Discussion Paper

Voluntary GM-Free Labelling 

April 2003

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1. Introduction

• 1.1 Overview
• 1.2 Purpose of this Paper

1.1 Overview

The Royal Commission on Genetic Modification identified consumer demand for more information than the Joint Australia New Zealand Food Code requires about whether a food results from a genetic modification process, or contains any GM material. Following consideration of the Royal Commission's recommendations, the government directed an interdepartmental working group, consisting of the Ministry of Consumer Affairs and the New Zealand Food Safety Authority, to facilitate the development of a voluntary "GM-free" labelling system.

Readers should note that throughout the paper the term GM-free with speech marks ("GM-free") means the complete absence of any genetically modified material, or use of a genetic modification process, in a food or food product. This interpretation is based on the Commerce Commission's guidance. Where no speech marks are used, the term GM-free may convey a less strict interpretation. For example, it may encompass other representations such as "best endeavour to be GM-free".

As it is a voluntary initiative, responsibility for developing a successful GM-free labelling system ultimately rests with stakeholders. The role of the interdepartmental working group is to assist by identifying issues and options, analysing submissions received from this paper, and co-ordinating interested suppliers, consumers and consumer groups in their efforts to develop a labelling system. The working group's role does not extend to developing or funding a labelling system itself.

1.2 Purpose of this Paper

This paper is intended to provide a starting point to help stakeholders develop a GM-free labelling system. It does this by:

• setting out the issues around defining what "GM-free" might mean
• identifying the legal parameters within which "GM-free" claims may be "tested" under the Fair Trading Act 1986 and also within which a labelling system must be developed
• examining some of the reasons why consumers and suppliers may wish to become involved in developing a labelling system, and using these to identify what information a labelling system could (or should) provide
• looking at labelling as a tool to provide consumer information, and the specific issues associated with the use of a "GM-free" label
• looking at the purpose of a labelling system
• presenting possible options for a labelling system
• introducing some of the issues that should be considered when looking at possible labelling systems.

As they work through this paper, readers will realise that the successful development of a voluntary GM-free labelling system depends on obtaining the support of those stakeholders that have the capacity, expertise, or financial resources to engage in developing a labelling system. This may not be an easy task. During the period over which this paper has been researched and written, the interdepartmental working group has identified only one group developing (or looking to develop) a voluntary GM-free labelling system in New Zealand - the National Consumers Food Safety Network.

By releasing this paper, the working group hopes to stimulate discussion amongst stakeholders on the merits of developing a voluntary GM-free labelling system, and, from submissions received, identify those stakeholders willing to contribute to its development.