Verifying Non-GMO Status

Can I use an OMRI NOP listing to verify GE status under COR?

By Tessa Barker

Review Program staff are often asked if products that are OMRI Listed® under the USDA National Organic Program (NOP) standards would be allowed for use in products applying for OMRI listing under the Canada Organic Regime (COR). Because these ruling bodies are independent, they have different requirements. A listing under the standards of one ruling body does not automatically translate to a listing under another. One specific way in which COR and NOP standards differ is in the level of scrutiny given to genetically engineered (GE) or modified organisms. 

When applying for OMRI listing under the NOP standards, applicants must attest that their final product and its ingredients were not produced using genetic engineering. If products include corn or cotton, OMRI may require that the statement comes directly from that ingredient’s manufacturer, as those materials are considered “high-risk” for GE within the U.S. However, there are some cases in which materials that originated from GE plants or animals may have a compliant use within an input. For example, GE materials that are composted, or in which the protein is removed, denatured or deactivated, may be allowed for use in NOP crop inputs. Likewise, a microbial product that was cultured on GE growth media that does not remain in the final product may also be allowed in NOP crop inputs. 

Similarly, companies that apply for OMRI listing under COR also must attest that their final product and ingredients were not produced through genetic engineering. However, under COR standards, there is a longer list of materials that are considered “high-risk” for GE. These include non-organic alfalfa, canola, corn products (corn syrup, cornstarch, and starch derivatives such as dextrin and dextrose), cotton, papaya (papain), soy (including vegetable protein), sugar beets (sugar or molasses), squash, yeast, enzymes, microorganisms, and products of microbial processes. If a product includes any of these ingredients, OMRI must receive a statement from the material’s manufacturer to confirm that the ingredient was not produced with GE. 

Some manufacturers may provide a negative result from a GE DNA test in an attempt to meet this requirement. However, OMRI is unable to accept this as proof of non-GE status, as there may be processing steps that obscure whether the original material was genetically engineered. Suppliers that source commodity ingredients such as canola, corn, soy, or molasses may have many raw material suppliers, and as such, OMRI obtains attestations from each as part of that ingredient’s review. A hypothetical OMRI Listed product under the NOP may contain sugar beet molasses. For the product to be used as an ingredient in another product applying for listing under NOP, the statement already on file for the OMRI Listed product is sufficient documentation of non-GE status. If, however, the new product were to apply for listing under COR, OMRI would require an additional statement from the manufacturer of the molasses ingredient to complete the review.   

This article was originally published in the spring 2023 edition of the OMRI Materials Review newsletter, and was revised in September 2024 by Research and Education Manager Peter Bungum..