The CSS Executive Team was able to spend several hours with the entire Non-GMO Project Board including the SOC (Standards Oversight Committee) at their annual retreat last month. We were welcomed warmly and had a very engaging and well-received dialogue. CSS expressed our desire to continue to work with the Project in order to ensure a feasible pathway for dietary supplement verification. The Project reciprocated that desire and has showed renewed focus and interest in understanding the DS ingredient supply chain.
The CSS Executive Team has been meeting bi-weekly with the Non-GMO Project Team. We are excited to report we are making great progress on many issues. Tools are being created that will specifically aide dietary supplement companies in attempts to gain adequate documentation. We are optimizing communication pathways between the Project, the TA's and our coalition members. And through detailed education of our supply chain, we have been able to discuss changes to the NGP Standard that will ensure feasible pathways for Non-GMO-dedicated companies to gain product verification.
Clarification of proposed micro exclusion language for use in version 13 of the NGP Standard due for release in January. Favorable draft revisions include:
- Allowing for a limited scope of review for micro ingredients which will result in approval without the use of a micro exclusion. Expected to make compliance with the 0.9% ceiling more achievable.
- Required micro exclusion usage for substrates and feed is being eliminated.
- GM enzymes and non-viable microorganisms used as micros can be exempted using a micro exclusion allowance.
Compliance with Synthetic Biology declaration requirements for existing approved ingredients has been delayed. NGP preparing a decision tree which limits the ingredients impacted by this requirement. Technical Administrators are expecting this document mid-January and will implement updates immediately.
NGP has temporarily eliminated the requirement that all nutrients used in supplement products are defining.
Vitamin manufacturing categories and accompanying process flow charts have been developed and shared with the NGP.
- NGP has a new appreciation of the complexities of our industry.
- These documents demonstrate the low level GM risk involved in manufacturing of supplement nutrients.
- Will be used as education materials in the upcoming CSS discussions with the NGP SOC.
CSS meetings with SOC to address the more complex issues. Goals are:
- Remove stigma that all supplement product nutrients are defining and that all nutrients are GM.
- Identify compliance pathways by manufacturing category (e.g. fermentation, plant and animal derivatives, non-bio sources, etc.).
- Achieve a reasonable strategy for Country of origin downgrade to low risk due to regional GM growing moratoriums.
- Identify reciprocity with other schemes.
- Provide specific education to facilitate satisfactory compliance pathways for enzymes and probiotics.
Several less complex issues are in stages of resolution by the NGP. Most are expected to resolve satisfactorily.
Expo West meeting being arranged for CSS members. We will be meeting on Wednesday March 9th from 4-6pm pacific time in the MegaFood Marriott Suite adjacent to the Anaheim Convention Center. Room number will be announced upon check in.
NGP continues to commit to working to resolve key issues by Expo. There will likely be some carry over post Expo West. However, the CSS executive team will continue discussions and education with an additional meeting with the Non-GMO Project Standards Board on Friday during the show.
We will continue to provide updates here as needed. Very encouraging progress overall!