Approaches on GM Food Labelling

The regulatory approaches on GM food labelling vary in different countries and areas, and can be broadly classified as voluntary or mandatory.

For the voluntary labelling approach, only GM food that is significantly different from its conventional counterpart, in terms of composition, nutritional value and allergenicity, needs to be labelled.

For the mandatory labelling approach, it can be further classified as two categories, i.e. "pan-labelling" or "labelling for designated products only". The "pan-labelling" category requires that any food products, which contain GM materials exceeding a threshold level or have any significantly different characteristics as a result of genetic modification, must be labelled. The "labelling for designated products only" category requires that only the designated products, which are genetically modified, need to be labelled.

International Practices on GM Food Labelling

The Codex Alimentarius Commission (Codex) considers that governments of different places may make their own decisions on whether or not to label GM food, and emphasises that labelling arrangements should be in conformity with the provisions promulgated by the Codex to avoid potential trade issues. At present, policies on GM food labelling vary in different countries and areas:

1. Mainland China

   The "Implementation Regulations on Labelling of Agricultural Genetically Modified Organisms"《農業轉基因生物標識管理辦法》 stipulates that five categories of GM crops including soya bean, corn, cotton, canola and tomato, as well as some of their products are required to be labelled.

2. Canada

   Labelling of GM foods is only required when the food is significantly different from its conventional counterpart in terms of composition, nutrition and allergenicity. However, the trade may label other GM foods on a voluntary basis. In Canada, a set of guidelines for voluntary labelling of GM foods has been issued.

3. The United States

   GM foods must be labelled in the United States starting from January 2022.  There are several labelling options: text, symbol, electronic or digital link, and/or text message. Additional options such as a phone number or web address are available to small food manufacturers or for small and very small packages. A threshold in the labeling standard allows for the inadvertent or technically unavoidable presence of a GM substance, of up to 5%, in each ingredient.  The labeling standard does not cover ingredients or products in which the modified genetic material is not detectable.

4. Member countries from the European Union

   All GM foods have had to be labelled in countries of the European Union. The requirement stipulates that all foods produced from Genetically Modified Organisms (GMOs) should be labelled, irrespective of whether DNA or protein of GM origin is detectable in the final product. Moreover, conventional foods with adventitious presence of GM materials of higher than 0.9% should also be labelled.

5. Australia and New Zealand

   The Australia and New Zealand authorities decided that all food products produced or imported had to be labelled when any of their ingredients contains more than 1% GM material. Additional labelling was also required for GM food ingredients with significantly altered characteristics. Highly refined foods, processing aids or food additives with the absence of GM materials, flavours in a concentration no more than 1g/kg in the final food, as well as foods prepared at point of sale are exempted from the GM food labelling requirement.

6. Japan

   The Japanese authorities have required designated agricultural products and processed food items containing GM materials to be labelled. For the processed food items, those ingredients containing GM materials that are ranked within the top three constituents in terms of weight and the weight ratio of which account for five percent or more of the total weight have to be labelled. Labelling is not required for oil and sauce, where the original GM materials can no longer be detected.

7. Republic of Korea

   The Korean authority requires that all approved genetically modified agricultural products (including vegetables grown using the genetically modified agricultural products, such as bean sprouts and bean leaves), which contain more than 3% GM materials have to be labelled.

8. Other places in Asia

   Some other Asian countries such as Thailand and Vietnam have also set up regulations on GM food labelling.

Pros and Cons of Major Labelling Approaches

Voluntary Labelling Approach

1. Pros
   • Appropriate labels on GM foods which are significantly different from their conventional counterparts help to alert consumers of their differences in terms of allergenicity, nutrition and toxicity. Therefore, this labelling approach addresses the basic concerns of most consumers and hence safeguards public health against any potential risks.
   • This approach imposes fewer barriers and constitutes less trade implications.
   • This labelling approach would not significantly affect the cost of food production.
2. Cons
   • Consumers would not know whether the food contains any GM materials. This labelling approach hence limits their rights to "informed choices". Some consumers would like to make their choices not only based on food safety grounds but also taking environmental, social or ethical issues into consideration.

Mandatory Labelling Approach

1. "Pan-labelling"
   1. Pros
      • Labelling of all GM foods enables consumers to know whether the food contains any GM materials at all and hence make informed choices.
      • Moreover, it helps to enhance surveillance and tracing on GM food.
   2. Cons
      • Additional costs to the trade would be incurred. However, these costs would either be absorbed by the trade or passed on to the consumers and hence the extent of any price changes due to labelling GM food is uncertain. Additional costs of labelling GM food may arise from:
        1. At present, GM crops/foods and non-GM crops/foods are often mixed together during harvesting, storage or processing. It would be necessary to establish a system to segregate these crops along the food supply chain, especially when the trade would like to source for non-GM food products. Hence additional cost would be incurred to establish and maintain segregation systems.
        2. The detection and identification of GM foods, which require sophisticated laboratory tests, might also incur additional cost.
      • The requirement to label all GM foods is not easy to enforce because:
        1. Not all GM food products are readily identifiable by end-product analysis.
        2. Adventitious mixing of GM and non-GM crops may occur during processing and storage, hence establishment of threshold level may be necessary to determine whether the batch of food product is GM or not. However, there is no international consensus on threshold level for GM food labelling.
2. "Labelling for designated products only"
   1. Pros
      • Labelling for designated food products enables consumers to know whether the designated food items contain any GM materials and hence make informed choices.
      • Moreover, this labelling requirement is possible to be enforced.
   2. Cons
      • It might not address the need of consumers who would like to know whether the non-designated food items contain any GM materials or not.
      • Additional costs might be added to the designated food items.

The pros and cons of the above labelling approaches are summarised below:

Issues to be Considered in Setting Up a Labelling System

Different labelling approaches have their merits and shortcomings. Issues to be considered in setting up a practical and balanced labelling system include:

1. Limitation of Detection Methods

Difficulties in detection of GM materials include:-

• Not all GM food products can be identified by end-product analysis.

• Detection methods for highly processed foods e.g. soy lecithin are less sensitive and reliable when compared with raw or lightly processed foods, e.g. tofu (soy).

• For highly refined food items such as oil and sugar, it is impossible to detect the presence of any GM materials.

• There is no single test that can be used to detect all types of GM materials.

2. Present Practices of the Food Supply Chain

Since GM and non-GM crops are often mixed together during harvest, transportation, processing and storage, it is difficult to determine the GM status of the respective crops/foods. Therefore, a system to segregate GM and non-GM products at various stages of processing along the food supply chain needs to be set up and maintained.

3. Costs of Compliance

The costs of compliance with GM food labelling requirement will either be absorbed by the trade or passed on to the consumers and hence the extent of any price changes due to labelling of GM food is uncertain in the short run.

4. International Practices

The Codex Alimentarius Commission, the authority for setting food-related standards under the United Nations, considers that governments of different places may make their own decisions on whether or not to label GM food.