New GM rules set to confuse
So you've implemented systems to comply with the new genetically modified (GM) traceability and labelling legislation, potentially altering your supply chain to ensure you have no requirement to label ingredients as 'produced from GMOs'.
If you've extended this to all ingredients produced from GM micro-organisms, such as vitamins or other additives, you may be a little frustrated at the decision made at the Standing Committee meeting in September to exclude some ingredients from the scope of European Commission regulation 1829/2003.
The Food Standards Agency guidelines, which group the production of lecithin from soya (a straightforward processing product) with that of riboflavin (a complex fermentation process consisting of several stages, different substrates and in-situ reactions) demonstrates a general lack of understanding of this area.
The key points to note from the September meeting are:
1. products generated by fermentation processes where the GM micro-organism is not present in the final food or feed are outside the scope of 1829/2003 (ie, riboflavin and enzymes are now outside the scope)
2. products generated by fermentation processes where the GM micro-organism is present in the final food or feed, whether alive or not, are within the scope of 1829/2003 (ie, yoghurt produced by GM starter cultures, and probiotics).
It ignores the complex facets of different fermentation processes, for example, beer produced by Swedish brewers Österlenbryggarna, utilising GM corn, which triggered the requirement to label. How about bread made with a GM yeast present in the final product -- is this an ingredient or a processing aid ... within or outside the scope of 1829/2003?
There is also the question of which legislative framework now encompasses food products of GM fermentation. Previously under the Novel Foods Regulation, temporarily under 1829/2003, they are now covered by neither. Confused? You will be!
Jean Feord Business Manager
for Legislation,
Leatherhead Food International.
