GM Free Certification Scheme
for Businesses and Products
Current Draft as at 1/11/99 by Robert Vint
CONTENTS
2. How applicants can become registered symbol-users
3. How manufacturers who are not registered symbol-users can register brands
4. How the scheme can be administered and monitored
5. How the scheme can be financed
6. How the scheme can be promoted
7. Product standards and registration criteria
8. Symbols, Guarantees, Policy Statements, Letters and Contracts
1. AIMS AND OBJECTIVES
Customer pressure had led to a demand for a clear means to identify products and food outlets that avoid all GM ingredients, derivatives and processes. To provide such an indication it is necessary to set a consistent national standard throughout the wholefood sector - and preferably the food sector as a whole. For such a standard to be respected it must be implemented using recognised and reliable procedures that are independently monitored.
For any registration scheme to work it will need to be an asset to all the participants. To increase sales and the number of customers any symbol displayed must have a clear meaning and carry status and credibility. The scheme must not impose an excessive financial or administrative burden on participants or GFA but must be self-financing through the levying of an appropriate membership fee.
Because of the very high cost of DNA testing and the need to test every batch of a product when using this technique it is felt that this procedure could not be used on a regular basis for small businesses in the wholefood sector. The affordable alternative is to set up procedures to ensure that food ingredients are traceable down up the chain of supply to ensure that they come from identity-preserved non-GM sources and that this guarantee can be provided at each link in the chain. Occasional DNA testing could be used on a spot check basis and where there were concerns about the validity or guarantees.
2. HOW APPLICANTS CAN APPLY FOR A GM-FREE SYMBOL LICENCE
RETAILERS AND WHOLESALERS pay a membership fee (of £60 for retailers and £400 for wholesalers/importers) to join GFA. Members who are ready to register as GM-Free and use the GM-Free Business symbol receive an application form, instructions for participation and a list of GFA approved GM-Free manufacturers, brands, wholesalers and importers.
Before and during registration as symbol-users the retailers and wholesalers will check all orders and incoming stock by the following simple procedure:
a) By ordering stock from a GFA approved GM-Free supplier
b) Where a non-approved supplier is used, brands and products are checked against the GFA list [All organic produce (except possibly honey) is assumed to meet GFA criteria]
c) Where a product from a non-approved supplier is not indicated as approved, they may either ask GFA to obtain a guarantee from the manufacturer or obtain one themselves using a standard GFA letter.
Additionally, applicants will require all suppliers who are not GFA symbol-users to sign a guarantee that all products supplied meet GFA criteria.
Finally, a series of supplementary precautions will be taken by the applicant to ensure that mistakes and misunderstandings with suppliers are avoided (see section 4)
Once these steps have been taken and all stock has been selected using these procedures the applicant will receive window stickers, artwork and logos for use on their stationery, a policy statement to display, listing in GFA guides and directories and, if possible, in trade publications.
Symbol-users agree to undergo occasional inspections and any registered user who supplies other registered users is committed to inform these customers should they lose their GFA status.
MANUFACTURERS pay a GFA membership fee (of £400) and are then entitled to apply to be registered as GM-Free and to display the GM-Free Business symbol. They will receive an application form and copies of guarantees for their suppliers to sign.Before and during registration as symbol-users the manufacturers will check all orders and incoming ingredients by the following procedure:
a) By obtaining written guarantees from all relevant suppliers that all potentially GM ingredients are traceable to identity-preserved non-GM sources and that due diligence is being exercised in preventing accidental contamination with GM or unsegregated ingredients.
b) By obtaining confirmation that their suppliers have written guarantees to this effect from the original producer of the ingredients.
Finally, a series of supplementary precautions will be taken by the applicant to ensure that mistakes and misunderstandings with suppliers are avoided (see section 4)
Once these steps have been taken and all stock has been selected using these procedures the applicant will receive window stickers, artwork and logos for use on their stationery, a policy statement to display, listing in GFA guides and directories and, if possible, in trade publications. They will also be provided with the GFA GM-Free Product logo that may be used on all products that meet GFA criteria.
Symbol-users agree to undergo occasional inspections and any symbol-user that supplies other symbol-users is committed to inform these customers should they lose their GFA status.
3. HOW MANUFACTURERS WHO ARE NOT REGISTERED AS GM-FREE BUSINESSES CAN REGISTER INDIVIDUAL BRANDS
MANUFACTURERS do not have to be registered as GM-Free Businesses in order to register individual products or lines as "GM-Free to GFA Standards".
For administrative reasons (such as providing a guide that is short and easy for retailers to use), GFA will approve brands (and possibly lines within large brands) but not individual products from a brand that includes non-approved items. There will be no fee for brand registration. If a manufacturer wishes to register an individual product, this can be arranged for a fee of £50.
