Since 2011, NCG has been an influential and persistent advocate for mandatory GMO labeling, calling for a national law to require on-package disclosure of genetically engineered foods, so that shoppers can make their own informed purchasing decisions (see our position statement). With last year’s passage of the National Bioengineered Food Disclosure Law, NCG pivoted our resources to focus on becoming leaders within our industry to help slow climate change, all the while keeping a pulse on the nascent GMO labeling law’s progress.

With the law scheduled to go into effect by July 2018, USDA is on a tight timeline to develop supporting regulations. To help USDA staff begin drafting regulations, the agency posted this slate of exploratory questions for public comment. The draft regulations will be subject to further public comment in an iterative process, and NCG will take every viable opportunity to call for the most consumer friendly implementation possible of the law.

NCG’s comments in response to USDA’s exploratory questions are extensive, reflecting both our unique position as consumer-owned retailers and a unified voice among diverse partner organizations, including Just Label It, Environmental Working Group, Organic Trade Association, National Organic Coalition and Consumers Union. Here are some highlights from NCG’s comments, which you can find in full here.

• NCG does not view QR codes or other digital options as adequate disclosure, and strongly urges USDA to reject them.
• On package, ingredient-level text disclosure is the most transparent and accessible means to communicate that a product has been produced using genetic engineering.
• Disclosure language should be a clear presence or derived from claim (e.g. “produced” or “partially produced”) rather than the ambiguous statement “may contain.”
• NCG strongly urges USDA to require disclosure for food that contains highly refined products, such as oils or sugars that are derived from bioengineered crops.
• Anything less than a broad interpretation of bioengineering that accounts for a wide range of existing techniques as well as future developments would fail to harmonize the law with international standards, contributing to confusion in the marketplace.
• The regulations must reflect USDA policy memos stating that no certified organic products will be subject to disclosure as bioengineered; and no proposed rules for bioengineered food disclosure will require that modifications be made to the USDA organic regulations.

These comments reflect NCG Advocacy Guidelines supporting product labeling that improves consumers’ ability to make informed food choices.