30 Questions for You on the GMO Labeling Standard

I remember with no measure of fondness the industry warfare that transpired after the GMO disclosure standard was enacted last July. It was a deal that no one on either wanted. The USDA recently posted 30 questions on their website that will be used to draft their proposed rule. No matter how much you dislike this rule, it’s time to lay down your sword and provide real input to make it as robust as possible.

The National Bioengineered Food Disclosure Standard was the very definition of a compromise bill. No one liked it. Big commodity and retail groups found it onerous and paid millions to defeat it. Advocates on the staunch organic side despised it for its option to provide digital or electronic disclosure. Yet the bill passed and the USDA has a scant 12 months to implement it as Congress mandated, in the summer of 2018.

Its passage heralds the first step of providing transparency of GMO ingredients in U.S. products. The bill was written with considerable vagueness, leaving many details to be sorted out by the USDA. For some time it looked as if the USDA would go from proposal to standard without any public input. Suddenly the USDA website offered up 30 questions to help draft the proposed rule.

Those 30 questions hold the key to developing a vigorous standard of GMO disclosure. We can help craft a meaningful standard for GMO foods that is based on Congress’ clear intent to cover all GMO foods and GMO technologies.

Understand that those who wish to water it down will be commenting quite vociferously.

While I won’t be reviewing all 30 answers in this post, here is my take on the most important input we can provide:

• Mandatory GMO disclosure must apply to all foods produced with genetic engineering, including ingredients derived from GMO crops like highly-refined sugars and oils.
• It must be applied to foods produced with new forms of genetic engineering like CRISPR and RNAi.
• The definition must be consistent with international regulations and standards. To be consistent with the greatest number of countries, as well as the standards set by the U.N. Codex Alimentarius, the GMO standard should apply to all GMO food.
• USDA must ensure that the GMO disclosure standard doesn’t conflict with existing organic standards and will not require any modifications to be made to the USDA organic regulations.
• USDA must have strong rules to make sure that digital disclosures using QR codes consistently scan every time and in all conditions and are the first thing a customer sees when they scan a product. (I know you may be staunchly opposed to the QR option, but it’s in the standard for good)
• The standard must provide options so that consumers who don’t have smartphones or live in parts of the country without reliable cellular service can access the GMO disclosure. These options must be as convenient as it would be for someone to pull out their phone and scan a product. (Electronic scanners in every aisle would do the trick)
• Finally, the USDA must finalize its GMO disclosure standard by July 28, 2018. (Some Congressional leaders would like to defund the implementation in the budget process)

There is no stated deadline for comments on the website, but the sooner you can assemble your substantive answers the better. The Organic Trade Association will be drafting comments specifically safeguarding organic as the gold standard for transparency and non-GMO status.

“Just Label It” has assembled guidance that can help you with your comments.

Let’s finish the job Congress passed last summer and finalize a robust GMO disclosure standard that nine out of ten Americans say they want. We deserve the same right held by consumers in 64 other countries.

Let me know what you think about the 30 questions.