The members of the National Sustainable Agriculture Coalition (NSAC) care deeply about ensuring the integrity of agricultural product labeling claims on behalf of consumers and producers. For this reason, NSAC submitted comments in response to the U.S. Department of Agriculture’s (USDA) GMO Labeling Proposed Rule. Today is the last day to submit comments.

Many of the farmers with whom NSAC works choose to grow only non-genetically engineered (GE) crop varieties. They make this choice for many reasons: because the markets they serve demand GE-free products; because they have concerns about potential adverse economic, environmental, and agronomic impacts of GE crop technologies; or because they are USDA certified organic and not allowed to grow GE crops. NSAC therefore supports marketplace transparency regarding whether products have been produced with GE crops and technologies. However, we have grave concerns about the proposed rule, which we believe fails to ensure a robust, meaningful, and value-neutral labeling standard that will provide confidence to producers and consumers alike.

NSAC provided comments on the proposed rule to highlight the sustainable agriculture perspective in this debate, and to dispel the notion that this label is only about consumers concerned with the safety of their food. Rather, this label provides purchasers with information about the systems and processes that went into the production of their food, and the very real opportunity to vote with their food dollars for the type of agricultural system they wish to support.

NSAC believes labeling claims with integrity are rooted in the following principles:

• Clarity/Simplicity of Meaning: The claim must be clear enough to distinguish certain producers’ products from others in the marketplace and convey information about practices that is meaningful for consumers to know, and not create confusion in the marketplace beyond what would be expected from legitimate competition.
• Transparency of Process: A transparent process for developing, using, and verifying a particular labeling claim is essential in order to establish the integrity and meaning of the claim in the eyes of the public.
• Accountability: In order for the labeling claim to retain its meaning and integrity, misuse of the label must incur consequences.
• Stakeholder Engagement: The involvement of a variety of stakeholders, including producers and consumers, helps ensure the labeling claim is meaningful, reasonable, and rigorous, which in turn helps to establish legitimacy in the marketplace.
• Independence: The degree of independence of the parties involved in verification increases in importance along with the distance in the relationship and/or the supply chain between producer and consumer.
• Fairness/Equity: Information about the labeling claim should be readily accessible knowledge to all affected producers, and equitably accessible to consumers. The cost or bureaucratic requirements to use a labeling claim should not be prohibitive to small, disadvantaged, or limited capacity producers; nor should the method for accessing information behind the labeling claim be cost-prohibitive or otherwise difficult to access for consumers.
• Value/Effectiveness: Use of the labeling claim has a positive impact on (or at least does no harm to) the future of family farming, sustainable farm and food systems, community development, and/or the environment.

We believe that the proposed labeling requirements fail to meet many of these principles, and will therefore fail to ensure integrity in the marketplace.

We recommend that USDA:

• Include GE and Genetically Modified Organism (GMO) as interchangeable with the proposed “bioengineered” or “BE” disclosure statements. Given the ubiquity of the term GMO, and the markets that have been built utilizing the term, we strongly recommend that AMS use the authority Congress granted it to include “GMO” and Genetically Engineered” into the disclosure standard as terms that are interchangeable with “bioengineered” and are more readily understood by consumers and the industry.
• Broadly define bioengineered such that both transgenic and gene editing techniques trigger the disclosure requirement, and disclosure should be required of products containing highly refined ingredients produced with GE crops and technologies such as oils and sugars.
• Adopt a symbol that is clear and value-neutral. The USDA Organic seal or the Process Verified shield provide examples of a straightforward, unambiguous, and non-promotional symbol. An appropriate symbol would not be easily confused with any existing symbols (such as the USDA Organic seal), and should not convey any positive or negative attributes, unlike the current proposed symbols.
• Align the threshold with existing industry and international trading partner expectations such that any intentional use of GE material in food manufacturing should trigger the requirement to disclose, and the inadvertent or technically unavoidable presence of GE material should not exceed 0.9 percent before triggering the requirement to disclose.
• Establish strong rules that govern the use of QR codes, and provide meaningful comparable options to accessing the disclosure if electronic or digital disclosure is selected to ensure that product information is equitably accessible.
• Not disrupt existing Organic and non-GMO marketing claims.
• Make the most of its enforcement authority by developing, publicizing, and then implementing a regular schedule for conducting audits, and making the results of those audits available to the public in a timely and accessible manner.

You can read our comments in full here.