Introduction

As a result to the market demand for non-GMO feed within the European Union (EU) GMP+ International has created MI 5.4 GMO controlled. This in order to facilitate feed companies to comply with the demands of the market initiative VLOG.

Consumer perception plays an important role in the demand for non-GMO food (and feed). At present many (inter)national non-GMO standards are applied in the feed sector. The German VLOG standard has set a standard for the food and feed sector inside the EU. Therefore, GMP+ International has chosen to collaborate with VLOG to be able to facilitate the demand especially in Europe.

Legislation has been published in various countries, including Germany and France, to label products from animal origin (meat / milk / egg) as non-GMO. Such labelling also means that specific requirements are imposed on the chain upstream, including the animal feed industry. Conditions relating to the production of non-GMO food from animal origin require the use of GMO controlled feed. To provide animal feed suppliers with the opportunity to supply GMO controlled feed to farmers who deliver non-GMO end-products (meat / milk / egg) to markets where legislation allows such labelling, MI 5.4 GMO controlled was developed.

Regulations (EC) No. 1829/2003 and 1830/2003

The VLOG Standard is based on the GMO labelling provisions of Regulations (EC) 1829/2003 and 1830/2003. Contamination with GMOs permitted in the EU by law does not require labelling according to Regulations (EC) No. 1829/2003 and No. 1830/2003 provided that two requirements are fulfilled:

• The threshold value of the GMO content of 0.9% per feed material is not exceeded and
• The presence of the GMO content is “adventitious or technically unavoidable”.

Contamination with approved GMO content < 0.1% are generally considered as technically unavoidable or adventitious. Contamination present in quantities from 0.1% to 0.9% is considered as labelling-compliant if the business has installed and demonstrably implemented organisational measures to avoid introduction of GMO material.

Verband Lebensmittel ohne Gentechnik (VLOG)

VLOG - Verband Lebensmittel ohne Gentechnik (VLOG) provides a non-GMO standard which includes requirements for the production of products from animal origin without the use of GMO feed ingredients. The VLOG standard supports production facilities in the implementation of the German legal requirements of non-GMO labelling and establishes uniform inspections for certification companies. It is based on the German EC Engineering Act (EG-GentDurchfG) and on “BVL-Guideline for Monitoring GMOs in Feed”, version 3 as of 15 July 2021 (Feed Guideline). GMP+ International worked together with VLOG on MI 5.4 GMO controlled. The current MI 5.4 GMO Controlled is based on the VLOG – ‘Ohne Gentechnik’ Production and Certification Standard version 23.01.

1. Scope of this document

The requirements to produce, store, transport and/or trade GMO controlled feed that is in compliance with the requirements as defined by VLOG are included in this document.

2. Normative references

This Market Initiative (MI) document holds the responsible feed and feed services requirements. This MI document must always be used in combination with the R5.0 Feed Responsibility Management Systems Requirements which ensures the implementation of a Feed Responsibility Management System (FRMS). The combined use enables a company to provide responsible feed products and feed services in accordance to the request from the Market Initiative.

Both the R5.0 Feed Responsibility Management Systems Requirements and the Market Initiative documents must be considered as a normative part of the GMP+ FRA module.

This document is to be used:

1. in addition to the GMP+ FSA module;
2. in combination with an equivalent feed safety standard (see TS1.2 Purchase)

Storage and transshipment companies and transport companies can only use MI 5.4 GMO controlled and R5.0 Feed Responsibility Management Systems Requirements in combination with GMP+ FSA certification for the scopes storage and transshipment and transport respectively.

2.1. How to read this document

MI 5.4 GMO controlled gives only additional requirements to the requirements of R5.0 Feed Responsibility Management Systems Requirements. These requirements are relevant for the scope of MI 5.4 GMO controlled.

The structure of MI 5.4 GMO controlled follows the same structure as R5.0 Feed Responsibility Management Systems Requirements. Only when there is an additional requirement to a certain paragraph of R5.0 Feed Responsibility Management Systems Requirements, this is added in MI 5.4 GMO controlled. For convenience, the numbering and names of the paragraphs of MI 5.4 GMO controlled correspond with the relevant paragraphs in R5.0 Feed Responsibility Management Systems Requirements. These additional requirements are extracted from the VLOG standard.

3. Terms and Definitions

In addition to the terms and definitions mentioned in F0.2 Definition listthe following terms are used:

4. GMO controlled

4.1. Feed Responsibility Management System

In addition to the requirements in this document, the certified company must also meet the requirements mentioned in R5.0 Feed Responsibility Management Systems Requirements.

