The Non-GMO Project operates North America's most trustworthy certification for GMO avoidance. Products undergo rigorous evaluation by third-party experts to ensure the formulations meet the requirements of our Standard. However, our vigilance doesn't stop there. The Non-GMO Project team also conducts year-round surveillance to ensure the Verified products you see on store shelves can withstand the strictest scrutiny.

The Surveillance Program supplies an added layer of rigor to product verification. It's a barometer of our efficacy at delivering the promise of the Butterfly. Surveillance provides crucial insight into how the Standard's benchmarks help the Non-GMO Project achieve its goals. 

Let's look more closely at the Surveillance Program's goals, processes and ambitions. 

Which products are good candidates for surveillance?

Selecting Verified finished products for the Surveillance Program begins with a random group pulled from our database. From that list, we ask a series of questions, narrowing the selection down to products that will generate meaningful and accurate results while addressing the most impactful aspects of the supply chain. 

"Does it contain a high-risk ingredient?" — The first question we ask is about risk status. The term "high risk" indicates that the GMO version of a crop is so commonplace in the supply chain that a buyer would likely end up with a GMO unless they intentionally looked for a non-GMO version. "High risk" does not indicate an inherent danger to human, animal or environmental health. 

Assigning risk statuses helps us focus scrutiny on the parts of the supply chain where we're most likely to encounter GMOs. You can learn more about risk status here.

"Is the high-risk ingredient testable?" — Not all GMO crops are detectable through commercially available tests. In recent years, we've seen a dramatic increase in non-testable GMO crops. The Product Verification Program and the Surveillance Program have evolved to address the issue of non-testable GMOs while maintaining program rigor. 

Products made with non-testable GMOs are still part of the Surveillance Program. Still, the review process differs from products made with testable high-risk ingredients — we'll explore testability in greater depth below.

"How processed is the high-risk ingredient? How processed is the finished product?" — Processing can degrade DNA, making it harder to detect genetically modified DNA through testing, which is particularly significant when reviewing finished products. Processing includes any manufacturing step to transform the raw agricultural product into a finished, consumer-ready product, such as cooking, milling or refining.

Let's see how processing impacts different products made with corn, a high-risk crop, to see how this plays out. Corn shows up in a variety of forms, which directly impacts surveillance.

Example #1 — Corn oil. While the main ingredient of corn oil is corn, corn oil is a highly refined product. We know that processing can degrade DNA, and that is particularly true for refined oils. Generally, if you can see through a product, it's unlikely to be a good candidate for surveillance. Refined corn oil is unlikely to contain sufficient intact DNA for testing, making it a poor candidate for surveillance.

Example #2 — Corn flour. Like corn oil, corn flour is made from corn as the main ingredient. However, unlike corn oil, it is minimally processed, leaving sufficient DNA for an accurate test result. Corn flour would be a good candidate for surveillance testing.

Example #3 — Baked goods. What if the product we're checking is a baked good made with corn flour, corn oil or cornstarch as one of many ingredients? This one is tricky. Remember that corn oil is too refined for testing. The corn flour might produce an accurate test result depending on how much of it is in the product formulation. The testability of cornstarch varies depending on how it is processed. However, the amount in each product unit is likely too small to produce an accurate test result. With so many variables at play, our team's technical expertise would be crucial to determining next steps.

Rest assured that even the products not selected for surveillance are still thoroughly evaluated by independent technical administrators during verification.

Having narrowed the selection to the most impactful products, the surveillance team procures products. We look for products in the same places shoppers get them: brick-and-mortar stores and online retailers. This approach ensures that our samples honestly reflect what the public buys and consumes, though it does involve some practical limitations. Not all products are available or in stock when we want them. Our team is based in the U.S., while the Non-GMO Project label can be found on products for sale in Canada and Mexico, too — we might not have access to products sold across national borders. Perishable or refrigerated products pose unique challenges.

The Surveillance Program reviews at least 1% of all Verified products (currently more than 64K) each year, amounting to hundreds of products made with high-risk ingredients that undergo extra scrutiny and testing.

How testability impacts surveillance

When the surveillance program began in 2016, all the crops on the High-Risk List were testable. Since that time, the biotechnology landscape has changed. Non-testable GMOs have become much more common.

When we refer to a crop as "testable," we mean there are commercially available tests that can pick up the presence of modified DNA. Of course, ingredients and derivatives made from a testable GMO crop aren't necessarily testable because processing can degrade DNA (this is particularly important with surveillance, which deals exclusively with finished products). We prioritize products made with minimally processed high-risk ingredients to make the most of the Surveillance Program's resources.

A "non-testable" GMO means there is a GMO crop for which no commercially available test is currently available. The difference between the two often comes down to how the GMOs are made. Regulators often required developers of older GMOs to produce a test for their product to bring it to market. However, GMOs made from newer techniques don't necessarily face the same regulatory hurdles. GMO developers are unlikely to provide a test if regulators don't require one.

To be clear, GMO crops, whether made with old techniques or new ones, are not inherently untestable. Testability comes down to whether a test has been developed, not whether a test could be developed. For our purposes, if no widely available and reliable test exists on the market, that GMO crop is considered non-testable.

The rise of non-testable GMOs in the supply chain has driven evolution in product verification and surveillance to ensure the Standard remains meaningful, regardless of testability. New processes are in place specifically to address the rise of non-testable GMOs in the supply chain, and verification relies on legally binding documentation such as affidavits. Surveillance of products made with non-testable, high-risk crops involves a document-based review. 

The question of compliance

The vast majority of Verified products reviewed under the Surveillance Program are in compliance with the Non-GMO Project Standard, meaning that they meet the requirements of the Standard. The required documentation is up-to-date and test results show that modified DNA does not exceed the action threshold. High levels of compliance show that the Product Verification Program sets an achievable benchmark and most brands and third-party technical administrators have checked every box during the verification process. 

The Non-GMO Project invests a great deal of thoughtfulness and expertise into the Surveillance Program. Surveillance draws on technical expertise and supply chain vigilance to keep the Butterfly soaring. It illuminates where the Non-GMO Project Standard supports our goals and where there are opportunities to refine our approach, collaborate with stakeholders and increase our efficacy. We continually look for ways to improve it and glean more valuable insights.

Surveillance is a compelling measurement of how well the Butterfly delivers on its promises to shoppers and eaters across North America.