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Glossary for Industry
Adventitious Presence
In the case of 'Non-GMO' certification, this refers to the accidental introduction of genetically modified (GM) material or ingredients to a 'Non-GMO' product line. This can happen during processing, shipping and handling and improper cleaning of equipment or other manners, such as the mislabeling of lot numbers.
Compliance with the 'Non-GMO' Standards of CERT ID, as well as with certification plans based on it, helps to avoid such occurrences.
Since the coming into force of the Regulations (EC) ) No. 1829/2003 and No. 1830/2003 (both of 22 September 2003) in the European Union the term of "adventitious or technically unavoidable" contamination with GMOs has assumed a special meaning. No. 1830/2003 is about the traceability and the labeling of products that contain GMOs or are made from them. Products with a GMO content that exceeds a certain threshold (labeling threshold) must be labeled if they were produced after 18 April 2004. Even if these thresholds are not exceeded products must be labeled if the GMO contamination was not "adventitious or technically unavoidable" [Art. 7 and 8 (EC) No. 1830/2003].
CERT ID®Database
As a certification body, CERT ID stores all of its data in a decentralized database, called the CERT ID® Database. Be it inspector audit reports, decisions of the Certification Committee, port facility photographs or a laboratory's Analysis Reports - they all are stored in this database in electronic form.
Those data pertaining to the supply chain of a given CERT ID client are available to this client, again in electronic form. The client company is then able to use these data in the event of a challenge from government authorities, or from any other side, to demonstrate that their production system complies with the CERT ID Standard and satisfies the precautionary principle.
Global Laboratory Alliance®
CERT ID 'Non-GMO' Seal
The CERT ID 'Non-GMO' Seal consists of the Seal itself, above the term 'Non-GMO' and the URL of this website (www.cert-id.com). In agreement with CERT ID, the term 'Non-GMO' may be substituted by an equivalent in another language, e.g. 'Não-OGM' or 'Não-Transgênico'' (both are Portuguese), 'Non-OGM' (French) or 'Non-GVO' (German).
Clients' products certified as 'Non-GMO' may carry a depiction of the CERT ID 'Non-GMO' Seal. All other use infringes on CERT ID's rights to that service mark and will result in legal action, as will the unauthorized use of the name CERT ID.
CERT ID 'Non-GMO' Standard
This is, in written form, the “degree or level of requirement, excellence, or attainment” (The American Heritage® Dictionary) all certified clients of CERT ID have to comply with if they want to become certified as ‘Non-GMO’ and have their products show the ‘Non-GMO’ Seal. The CERT ID Standard consists of several modules that pertain to different industries, such as agricultural producers, food manufacturers, infrastructure (ports, warehouses),etc.
Certification
To certify something means to assure or to confirm that something is true. Certification, as used in CERT ID Certification, means that CERT ID, as a third party certification body, assures that the systems or products certified comply with the criteria that are laid down in a written Standard.
Certification Committee
A group of individuals that are not involved in the inspection or auditing of a particular client make up this committee. Based on the inspectors’ report and other data, they decide whether an application for CERT ID certification is successful.
Contamination
The process of "making something impure or unclean by contact or mixture" is central to the risk assessment within CERT ID 'Non-GMO' certification. The question always present is this: How high is the risk of adventitious contamination at a given point in the supply chain?
Besides adventitious, or accidental contamination, intentional contamination by way of mixing is also practiced. Certain jurisdictions with labeling regulations, such as the EU, do permit a certain level of adventitious contamination. But, contrary to widespread belief in industry circles, intentional contamination is ruled out, even if it stays below the labeling threshold. In other words, some labeling regulations concern themselves with the intention that may be behind the GMO content!
Content Guarantee
The 'Non-GMO' assurance given by CERT ID is not a content guarantee but a process guarantee. This means that CERT ID assures that the systems the company's inspectors have audited comply with the CERT ID Standard and will thus produce only product that complies with the CERT ID Standard as well - with a GMO content well below 0.1%. No certifier can guarantee that every grain, kernel or bean meets this requirement at all times.
This is also recognized, for instance, by the national regulations of many countries, including all EU member states, which require that the so-called precautionary principle be met. This means that a production system must meet "all reasonable precautions.
Dioxin Scandal
This term refers to a feed scandal back in 1999 (see story) that involved a small amount of motor oil accidentally spilled into animal feed in Belgium. This event marks the beginning of a series of food scares that has seriously undermined consumer confidence in some food products – far beyond the borders of Belgium and even Europe.