Manufacturers request a brand application form from GFA [GFA will also be proactive in contacting likely producers of GM-Free brands].
Prior to registering their brand, manufacturers will require all the suppliers of potentially GM ingredients for the products concerned to sign a GFA guarantee that they have carried out for the brands concerned the procedures required for manufacturers to become symbol-users described in section 2 above.
Once the manufacturer can provide assurance that all products under the brand name have been checked according to GFA criteria they return the application form and receive a logo to use on the products and in adverts for that brand (only) and a listing of the brand in the GFA directory.
4. HOW THE SCHEME CAN BE ADMINISTERED AND MONITORED
HOW WHOLESALER AND RETAILERS REGISTERED AS GM-FREE SHOULD ENSURE THAT STOCK MEETS GFA CRITERIA
a) GFA will endeavour to provide a comprehensive list of manufacturers, importers, wholesalers, brands (and individual products where a manufacturer has paid for these to be listed) that meet GFA criteria. A secondary list of products not meeting GFA criteria will also be provided (this will include items where a producer has consistently failed to guarantee that they are GM-Free). A full list will be provided to registered GM-Free Businesses and applicants, together with regular updated. Updates will also be e-mailed, published in trade magazines and displayed on the website. The provision of this information by GFA does not obviate the requirement of the symbol-user to exercise due diligence in avoiding suspicious products.
b) Registered GM-Free Businesses and applicants may ask GFA to check unlisted products
c) For situations where a guarantee is urgently required, the business will be supplied with copies of a standard GFA enquiry form that they can fax or post to manufacturers. This will ask the manufacturer to sign the guarantee and return it to the symbol-user, with a copy to GFA.
ADDITIONAL PRECAUTIONS AND REQUIREMENTS
a) Wholesalers and retailers must send all existing and future suppliers (except where these are GFA registered businesses) a copy of their GFA purchasing policy and require that the supplier signs a standard GFA letter confirming that all orders will be checked to ensure that they meet these criteria. The signed letters must be stored on the premises and be available for inspection.
b) As soon as a symbol-user realises that they may be unable to continue abiding by GFA regulations they must inform GFA
c) All order forms must carry a brief statement that "Items ordered will only be accepted and paid for if they are GM-Free to GFA standards"
d) A GFA Policy Statement must be clearly displayed at the symbol-user's premises and copies of the full GFA policy must be available on request.
e) Wholesalers and retailers must sign up to the "Five Year Freeze" campaign.
HOW MANUFACTURERS OF CERTIFIED PRODUCTS SHOULD ENSURE THAT THESE MEET GFA CRITERIA
ADDITIONAL PRECAUTIONS AND REQUIREMENTS
a) Should a manufacturer reformulate or intend to reformulate any certified product in a way that may remove its GFA status they are obliged to inform GFA of this matter.
HOW GFA CAN MONITOR COMPLIANCE OF REGISTERED BUSINESSES WITH GFA STANDARDS
It will be necessary to check that products sold by registered wholesalers and retailers meet GFA criteria and that the ingredients used by registered manufacturers meet these criteria.
GFA would recruit a network of volunteer inspectors from local GM campaign groups. Inspectors would be given basic training by correspondence and telephone and be provided with guidelines and an inspection card. Inspectors would be informed that they are providing a service to help retailers - and not to intimidate them!
MONITORING REGISTERED RETAILERS, WHOLESALERS AND IMPORTERS
Inspection of paperwork and discussion with the manager must be by appointment with advance notice and be held at a time convenient for the manager. The following should be subject to inspection: stock, general guarantees signed by all suppliers, specific guarantees from manufacturers of unlisted products where these have not been obtained via a GFA approved wholesaler / importer.
Products on sale in registered retail outlets may be monitored at any time. Any items that clearly violate GFA criteria can be brought to the attention of staff.
MONITORING REGISTERED MANUFACTURERS
Inspection of paperwork and discussion with the manager must be by appointment with advance notice and be held at a time convenient for the manager. The following should be inspected:
MONITORING MANUFACTURERS OF GFA APPROVED PRODUCTS WHO ARE NOT REGISTERED SYMBOL-USERS
Inspection of paperwork and discussion with the manager must be by appointment with advance notice and be held at a time convenient for the manager. Checks would be restricted to the potentially GM ingredients used in the registered products (eg TVP in readymade meals or oil dressings on dried fruits). The following should be inspected: Guarantees from suppliers - and copies of guarantees from their suppliers where relevant, copies of letters notifying all relevant suppliers of the manufacturer's GM-free policy and GM-Free certification documents where primary soya or maize products are used.
Spot DNA checks may be carried out on the products of registered manufacturers and on individual registered products at the discretion of GFA.
