Troublesome Issues with Compliance
GMO Regulations, Domestic and Abroad
The Russian’s Concern with Pet Food
For North American exporters, keeping abreast of this dynamic global economy can be harrowing. Sometimes, regulatory authorities roll out changes faster than exporters can adjust. This is frustrating for many North American food exporters who must continually monitor and adjust… monitor and adjust… monitor and adjust, often with valuable product in detain halfway across the world. Something is always popping up to cause problems. It’s like having six corks in the water but only five fingers to keep them submerged.
Just as troublesome is the increased cost of compliance that may be associated with regulatory compliance. Let’s be clear – regulatory compliance can be positive, productive, and is requisite. Compliance is a necessary cost of doing business. At the same time, global regulations can be wielded as a barrier to entry, exacting high certification and verification costs that many manufacturers cannot or will not pay. Even if a food manufacturer decides to remain in a market, they may have to add additional compliance costs to their price points potentially pricing them right out of the competition.
In the GMO world, The National Bioengineered Food Disclosure Standard (NBFDS) is the primary focus of food manufacturers here in the United States. The new U.S. regs apply to imported products as well, impacting manufacturers from all over the world. And while the NBFDS certainly affects many companies both in the U.S. and abroad, a critical development in Russia has hit the GMO radar in a big way with regs that are generally tougher than those of the E.U. creating significant challenges for pet food and feed manufacturers exporting their products to Russia.
To be sure, bioengineered foods have moved front and center as a growing number of consumers demand “healthier,” “cleaner” options for themselves, their families, and their pets. Different countries have different GMO standards while consumers the world over are unifying in their preference for transparent food options. Things can get confusing. In Russia, regulations governing GMO’s in pet food have tightened to the extent that some exporters are considering withdrawing from the market. Specifically, Russia does not permit any GMO’s in imported pet food. Any GMO detected must quantify less than 0.5% per event. For animal feed, Russia has approved 4 corn (T25, Bt11, 3272, and MIR162) and 1 soy event (Mon89788). The presence of any other unapproved GMO’s is limited to 0.5% per event.
At the moment, the primary concerns appear to be corn, soy, and canola cultivars. Still, the restrictions theoretically apply to all possible GMO crops including alfalfa, rice, potato, sugarbeet, and apple. Compliance poses quite a challenge. Theoretically, a company exporting pet food to Russia would have to test for every GMO possibility even if the crop is not in the recipe formulation, such as foreign material or dockage for instance.
Submitting finished product is problematic, and the Russians rightfully point this out. Finished product testing is a bucket – not a can — of worms. This is because GMO testing on finished product (as opposed to raw ingredient testing like that required by the Non-GMO Project, for example) will never fully determine the GMO content because there is no way of determining with certainty all the exact sources of positive hits in a complex finished matrix.
The potential cost of compliance can discourage exporters or even price them out of the market. Indeed, companies are assessing the benefits of compliance against withdrawing from the Russian market entirely due to overhead costs and the need to raise prices. For example, if a finished feed sample tests positive for P-35S, verification testing must cover all events in all cultivars in which this marker can be found except the four corn and one soy event I noted above. Once that screen is complete, any hits have to be quantified against the 0.5% threshold.
The Russians are stricter with pet food, and this reflects a growing trend among consumers as well. There are no approved GMO’s for pet food in Russia. Any inclusion of GMO, inadvertent or otherwise, must be quantified and total less than 0.5% per event. Again, Russian authorities seem concerned only with corn, soy, and canola at the moment although that can change at any time. So, a sample of kibble that hits on P-35S would need to be tested for any corn, soy, or canola cultivar containing this marker, assuming any one lab is even capable of screening every single event in each of these crops. Any event-specific hits need to be quantified at less than 0.5% per event.
As you can see, event-specific quantification in complex mixed matrices can be daunting. Pet food can contain many different ingredients, several of which could derive from GMO sources. Requirements can be challenging. Nevertheless, this is a reality of the business environment in Russia and many other countries.
What Can Mérieux NutriSciences Do For You?
Mérieux NutriSciences GMO Services is committed to assisting our clients with balancing regulatory requirements, budgetary concerns, and the realities of the marketplace. The GMO Services program at Mérieux NutriSciences has been working diligently with government authorities and North American pet food manufacturers to develop a testing protocol specifically designed for pet food and feed exports to Russia. The foundation of this testing platform can be adapted to a variety of product types headed to any number of countries. We also work regularly with companies building strategies for managing the National Bioengineered Food Disclosure Standard.