Certification (Non-GM), Organic, Gluten-Free)
Foods that have been modified by genetic manipulation (i.e. changing the genetic material or code of an organism) are known as genetically modified (GM) foods, genetically engineered (GE) foods or biotechnology-derived foods. GMO stands for “genetically modified organisms”, and there has been an increased focus within the marketplace on products containing genetically modified ingredients.
In Canada and the USA, product labels do not have to identify the method of production used to develop a food, including genetic modification. The only requirement for labelling these types of foods exists when these foods have significant nutritional or compositional changes or when potential health and safety risks exist. However, many companies choose to voluntarily declare the use, or more commonly absence, of genetically modified ingredients, which is permissible as long as the claims made are truthful. The same criteria exists in the European Union (EU) pertaining to labelling the absence of GM ingredients, but, unlike Canada and the USA, in the EU it is mandatory to indicate on the product label if a food contains GMOs or ingredients produced from GMOs, regardless if any GM material is present in the final product. There is a threshold limit for the accidental presence of GM material in non-GM food in the EU, which is set at 0.9%.
In any country, a claim that any food is free from genetic engineering requires verification, and NHP Consulting can provide third party verification options including testing, detection methods, inspection, and audit tracking.
An organic product is an agricultural product that has been certified as organic based on the organic regulations of the associated country, including the Organic Products Regulations (OPR) in Canada, the United States Department of Agriculture (USDA) organic regulations in the USA and the EU regulation on organic production and labelling of organic products in Europe. To be certified, operators must have their products certified by a certification body accredited by the Canadian Food Inspection Agency (CFIA), the USDA or the competent authority of the specific Member State in the EU, as applicable.
Only products with organic content that is greater than or equal to 95% may be labelled or advertised as “organic” and bear the organic logo. To make an “organic” claim on the product label, the name of the certification body must also be included for Canadian and US labels and for EU products additional information is required. For products with less than 95% organic content, there are a few options for organic-type claims, including identifying the organic ingredients in the list of ingredients.
NHP Consulting can assist companies in understanding the country-specific certification requirements for an organic claim, guide your application process and selection of an accredited certification body, as well as provide assistance after certification including the review of your organic product labels for compliance.
Grains such as wheat, rye and barley contain gluten, which can cause adverse health effects in consumers with gluten intolerance. Many companies like to highlight the fact that their food products are free of gluten, in order to better appeal to consumers looking for gluten-free options. A gluten-free claim on a food product is any representation in labelling or advertising that states, suggests or implies that a food is free of gluten. When used, these types of statements must be factual and not misleading.
“Gluten-free” label declarations are voluntary declarations in Canada, the USA and Europe, and products must contain less than a maximum threshold dictated by the regulatory body in order to make the claim.
In both Canada and the USA, food labels can specifically declare the maximum amount of gluten the food may contain, so long as the amount is truthful and non-misleading. Along these lines, the EU permits the use of a “very low gluten” claim on food products containing cereal ingredients that have been specifically processed to remove the gluten. A higher maximum threshold is permitted for a “very low gluten” claim than for a “gluten-free” claim.
There are no regulatory requirements in any of these jurisdictions which require dedicated facilities be used in the production of gluten-free foods; however, manufacturers are responsible to ensure that sufficient processing controls are in place to ensure that foods claiming to be gluten-free consistently meet the regulatory requirements.
NHP Consulting Inc. can assist food and natural health product manufacturers in determining whether their products are eligible to make “gluten-free” claims and recommend test protocols and manufacturing controls to ensure the parameters required to make “gluten-free” claims are met.