ISCC for Non GMO food and feed

ISCC for Non GMO food & feed ISCC for Non GMO food and feed V 01 24/06/2016

Copyright notice ISCC 2016 This ISCC document is protected by copyright. It is freely available from the ISCC website or upon request. No part of this copyrighted document might be changed or amended. The document might not be duplicated or copied in any form or by any means for commercial purpose without permission of ISCC. Document title: Application date: ISCC for Non GMO food and feed x

Content Content... 3! 1 Abbreviations... 4! 2 Introduction... 4! 3 Reference documents... 5! 4 Requirements... 5! 4.1 Economic operators... 5! General requirements... 5! Requirements for food producers... 5! Requirements for feed producers... 6! 4.2 Certification and auditor requirements... 6! Certification and audits... 6! Scope of audit... 7! Auditor competency... 7! ISCC Non GMO for food & feed 3 von 7

1 Abbreviations 1829/2003/EC 1830/2003/EC GM GMO EGGenTDurchfG QS Regulation (EC) on genetically modified food and feed Regulation (EC) concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms Genetically modified Genetically modified organism EC Genetic Engineering Implementation Act (EG-Gentechnik- Durchführungsgesetz) Quality and Security System 2 Introduction The hereinafter-described ISCC system for Non GMO food & feed is a module for the sole certification of non-genetically modified materials and products. It is applicable for food and feed products and completely independent from the general ISCC certification of environmental, social and economic sustainability on farm level, zero deforestation or Add-ons, such as the greenhouse gas emissions. The objective of this document is to set requirements for a labeling of Non GMO food & feed products in accordance with the EC Genetic Engineering Implementation Act 3a and 3b (EGGenTDurchfG). It is globally applicable. Producers of final food or feed products, which fulfill the respective requirements of this document can label their products with the claim Non GMO for food or Non GMO for feed depending on the markets they want to deliver the products to. E.g. Soybean oil, which fulfills the requirements for Non GMO for feed but not Non GMO for food can be sold into the feed market. If it fulfills both standards, it can be sold into both markets (to the feed market with the label Non GMO for feed and to the food market with the label Non GmO for food ). The specific requirements for a successful certification of final producers of food or feed products are highlighted in chapter 4. The requirements of this document only refer to non-animal raw materials and products. If animal-based components are used, further requirements under the EGGenTDurchfG become valid, which are currently not covered by ISCC Non GMO for food and feed. ISCC Non GMO for food & feed 4 von 7

3 Reference documents Relevant ISCC documents for a successful certification against the ISCC Non GMO for food & feed: ISCC 201 ISCC 204 ISCC 207 ISCC 251 ISCC 252 System Basics Mass Balance Calculation Risk Management Requirements on Certification Bodies Regulations to carry out Audits If requirements of this document deviate from requirements within the above ISCC documents, they will further be specified in the following sections. 4 Requirements 4.1 Economic operators General requirements In general all regulatory requirements for non-genetically modified products shall be fulfilled. Any materials (including raw materials, auxiliaries, additives) that are used to produce Non GMO for food or Non GMO for feed shall at no circumstances be genetically modified materials being subject to GM labeling under the 1829/2003/EC or 1830/2003/EC. This means that the threshold value of 0.9% GM ratio of each raw material and product shall not be exceeded and any contamination should be accidental or technical unavoidable. A physical segregation (temporal, spatial) of raw materials and products fulfilling the different ISCC Non GMO requirements ( Non GMO for food or Non GMO for feed ) from other raw materials and products is required for the processing, manufacturing, storing or transporting steps. If a product shall be labeled as Non GMO for food it must be also physically segregated from Non GMO for feed raw materials and products. Requirements for food producers For food products, contamination up to the detection limit of 0.1% GM ratio is tolerated for each raw material. Contaminations below this limit are regarded as accidental or technically unavoidable. If for certain additives, like vitamins, it can be shown that they are not available in genetically free quality, die exemption rule applies, which allows to use such, produced through GMO. 1 In order to use the label Non GMO for food, a successful certification of the final food producer against the following requirements is required. The upstream processing and manufacturing step supplying the raw material, can be fulfill its burden of proof by 1 Precondition is the listing of such additives by the EU Commission ISCC Non GMO for food & feed 5 von 7

Delivering an annual conformity declaration (e.g. through an analysis from a testing institute or a legally binding declaration); or Adding information on the delivery note; or Arranging an explicit contractual agreement Following 3b of the EGGenTDurchfG appropriate proofs for raw materials, which fulfill the general requirements, would also be analysis results or a documentation that show that the prerequisites for the labeling of Non GMO for food are complied with. Traders or logistics companies should also be integrated in the monitoring concept. However, in case of low contamination risk, they do not have to be certified by an independent auditor. Requirements for feed producers In order to use the label Non GMO for feed, a successful certification of the final feed producer against the following requirements is needed. It must be proven that appropriate steps have been taken to avoid a contamination with GMOs (e.g. through contractual agreements with the suppliers, measures to separate GMO from Non-GMO temporarily or spatial and suitable precautionary measures for raw materials from third countries). Minor contaminations (<0.9% GM ratio) are tolerated if they are accidental or technical unavoidable. Auxiliaries for feed products, which have been produced by genetically modified organisms, are accepted for feed production. 4.2 Certification and auditor requirements Certification and audits An independent certification by one of ISCC recognized and accredited certification bodies is mandatory for the final producer of the feed and food product and for all manufacturers/processors, who want to label their products with the specific claim Non GMO for food or Non GMO for feed. For upstream processing and manufacturing steps, which do not want to label their products with the specific claim Non GMO for food or Non GMO for feed, an independent certification is not required. However, we highly recommend an independent certification in the following cases: The economic operator obtains raw materials from countries, where an permit for the cultivation of genetically-modified variations exists (e.g. soy from Brazil) The economic operator of the labeled food or a producer of respective raw materials also produces similar food products, which are GMO or which do not classify under Non GMO for food Food products, which include more than 5 ingredients/raw materials Combined audits with the VLOG standard are possible in order to gain synergy effects. The VLOG checklists are regarded as equivalent with the ISCC Non GMO for food and feed checklist. ISCC Non GMO for food & feed 6 von 7

For the certification of feed producers also recognized quality management standards such as QS or GMP+ can be used to reduce the audit effort to specific topics only relating to Non GMO for feed. Scope of audit For a successful audit, the following requirements are checked: Management system including responsibilities, record-keeping, risk management (as integrated in the ISCC document mass balance, risk management and system basics). However, the management system shall only refer the specific requirements of ISCC Non GMO for food & feed. All other requirements of the ISCC documents (e.g. referring to sustainability or Chain of Custody for sustainability claims) do not apply Supplier and recipient information (e.g. conformity declarations from Non GMO suppliers) and control of mass balance/quantity flow Physical segregation With successfully completing the certification audit the auditor issues the ISCC certificate for Non GMO food and feed. The certificate highlights next to the general information on the economic operator and validity of the certificate also the products (raw material specific), that have been qualified under Non GMO for food and the products that have been qualified under Non GMO for feed. Auditor competency The auditor needs the same audit competency as for a normal ISCC audit. However, the competency must clearly relate to the ISCC Non GMO for food & feed. ISCC sustainability specifics, such as GHG emissions, does not need to be covered by an auditor compiling Non GMO audits. An ISCC basic training is also not required for auditors verifying the compliance with this module. However, a sound understanding of Non GMO and QS requirements and respective audit experience must be proven. ISCC Non GMO for food & feed 7 von 7