DNA [DeoxyriboNucleic Acid]
A nucleic acid that carries the genetic information in the cell. DNA consists of two long chains of nucleotides twisted into a double helix and joined by hydrogen bonds between the complementary bases adenine (A) and thymine (T) or cytosine (C) and guanine (G). The sequence of nucleotides determines individual hereditary characteristics. (The American Heritage® Dictionary) – In a plant or animal it is these individual hereditary characteristics in the DNA that are modified. Products derived from them are called genetically modified organisms (GMO).
Food Safety
For consumers, safety is the most important ingredient of their food. Past crises have undermined public confidence in the capacity of the food industry and of public authorities to ensure that food is safe. Governing bodies, such as the European Commission, have identified food safety as one of their top priorities.
Food safety today usually means modernizing legislation and industry practice according to a coherent and transparent set of rules, reinforcing controls from the farm to the table and increasing the capability of the scientific advice system, so as to guarantee a high level of human health and consumer protection.
Global Laboratory Alliance®
The Global Laboratory Alliance® (GLA), initiated by Genetic ID, establishes uniform quality standards in GMO testing worldwide. With expert labs strategically located around the world, the GLA is a powerful force serving the food and agricultural industries with accurate, reliable GMO testing.
It was established to respond to the urgent need of the industry for standardized, reliable GMO testing around the world. With its comprehensive network of laboratories, the Global Laboratory Alliance ensures standardized testing wherever products are marketed. By working around the world with GLA laboratories, and making sure that their customers work with GLA labs, suppliers can be confident that GMO assessment of their products will be consistent, reliable, and based on the highest standards of science. In addition, the testing protocols used by Global Laboratory Alliance laboratories are designed to comply with regulatory requirements around the world, and are backed up by Genetic ID's broad knowledge of regulatory developments related to GMOs. Through the Global Laboratory Alliance, Genetic ID can help its clients address regulatory issues wherever they operate.
The laboratories owned by Genetic ID are accredited against DIN EN ISO 17025.
GMO (Genetically Modified Organism)
Sometimes also referred to as GM (genetically modified) or GMF (genetically modified food) or GE (genetically engineered); similar abbreviations exist in other languages.
GMO Testing
Analyses of samples of food or agricultural products for the presence of GMOs, often also for the quantity of GMOs and types of GMO events. The testing method approved by CERT ID as a base for certification is only PCR which tests for DNA, but so-called strip tests looking for certain proteins may also be used at early stages of agricultural production in order to reject possible GMO input into a production process.
GMO Traceability
General traceability, in force in the European Union since 18 April 2004, stipulates the requirement for operators to label and trace products containing or made from GMOs, [EU Regulation (EC) No. 1830/2003.
Accordingly, food and ingredients must be labeled ...
- if they consist of, contain or are made from a genetically modified organism - e.g. a plant; and,
- if this modified organism can be detected in the finished food product.
However, some food ingredients are processed so deeply that even the most delicate PCR testing is sometimes unable to distinguish whether they were produced from genetically modified or from conventional plants. This is due to the DNA being destroyed during the processing and therefore, no DNA can be extracted for testing.
Therefore, the new EU Regulations state that food, feed, ingredients and additives must be labeled:
- if they are or consist of a genetically modified organism
- or if they have been made from genetically modified organisms - regardless of whether these can be detected in the food/feed or not.
Labeling independent of detection is possible only if the information about the application of genetically modified organisms is handed down the entire production chain - from the producer to the retailer. The EU Regulation requires that the food industry and at least the suppliers of raw materials for the feed industry set up appropriate traceability systems.
Inspector (also: authorized Inspector)
CERT ID uses inspectors to carry out on-site audits and inspections worldwide. Individuals assigned to these tasks are either CERT ID employees or specially selected and trained to conduct this type of work. They have to meet certain criteria laid down in the CERT ID Standard in order to receive written CERT ID approval as authorized inspectors.
All authorized certification inspectors working for CERT ID are demonstrably impartial and independent evaluators of client compliance with the CERT ID Standard.
IP (also: Identity Preservation)
Legislators of several countries have satisfied consumer and industry demands by enacting mandatory labeling laws for foods containing ingredients derived from genetically modified crops. To comply with these labeling laws, food manufacturers must be able to document the genetic purity of both GM and non-GM ingredients. This can be accomplished by preserving the identity of a crop from seed to final product (Identity Preservation or IP) and by thus enabling the various players in a supply chain to document traceability. This means being able to trace back from the final product to the crops from which ingredients were manufactured.