4.1.1. Determining the scope of the Feed Responsibility Management System

The certified company determines and documents which feed materials, feed additives, premixtures and/or compound feed are covered within the scope of the management system.

4.2. Prerequisite programmes (PRPs)

These requirements are in addition to R5.0 Feed Responsibility Management Systems Requirements.

4.2.1. People

The certified company performs a relevant training at least once a year and in any case before the relevant employee starts with the activities which may have an impact on the GMO controlled feed.

4.2.2. Traceability system

The certified company has a written recall procedure which can be used within the framework of handling positive results and complaints.

4.3. Risk assessment

These requirements are in addition to R5.0 Feed Responsibility Management Systems Requirements.

4.3.1. Additional requirements for trade

Buying feed materials from a non-certified supplier and selling this as GMO controlled feed material, is only allowed in case genetic modification can be technically detected in the feed material through PCR tests. In that case the certified company must also comply with the requirements in § 4.3.2.

4.3.2. Additional requirements for production

The certified company is required to make an individual, batch-specific risk assessment of risk/ not at risk feed materials, which are used within the scope of GMO controlled feed.

*Dried corn can be considered as not ‘at risk’ when coming from specific regions. These specific regions are described in Part E: Agriculture (Chapter E § 4.2) of the VLOG – Ohne Gentechnik standard available on the VLOG homepage https://www.ohnegentechnik.org/en/for-businesses/standards/the-vlog-standard (most recent version).

4.4. Purchase

These requirements are in addition to R5.0 Feed Responsibility Management Systems Requirements.

4.4.1. Selection of suppliers

The certified company must purchase feed and/or services from a supplier according to the below specifications:

4.4.2. Verification of incoming products and/or services

In case of outsourcing activities to third parties (for example subcontracts for storage, transport or other services), the certified company:

1. ensures that this activity is purchased in compliance with the purchasing requirements in § 4.4.1. and;
2. provides the third party with written instructions to ensure compliance with the requirements in this document.

4.4.2.1. Additional requirements for incoming products to be used for production

For each feed classified as ‘at risk’ in the risk assessment, a confirmation of the non-GMO status from the supplier is required. This may be done by one or more of the following examples:

1. a valid certificate in accordance with MI 5.4 GMO controlled (or equivalent) together with a declaration about the non-GMO status of the batch/lot being delivered;
2. a test result according to the requirements of MI 5.4 GMO controlled (or equivalent) proving the non-GMO status of the batch/lot being delivered;
3. an additional indication on the delivery slip declaring the products to be exempt from mandatory labelling;
4. a clear contractual agreement regarding the delivery of feed exempt from mandatory labelling.

Furthermore, for feed additives and processing aids, to be processed in GMO controlled compound feed and feed materials it must be documented in writing that they are not subject to mandatory labelling obligations.

4.5. Informing the customer

These requirements are in addition to R5.0 Feed Responsibility Management Systems Requirements.

4.5.1. Inform the customer about the status of the feed

Note: According to the VLOG standard livestock farmers demand a statement from their feed suppliers about the non-GMO status of the feed they receive.

The system must ensure that feed materials and/or compound feed which are subject to mandatory labelling are labelled in accordance with Regulations (EC) 1829/2003 or 1830/2003.

Note: For the use of logo’s and trademarks, see F0.1 Rights and Obligations.

4.6. Verification

These requirements are in addition to R5.0 Feed Responsibility Management Systems Requirements.

4.6.1. External communication

5. Supply chain models

These requirements are in addition to R 5.0 Feed Responsibility Management Systems Requirements.

5.1. Segregation

Vehicles must be demonstrably dry cleaned after transporting bulk raw materials or feed labelled as genetically modified pursuant to Regulations (EC) No. 1829/2003 and 1830/2003.

6. Sampling and Testing

6.1. General

Sampling is done in compliance with relevant EU legislation and/or already accepted sampling standards.

6.2. Monitoring plan

6.2.1. Feed in which genetic modification cannot be detected

If the certified company only uses feed in which, due to technical limitations, genetic modification cannot be detected through PCR tests, no sampling/GMO test is necessary. This must be concluded from the risk assessment.

6.2.2. Feed in which genetic modification can be detected

The certified company must have a monitoring plan that describes the sampling and testing procedure. This plan must be carried once a year.

The monitoring plan must at least contain:

1. requirements to sample takers;
2. sampling method:
   1. product to be sampled;
   2. place of sampling;
   3. method of taking aggregate samples and retained samples;
   4. sample size and number of samples;
   5. sealing and identification;
3. storage duration of samples;
4. documentation of samples;
5. sampling frequency;
6. name of the VLOG-recognized laboratory to be used for testing.

