UK report to the Commission on the EC co-ordinated programme for the official control of foodstuffs for 2002: Labelling of genetically modified foodstuffs
Friday 20 June 2003
The European Commission requested Member States to conduct checks on certain types of foodstuffs to ensure that, if they contained any genetically modified ingredients, they complied with the appropriate labelling rules. The Food Standards Agency (FSA) asked The Local Authorities Co-ordinators of Regulatory Services (LACORS) to co-ordinate the UK element of the 2002 EC Programme.
LACORS invited a number of geographically representative local authorities to obtain appropriate samples for analysis by their Public Analyst. All samples were taken as formal samples under the Food Safety Act 1990 and were taken during the period September to December 2002.
Current EC regulation for GM labelling requires labelling of any GM ingredient (at any percentage) if it has been used intentionally, but allows a 1% threshold for adventitious presence provided manufactures can show that they have attempted to avoid using GM ingredients in their product. Labelling is based on the presence of GM material (DNA or protein).
Samples were tested for GM ingredients in the following proportions: 45 soya; 42 maize, two rapeseed oil and two tomatoes.
Key findings
18 samples made 'GM Free' claims, three of which were found to contain undeclared GM ingredients. The GM DNA found in all three products was believed to be adventitious, and was only found at levels below the 1% threshold for adventitious presence. Local Authorities visited manufacturers to remind them of their responsibility to ensure that claims made on labels are representative of the contents to avoid misleading consumers.
Five samples were found to contain GM ingredients below the 1% threshold for adventitious presence of GMOs. Provided that the manufacturers can show that the GMOs below the 1% threshold were not present intentionally, they are not required to list it on the product label. Nevertheless, Local Authority representatives visited all five manufacturers to discuss labelling requirements for the use of GM ingredients, particularly when Identity Preserved sources are not used.
Three samples declared the presence of GM ingredients on their label but none were found on analysis. The manufacturers may have been applying the precautionary principle.
Sample Selection
The sampling programme concentrated on the following EC approved GM ingredients:
MAIZE: Avetis t25; Monsanto Mon 810; Novartis CG00526-176 and Bt11; and Pioneer MON809
OILSEED RAPE: Agrvo-transformation event TOPAS 19/2; Hoechst - Falcon GS40/90, Liberator; Monsanto - GT73; PGS - lines MS1Bn (B91- ), RF2Bn (Bn( B94-2), RF1Bn (NB93-101), MS8 (DBN230-0028), RF (DBN212-0005), MS1xRF2, MS1xRF2, MS8xRF3
SOYA: Monsanto line 40-3-2 (Roundup Ready)
TOMATO: Zeneca - Nema 1401F, H28F (tomato paste only, approved in the UK in 1995)
The following commodities, raw materials and foodstuffs were recommended for sampling and following global market share and product inclusion rates emphasis was placed on items containing maize and soya:
FOODSTUFFS DERIVED FROM SOYA: Soya beans; Soya Flour; Soya Meal; Tofu; Bakery Products; Bread; Pizza Bases; Meat Substitutes (eg Soya Mince; Meat Seasoning Mixes).
FOODSTUFFS DERIVED FROM MAIZE: Maize; Maize Flour; Maize Snacks; Maize chips; Maize Bakery Products; Polenta
FOODSTUFFS DERIVED FROM SOYA AND MAIZE: Baby Foods; Biscuits; Raw Materials for Food Supplements
The following minimum amounts were taken for analysis:
Commodities/Raw Materials: 2.5kg; Processed Foodstuffs: 250g
For pre-packed products complete unopened packs were taken to prevent adventitious contamination at the sampling stage. Perishable products were frozen prior to their dispatch to the Public Analyst to avoid deterioration.
Analysis
Analysis was carried out at Public Analysts laboratories accredited for GM analysis and covered the following aspects:
- a general screen for genetic modification using 35s promoter and NOS detection
- approved varieties of maize and soya based GM foods
- non-approved varieties of maize and soya based GM foods
Where positives were found these were considered for further quantitative analysis at Official Laboratories accredited for quantitative GM analysis. The limit of detection was 0.1%.
All positives were reported to the sampling officer as they were found so that detailed audits of records/identity preserved systems could be undertaken without delay.
The attention of Public Analysts was drawn to the 'Recommendations Concerning Analysis of Foodstuffs For GMOs' contained in the Official Journal. Sampling and Analytical results were recorded on a standard results form.
The presence of GM ingredients at any level must be labelled, except where documentary evidence can be provided to prove that manufacturers have attempted to avoid the use of GMOs, usually through the use of Identity Preserved materials. A provision applies of 1% or less for the adventitious presence of GM DNA or protein. There is no level set for the adventitious presence of non-approved GM varieties.
Sample Results
A total of 91 analytical results were received. A table of results is attached.
Commentary
A range of raw materials, ingredients and foodstuffs were sampled at a variety of locations including factories, catering establishments and retail premises during the period September to December 2002. Products included food coatings (batter mixes), textured vegetable protein, soya beans and flour, corn snacks, pizza bases, cakes and biscuits.
Products described as Imported were wholly produced and packed outside the UK. Products described as UK produced were wholly produced in the UK, although possibly containing some ingredients sourced outside the UK.
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