Traceability is not possible without existing IP systems. They require that manufacturers have a complete understanding of the supply chain for primary and secondary ingredients and blends. New specifications must be developed with well-defined expectations regarding purity and handling. Audit systems must be created to ensure compliance by farmers, grain elevators, processors, ingredient suppliers aswell as feed and food manufacturers.
IP Systems
Production or handling systems where IP (Identity Preservation) has been implemented.
Labeling Threshold
Level of GMO content of consumer products, as defined by some governments, above which a label on the packaging must indicate that the product inside contains GMOs.
Food products, feedstock and additives made from raw materials that usually contain a mix of normal and genetically modified plants must be labeled. Only unintentional ("adventitious") technically unavoidable admixtures are exempt.
Ingredients or additives made from soy or maize (corn) raw materials must always be labeled if they are derived from crop that is genetically modified. The content level is irrelevant.
Those admixtures of genetically modified plants that are adventitious or unintentional can remain unlabeled ...
- if their share in the respective volume of the relevant ingredient is not above 0.9%
- and the respective manufacturer can show evidence that the admixture is adventitious, technically unavoidable and that he tried to procure "GM-free" raw materials. Intentional blends are principally not exempt from labeling.
Lecithin
A phospholipid (phosphorus containing lipid) found in all living animal and plant cell membranes. Lecithin is the term used to describe the commercial mixture of 60% minimum Acetone Insoluble matter (E322). Today, lecithin is used in pharmaceuticals, dietetics, health foods, baby foods, confectionary, bakery products, even in paint, ink and magnetic media (e.g. video tape applications). Lecithin is most widely known to consumers for its use as an emulsifier in chocolate. However, an outsider is likely unaware of the strong interdependence of lecithin and soy meal used almost exclusively for animal feed.
'Non-GMO'®
CERT ID refrains entirely from using terms such as "GMO-free", "GE-free" etc., terms that would imply a 100% absence of GMOs. Certification to a 0.0% GMO content threshold is impossible for two reasons, each one being sufficient on its own: (1) GMO testing can only be conducted with representative samples, never with an entire lot. (Otherwise nothing would be left for consumption.) (2) The PCR testing method for GMOs is able to test to detection limits as low as between 0.1% and 0.01%, depending on the tested material. It does not "reach" as low as 0.0%.
At the same time, CERT ID endeavors to enable its Clients to attain a production output that is, in fact, as "free" of GMOs as possible. This is accomplished by rigid input testing for GMOs as well as by certifying to a rigorous Standard that ensures a minimization of contamination risks throughout the entire IP chain.
In any event, CERT ID's 'Non-GMO' certification stands for a maximum GMO content of 0.1%.
PCR (Polymerase Chain Reaction)
DNA amplification method for whose inventor, Kary Banks Mullis, received the Nobel Prize for Chemistry in 1993. In more scientific detail, PCR is a “technique for amplifying DNA sequences in vitro by separating the DNA into two strands and incubating it with oligonucleotide primers and DNA polymerase. It can amplify a specific sequence of DNA by as many as one billion times and is important in biotechnology, forensics, medicine, and genetic research” (The American Heritage® Dictionary). This ability to amplify DNA molecules millions of times in a rather short period enables a lab testing for GMOs to produce reliable test results from as few as two molecules extracted from a testing sample.
Precautionary Principle
This is the name of a legal concept found today in many countries. A matter of law in Germany and Sweden for years, the precautionary principle has begun to guide the policy of all of Europe: in February 2000 the European Commission outlined when and how it intends to use the precautionary principle. Increasingly, the principle is finding its way into international agreements. It was incorporated for the first time in a fully fledged international treaty in early 2000 - namely, the United Nations Biosafety Protocol regulating trade in genetically modified products. Gradually it has begun to work its way also into U.S. policy.
In an October 2000 speech at the National Academy of Sciences in Washington, D.C., the New Jersey governor Christine Todd Whitman averred that "...policymakers need to take a precautionary approach to environmental protection.... We must acknowledge that uncertainty is inherent in managing natural resources, recognizing it is usually easier to prevent environmental damage than to repair it later, and shift the burden of proof away from those advocating protection toward those proposing an action that may be harmful." (http://www.biotech-info.net/uncertainty.html)
Process Guarantee
The 'Non-GMO' assurance given by CERT ID is a process guarantee, as opposed to a content guarantee. This means that CERT ID assures that the systems the company’s inspectors have audited comply with the CERT ID Standard and can produce product that complies with the CERT ID Standard as well, with a GMO content well below 0.1%. No certifier can guarantee that every grain, kernel or bean meets this requirement at all times.
