically modified versions are used solely in controlled/laboratory conditions and are not in commercial use and where there is no risk of cross-contamination with other GMO crops.