5. HOW THE SCHEME CAN BE FINANCED
The scheme would be self-financing and operate on a non-profit basis. The priority would be upon providing a meaningful guarantee to customers at the minimum possible cost to symbol-users.
PROPOSED MEMBERSHIP FEES
Fees payable by standing order
FEES FOR NON-MEMBERS:
BRAND REGISTRATION FEE = Free
INDIVIDUAL PRODUCT REGISTRATION FEE = £50 (where the brand as a whole is not GM-free)
6. HOW THE SCHEME CAN BE PROMOTED
Three steps are recommended in the promotion of the scheme:
a) OBTAINING FORMAL SUPPORT FROM PUBLIC AND PROFESSIONAL BODIES (including the supporters of the Five Year Freeze campaign and consumer and food groups)
b) PROMOTING THE SCHEME AMONGST RETAILERS, WHOLESALERS AND MANUFACTURERS (using trade media and the wholesalers distribution channels)
c) PROMOTING THE SCHEME TO CUSTOMERS AND THE GENERAL PUBLIC (using the daily papers and relevant magazines)
7. PRODUCT STANDARDS AND REGISTRATION CRITERIA
REGISTRATION CRITERIA
RETAILERS, WHOLESALERS AND IMPORTERS, to be registered as GM-Free, must ensure that all general food products that they buy, sell or advertise, meet GFA standards. Standards for supplements and additional standards for honey and animal produce will apply from a later date.
MANUFACTURERS, to be registered, must ensure that all their supplies and products meet GFA standards. Standards for supplements and additional standards for honey and animal produce will apply from a later date.
PRODUCT STANDARDS
GENERAL FOODS will be classified as "GM-Free to GFA Standards" where the manufacturer can provide a written guarantee that they have:
a) been manufactured without the use of GM ingredients, derivatives or processes
b) that they have written guarantees from suppliers that all relevant ingredients are from identity-preserved supplies that are traceable to source and
c) that they have exercised due diligence in ensuring that no accidental contamination may have occurred.
ANIMAL PRODUCE, including meat, milk, cheese and eggs, will be classified as "GM-Free to GFA Standards" where the producer can provide a written guarantee that:
a) they have written guarantees from feed suppliers that all feed supplied is from identity-preserved non-GM sources
b) no animals have been injected with GM growth hormones (such as rBST - bovine somatotrophin)
c) that they have exercised due diligence in ensuring that no accidental contamination may have occurred.
HONEYS AND HONEY PRODUCTS will be classified as "GM-Free to GFA Standards" where the manufacturer can provide a written guarantee that they:
a) do not contain honey from any country where the precise location of GM crops is not in the public domain
b) do not contain any honey from a hive within 4 miles of a GM crop
c) do not contain any honeys that are not traceable to source
NB. This appears to be the only product category where we cannot rely upon Organic certification as a guarantee that the product meets the proposed GFA criteria.
[Notes: Consultation with the Soil Association, National Pollen Research Unit and the New Zealand Natural Food Company (honey importers) suggests that there is a consensus that bees collect pollen within a 4-mile radius of their hive.]
SUPPLEMENT BRANDS will be classified as "GM-Free to GFA Standards" where the manufacturer can provide a written guarantee that all products in the brand have:
a) been manufactured without the use of GM ingredients, derivatives or processes
b) that they have written guarantees from suppliers that all relevant ingredients are from identity-preserved supplies that are traceable to source and
c) that they have exercised due diligence in ensuring that no accidental contamination may have occurred.
8. SYMBOLS, GUARANTEES, POLICY STATEMENTS, LETTERS AND CONTRACTS
It is recommended that GFA only use the phrase "(Certified) GM-Free to GFA Standards" as the phrase "GM-Free" alone has no defined meaning and is opposed by the Consumers Association, the Soil Association and MAFF.
POLICY STATEMENT
We oppose the use of Genetically Modified ingredients, derivatives and processes in food and support the call for a Five Year Freeze on the use of etc etc …
[THIS STORE] IS CERTIFIED GM-FREE TO GFA STANDARDS
[This Store] is certified as GM-Free by Genetix Food Alert and is thereby committed to taking all reasonable steps to ensure that every product purchased, advertised or sold in this store is produced without the use of GM ingredients. We have checked that all products etc etc …
HOME| Search_Product_Database | GM_Products | GM_Free_Products | GM_Food_-_what_is_it? | GM_ingredients | Supplements | News | Organic_Food | GFA_Campaigns | Joining_GFA | Members | Members'_Resources | GM_Free_Certification | Links
|
Genetic Food Alert
4 Bertram House, Ticklemore St, Totnes, Devon TQ9 5EJ Tel: 01803 868523 info@geneticfoodalert.org.uk |