GMO Tests for Compliance with EU Legislation


Exporters to the European Union (EU) need to know how to comply with regulations regarding genetically modified organisms (GMOs). Three important points that exporting manufacturers should consider when sending their food products to the EU market are as follows; GMO labeling, GMO authorization and GMO testing.

GMO Tests for Compliance with EU Legislation

The EU was one of the first regions in the world to regulate the use of GMOs. Regulations (EC) 1829/2003 and 1830/2003 have been in force since April 2004.

EU regulations require “genetically modified” labeling for food products consisting of, containing or produced from GMOs. To avoid this mandatory labeling requirement, exporters to the EU must be in a position to demonstrate that they have taken appropriate steps to avoid the presence of GMOs.

EU rules require traceability of food ingredients to their source materials. A well-documented traceability and identity protection (IP) program can take reasonable action and due diligence to keep GMOs out of a product.

With such a system in place, any trace of GMOs could be considered "surprise" or "technically unavoidable".

The GMO rate should not be higher than the threshold determined in the standards. Although a producer refrains from using GMOs in food, genetically modified material may be present in trace amounts due to the accidental or technically unavoidable presence during seed production, planting, harvesting, transportation, storage or processing.

For this reason, the EU has set a GMO threshold of 0,9% per ingredient to enforce the mandatory labeling requirement. "Genetically modified" labeling is not required unless the percentage of GMOs is higher than 0,9% per component, provided that the presence of any GMOs is "unacceptable" or "technically unavoidable".

Before a GMO can be used in food on the EU market, it must first be authorized by the EU for that purpose. The authorization process includes a scientific assessment followed by a risk management decision. Authorized GMOs can be used in foods throughout the European Union.

EU authorized GMOs can be used in food at any level, but subject to the labeling requirement described above. GMOs not authorized by the EU cannot be used in food in the EU because the EU has zero tolerance for non-permitted GMOs.

GMO Testing

To check compliance with EU regulations and meet contract specifications, many exporters test each batch of product before exporting to the EU. Exporters usually send samples to an accredited laboratory that uses the Real-Time PCR (polymerase chain reaction) testing method.

This is the GMO testing method used by EU authorities for surveillance testing and is the method used worldwide to validate contracts and ensure regulatory compliance.

To determine the GMO percentage of a product/ingredient, exporters use Quantitative PCR analysis. Quantitative test results show the percentage of GMOs for a particular type, such as soy. 

Example: If a sample is tested to determine the percent GMO content of soy flour, a positive test result may be "0,7% GMO based on total soy DNA".

Please note that quantitative PCR analysis requires a sufficient amount of DNA. For example, instead of testing refined soybean oil, testing can be done on a precursor; crude oil or the soybean batch from which the oil is derived. The test results can then be linked to the refined oil content with lot-specific traceability records.

To check for the presence of a non-EU GMO, exporters use Qualitative PCR analysis. The detection limit of the PCR method is generally accepted as 0.01%. 

Example: If a particular GM corn strain has been commercialized in the US but has not yet been authorized by the EU, an exporter may need to test it. Qualitative rather than Quantitative analysis is appropriate as the EU has zero tolerance for any unauthorized GMOs in food.

GMO Testing Laboratory Selection

To best meet your GMO testing needs, choose a lab that provides:

Accurate test results; The hallmarks of a technically competent GMO testing laboratory include ISO 17020 accreditation, optimized methods for processed and multi-component samples, and many years of experience in GMO testing.

Knowledgeable customer service; Experts at an experienced GMO testing lab can help you choose the appropriate GMO testing plan for your particular crop and/or situation.

Do not hesitate to contact our expert team to get detailed information about the GMO Free and NON GMO label and certification, or to apply for certification.