Discussion Paper

Voluntary GM-Free Labelling

April 2003 

Previous Page / Table of Contents / Next Page

6. Labelling System

• 6.1 Overview
• 6.2 Verifying Claims
• 6.3 Standardised Label

Summary

This section introduces the idea of a "labelling system" to support a GM-free label. It discusses:

• The necessary relationship between what is contained on a label and the processes that verify identity-preservation and product-tracing mechanisms for "GM-free" food.
• Whether identity-preservation and tracing mechanisms for imported food provide a sufficient level of verification for suppliers to make "GM-free" claims.
• The possible role a labelling system can play in supporting a standardised label.

6.1 Overview

Because of the difficulty of establishing whether a food is "GM-free", both the Commerce Commission and Food Standards Australia New Zealand recommend that suppliers making "GM-free" labelling claims be able to provide reliable evidence that genetic modification production processes have not been used and that steps have been taken to segregate GM materials.

The purpose of a labelling system is to support a label by providing an assurance that the labelling claim on a product is meaningful and accurate through setting out appropriate supply, manufacturing and administrative procedures. It underpins in a reliable and authoritative way the claims made on the label.

A system for a "GM-free" label is likely to include a means of verifying identity preservation.[9] This is a procedure that requires segregation of GM food throughout the supply chain (for example, at seed, farm, handling and distribution, processing, manufacturing, and retail levels) to prevent contamination of "GM-free" food. The labelling system is also likely to include product-tracing mechanisms that provide documentary evidence that at each stage of the production process only "GM-free" food and food ingredients have been used.

6.2 Verifying Claims

Applying identity-preservation and product-tracing processes to the development of a "GM-free" labelling system raises a number of technical issues. New Zealand is an importer of food and food ingredients from countries with commercial GM crops. Identity-preservation systems for imported food will be based around the country-of-origin's definition of GM-free and its mandatory labelling requirements. These systems may not, particularly if the food is from North America, be the same as the definition of "GM-free" under the Fair Trading Act.

Developing a labelling system in New Zealand that includes identity-preservation and product-tracing elements will require consideration of whether the level of verification provides sufficient confidence to make a "GM-free" claim under the Fair Trading Act - that is, has identity preservation been designed to support an absolute interpretation of "GM-free", and does it exclude food from a genetic modification process?

The use of an identity-preservation process that provides a thresholdfor accidental contamination to support a "GM-free" label would not provide a defence for a breach of the Fair Trading Act (under Section 44 relating to the taking of reasonable precautions). For example, the British Retail Consortium and Food and Drink Federation have developed a voluntary technical standard for the supply of identity-preserved maize and soya to support the European Commission Novel Food Regulations. It provides a 1% accidental contamination threshold, and so could not be used as the basis for "GM-free" claims in New Zealand.

6.3 Standardised Label

A labelling system could prescribe the form and contents of a standardised GM-free label for the voluntary use of those suppliers that meet the system's requirements. This would allow suppliers who consider that there is a market advantage in sharing the same label to do so, while leaving other suppliers who use the system free to make their own claims.

Alternatively, the system could be designed in such a way that all users of the system are required to use the same label. An administrative body could licence use of the labels (see Section 7 for a more detailed discussion of this). For example, suppliers with products certified against Heart Foundation performance criteria are licensed to use the "Pick the Tick" label.

In either case, a standardised label could be supported by publicity and marketing on behalf of all suppliers who use the system - including additional information to support a GM-free symbol or alternative GM-free terminology.

Questions for Submitters

• What features should a labelling system provide?
• What identity-preservation and product-tracing mechanisms should a labelling system be based around?
• Should a labelling system provide for a standardised label?

[9] There is seemingly no internationally agreed definition of identity preservation, but the concept essentially refers to any system of crop or raw-material management that segregates or preserves the identity of the source or nature of the materials. Broadly, "segregation" is synonymous with keeping crops and products apart, whereas "identity preservation" is taken to apply to a positive desire to preserve the original identity source of a crop or product.