6.2.2.1. Requirements to sample takers

The sample taker complies with the requirements for samplers as laid down in TS1.6 Sampling.

6.2.2.2. Storage duration of samples

The storage duration of samples matches the use and shelf life of the sampled product.

6.2.2.3. Sampling and Testing frequency

The frequency of sampling and testing is based on the certified company’s individual risk assessment and is in compliance with the requirements in Annex 1. For each outgoing batch, at least one sample is taken and retained.

A trader may make use of representative samples and testing results from the producer (supplier).

Each final sample is tested.

Second or third analyses of the sampled batch are permitted. See § 6.3 in case two test results with different conclusions are obtained for a single sample.

6.2.2.4. Sample preparation and Analysis

Depending on the sample matrix, the following minimum amounts of sample material are to be completely milled in each case:

1. feed: min. 400 g, max. 1 kg, entirely milled;
2. raw materials (whole maize/corn kernels, soy beans or rapeseed/canola grains, among other): at least 3000 kernels or approx. the respectively corresponding sample amount (maize/corn at least 1000 g; soy at least 700 g, rapeseed/canola at least 60 g), entirely milled.

The testing on GMOs is carried out by a laboratory recognized by VLOG.

When commissioning a laboratory, the following information must be indicated in the order or other documents having similar effect, and submitted to the laboratory:

1. order of VLOG test (GMO tests) according to the VLOG requirements for laboratories as stated in the guideline for VLOG-recognition of laboratories;

2. composition of the sample.

If containing soy, maize/corn, rapeseed/canola and/or rice feed material or ingredients, it must be indicated in what form these are contained (e.g. maize/corn as maize/corn mash, soy as soy extraction meal) and the composition of the compound feed.

6.3. Evaluation of test results and measures to be taken

6.3.1. General

If two test results with different conclusions are obtained for a single sample, the following procedure is to be undertaken, resulting in a final finding:

1. if the results overlap, taking into account the expanded measurement uncertainty, the average value of the two test results is used;
2. if the results do not overlap, taking into account the expanded measurement uncertainty, a third test of the batch is ordered.

The internal auditor examines whether the test results were evaluated correctly and any necessary (corrective) measures were properly implemented.

In the event of inaccurately labelled feed placed on the market, the customers and Certification Body must be notified with at least the information as mentioned in Appendix 2.

6.3.2. Handling positive test results

The certified company must establish a system for handling positive test results. This must include appropriate measures like the labelling/blocking of noncompliant products and a recall procedure.

The customer is informed (on request) periodically about positive test results related to the delivered batches and receives a summary or overview of the results.

Positive test results must be handled in accordance with the table below.

Appendix 1 Sampling and Testing

The tables below specify the sampling and testing frequency for GMO controlled feed materials, feed additives, premixtures and compound feed. The sampling and testing frequency applies only to the products that fall under the scope of this standard.

The sampling and testing frequency is calculated based on 88% dry matter content.

The sampling and testing frequency is to be implemented by certified companies producing and/or trading GMO controlled feed materials, feed additives, premixtures and/or compound feed.

1. Producing companies

The table below provides the sampling and testing frequency for certified companies producing GMO controlled feed material, feed additives, premixtures and compound feed.

* Certified companies who only produce feed materials not subject to mandatory labelling can dispense with sampling of the outgoing feed materials if corresponding test was performed on the incoming goods.

2A. Trading companies

The table below provides the sampling and testing frequency for certified companies trading GMO controlled feed.

2B. Trading companies converting into GMO controlled feed materials

The table below applies to the certified company, as meant in paragraph 4.3.1 above, who buys a feed material from a non-certified supplier in which genetic modification can be technically detected through PCR tests and sells this feed material as GMO controlled.

* based on the certified company’s individual risk assessment

Appendix 2 Informing supplier and customer

In case the the certified company must inform his supplier(s), customer(s) and Certification Body (see § 6.3), at least the information as mentioned in the table below must be provided.

Feed Support Products

That was a lot of information to digest and one might ask, what is the next step? Luckily we can offer support for the GMP+ Community when doing this. We provide support by means of various tools and guidances but as each company has a shared responsibility to feed safety, and therefor tailor-made solutions cannot be offered. However, we do help by explaining requirements and provide background information about the requirements.

We have developed various supporting materials for the GMP+ Community. These include various tools, ranging from Frequently Asked Questions (FAQ) lists to webinars and events.

Supporting materials related to this document (Guidelines and FAQ’s)

We have made documents available which give guidance to the GMP+ requirements as laid down in the module GMP+ FSA and GMP+ FRA. These documents give examples, answers to frequently asked questions or background information.