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OTA submits comments on GMO labeling standard

OTA submits comments on Proposed National GMO Food Disclosure Standard

The Organic Trade Association (OTA) submitted its final comments to the U.S. Department of Agriculture (USDA) on the establishment of national mandatory GMO labeling standard (National Bioengineered Food Disclosure Standard). OTA thanks its GMO Labeling Advocacy Task Force for their dedicated time and efforts that informed OTA's comments to safeguard organic as the gold standard for transparency and non-GMO status. We also extend our appreciation to the task force co-chair, Colin O; Neil, Legislative Director of the Environmental Working Group (EWG), for his representation of EWG and Just Label It (JLI) and work to integrate our efforts. To read background on the topic as well as view the full text of the law, the proposed rule and corresponding USDA policy, visit USDA’s GMO Disclosure & Labeling web page.

OTA’s Top Messages

Consistent with Law (Pub. L. 114-216), we request a final rule that will put into action the following key organic provisions:

  • No USDA-NOP certified products will require disclosure as ‘bioengineered’;
  • USDA shall consider organic certification sufficient to make a claim regarding the absence of bioengineering in the food, such as “not genetically engineered,” “non-GMO,” or another similar claim;
  • The final rule should clearly state that products exempt from mandatory disclosure as "bioengineered" foods, such as milk from cows fed genetically modified feed, may not by default automatically qualify for an "absence” claim solely because the food is not required to bear a disclosure;
  • The definition of the term ‘bioengineering’ shall not affect the definition of “excluded methods” or any other definition under USDA’s National Organic Program; and
  • The requirements set under the bioengineered food disclosure will not require that any modifications be made to the USDA organic regulations.

We also urge USDA to:

  • Use its authority and broadly interpret the definition of “bioengineering” to include highly refined products such as oils or sugars derived from bioengineered crops;
  • Recognize and allow common terms and shorthand that industry and consumers understand, such as “genetic engineering,” “genetically modified,” “not GE,” and “non-GMO;”
  • Adopt symbol disclosure options that 1) utilize acronyms that consumers are familiar with such as “GE” or “GMO,” and 2) are consistent with the non-bias (neutral) stylistic tone of other AMS logos;
  • Adopt a threshold for inadvertent or technically unavoidable bioengineered DNA that is consistent with the level adopted by other major trading partners (no more than 0.9% of the specific ingredient).

Read our final comments and contact Gwendolyn Wyard with questions.

OTA's Position on GMO Labeling                  Final Comments on GMO Food Discolsure Standard    Final Comments to USDA on GMO Labeling Questions


Gwendolyn Wyard
Vice President of Regulatory and Technical Affairs