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Question: What challenges or opportunities might arise if Inputs that are typically not evaluated were assessed to confirm they do not contain prohibited substances?

Context: Notably, prohibited substances include controlled substances, recombinant bovine somatotropin (rBST), GM animals, and Synthetic Biology/synthetic biology. View more context for Question 1

Note: Participants are responsible for understanding and ensuring compliance with all relevant legal obligations beyond the Standard.

Question: The Project has proposed language that more clearly prohibits biological compounds naturally produced by humans but synthesized in host organisms using human genetic material. What unintended consequences, if any, could arise from this proposal? Are there other factors the Project should consider to address potential issues

Context: The proposed change aims to increase visibility around the prohibition of biological compounds that are naturally produced by humans but instead synthesized through heterologous expression. Heterologous expression allows an organism—such as yeast or bacteria—to produce a protein by inserting a gene from another organism. This method is used to manufacture human collagen for supplements and skincare, as well as non-human compounds like animal-free dairy proteins and vanillin. View more context for Question 2

Question: The Project has proposed language that more clearly prohibits biological compounds naturally produced by humans but synthesized in host organisms using human genetic material. Could the proposed language, specifically application of the term “heterologous expression” which currently applies only to human biological compounds, be expanded to include other compounds, such as animal-free dairy proteins and vanillin? How practical and effective would this approach be for broader applications?

Context: Heterologous expression allows an organism—such as yeast or bacteria—to produce a protein by inserting a gene from another organism. This method is used to manufacture human collagen for supplements and skincare, as well as non-human compounds like animal-free dairy proteins and vanillin. View more context for Question 3

Question: How might removing the Micro Exemption for Enzymes named in text on the Principal Display Panel and simultaneously listed on the Ingredient Panel affect compliance with the Standard? What challenges or opportunities could this create for you or others, like manufacturers or processors?

Context: A Micro Exemption allows certain Ingredients present at less than 0.5% by Weight Percentage to be used without proving Non-GMO sourcing. However, these exemptions are limited—not all Micro Ingredients qualify, and the total amount of Micro Exempted Ingredients cannot exceed 0.9% of a Product’s Weight Percentage. View more context for Question 4

Question: Which potential changes would be most effective in improving access to Certificates of Verification (COV) for businesses and stakeholders? Please rank all three options in order of importance, with 1 being the most important and 3 being the least important. If “I choose not to answer” is ranked as 1, the question will remain unanswered.

Context: Feedback indicates that accessing the Certificate of Verification (COV) can be challenging. On average, the Project receives 20 COV requests per month through the Technical Administrator confirmation process. View more context for Question 5

Question: What specific changes to the Standard could help overcome existing challenges while improving the value, usability, or accessibility of Verified Ingredients for businesses and other stakeholders?

Context: In the supply chain, a Verified Product—such as Non-GMO Project Verified cornstarch—becomes a Verified Ingredient when purchased by another business and incorporated into a different Product’s recipe. View more context for Question 6

Question: How should the Standard address inspection requirements and compliance criteria to ensure they are both meaningful and achievable for businesses sourcing Verified Ingredients for their Products seeking Non-GMO Project Verification?

Context: Currently, a “Verified” Risk Status may not explicitly trigger inspections during Parallel Processing. For example, a facility processing both Verified single-Ingredient cornstarch and conventional single-Ingredient cornstarch may not be inspected if the Verified cornstarch is purchased as a Verified Ingredient from a supplier. If “Verified” is reclassified as a compliance pathway, facilities processing both Verified and conventional Ingredients may be required to undergo inspections. View more context for Question 7

Question: What additional data, evidence, or supply chain practices should the Project consider regarding the risk of GM cane sugar entering the Non-GMO supply chain? How does this information support or oppose adding sugarcane to the High-Risk List and requiring an Affidavit to confirm Non-GMO sourcing?

Context: Publicly available data from the 2023/2024 planting season in Brazil indicates that sugarcane was planted and harvested across 9.5 million hectares, with GM sugarcane adoption at 0.45%, totaling approximately 42,750 hectares (USDA GAIN Reports). View more context for Question 8

Question: What changes to the Standard could enhance, refine, or streamline the current Chain of Custody requirements?

Context: Chain of Custody refers to the processes and documentation needed to ensure Non-GMO materials are kept separate, traceable, and compliant with the Standard throughout the supply chain. View more context for Question 9