PREVRA Non-GMO Compliance Checklist: Verify Your GM-Free Supply Chain
A practical checklist for UK food businesses making non-GMO claims. Covers supplier verification, GM labelling law, and due diligence for GM-free product ranges.
Why non-GMO claims require rigorous due diligence
Making a non-GMO claim on a food product in the UK is a legal statement, not a marketing slogan. Under retained EU Regulation 1829/2003, GM labelling is mandatory for products containing, consisting of, or produced from genetically modified organisms above 0.9% adventitious presence. But making a positive 'GM-free' claim puts the burden of proof entirely on you — you must demonstrate due diligence across your entire supply chain.
The less obvious risk: animal products from livestock fed on GM feed do not require GM labelling in the UK. A product labelled 'non-GMO' that contains milk, eggs, or meat from animals fed on GM soya could be challenged as misleading by trading standards. The Non-GMO Project and similar schemes require verification of animal feed, not just the final product ingredients.
Using this checklist for supply chain verification
Start with your highest-risk ingredients. GM soya, maize, oilseed rape, and cottonseed oil are the most common GM commodities in global supply chains. For each ingredient, obtain a written declaration from your supplier confirming GM status and the testing or segregation procedures they use. A vague statement of 'GM-free to the best of our knowledge' is not due diligence.
Consider third-party certification if you are building a non-GMO brand position. Digital SFBB can store and organise your supplier declarations, ingredient specifications, and test results, creating an auditable trail that demonstrates your due diligence to enforcement officers and certifiers.
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