Product Recalls
Surely one of the worst scenarios imaginable by manufacturers of any type of product, this is also a horror to government enforcement authorities. It goes hand-in-hand with food scandals, serious and not-so-serious, that have occurred in various parts of the world since the late 1980s. Among the most costly ones are, in Europe, the dioxin and BSE cases, and in North America the StarLink® incident. All three necessitated recalls of major proportions.
The foremost reason why these recalls resulted in such immense cost is that at the time there were not enough implemented IP systems that would allow traceability. Just to be safe, many shipments were covered by the recall that objectively contained none of the compromising substance. Realizing this, governments, such as the EU Commission on behalf of its member countries, are beginning to enforce more and more traceability requirements. The CERT ID program is based on full traceability. Products certified as 'Non-GMO' all come with complete traceability all the way back to the farm level. In the event that a recall of products containing CERT ID certified material should become necessary, for whatever reason, the recall cost will be minimized.
StarLink® is a trademark of Aventis CropScience
Sampling Protocol
Most CERT ID Certification Plans contain a description of where, when and how samples of product to be certified are to be drawn and treated subsequently. This procedural code is called sampling protocol.
StarLink® Incident
This event in June 2000 involved a genetically engineered corn (maize) variety approved in the U.S.A. for animal consumption only. Lab tests showed that it was found in a brand of taco shells, a type of Mexican food, offered in retail stores.
It was soon apparent, through sampling and testing in many locations throughout the U.S., that StarLink corn was present all over the country. The final result was a recall project that, at one point, brought the American corn logistics to a complete standstill for a day or two.
The price tag on all of this for the companies involved soon grew into billions of dollars. More IP systems and traceability could have reduced these costs considerably.
This event in June 2000 involved a genetically modified corn (maize) variety approved in the U.S.A. for animal consumption only. Lab tests
StarLink® is a trademark of Aventis CropScience
System Certification
This general certification bears in mind the principles of EU Regulation (EC) No. 178/2002. of the EU Parliament and of the Council about General Principles of Food Law of January 28, 2002. It serves as a platform on which Process Certification can be established. One of its main aspects is the presence of traceable IP. This and other EU Regulations are available for download.
TCC [Transaction Certificate of Compliance]
Industrial buyers of 'Non-GMO' certified material usually have to pay their suppliers a premium for the extra quality assurance. This plus their obvious interest in documentation of the 'Non-GMO' status of the products they receive necessitate that CERT ID issue documents for each shipment of certified material, called Transaction Certificates of Compliance (TCC).
All TCCs bear a number that is the key to all traceability information pertaining to the respective shipment. (sample TCC)
Third-Party Certification
Certification of any product does not change the product physically in any way. Certification assures that certain quality-improving measures are taken in processing a product and can add value to the certified product. Such certification makes sense only if provided by a so-called third party, i.e. an organization that is neither the manufacturer nor supplier of the product nor a consumer advocacy group.
Traceability
Legislators of several countries have satisfied consumer and industry demands by enacting mandatory labeling laws for food and feed products containing GMO ingredients. In order to comply with these labeling laws, food manufacturers must be able to document the genetic purity of both GM and non-GM ingredients. This can be accomplished by preserving the identity of a crop from seed to final product (Identity Preservation or IP) and by thus enabling the various players in a supply chain to document traceability. This means being able to trace back from the final product to the crops from which ingredients were manufactured.
Traceability is not possible without existing IP systems. They require that manufacturers have a complete understanding of the supply chain for primary and secondary ingredients and blends. New specifications must be developed with well-defined expectations regarding purity and handling. Audit systems must be created to ensure compliance by farmers, grain elevators, processors, ingredient suppliers and food manufacturers.
Since the coming into force of Regulation (EC) No. 1830/2003 in the European Union, the term of "adventitious or technically unavoidable" GMO contamination has assumed a special relevance. This Regulation is about the traceability and the labeling of products containing GMOs or made from them. Products with a GMO content in excess of a certain threshold (labeling threshold) must de labeled as containing GMOs since 18 April 2004. Even if this threshold is not exceeded, a product must be labeled if the GMO contamination was not "adventitious or technically unavoidable.".
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