Procedures for Including a “Non-Genetically Engineered” Statement

For meat or poultry products that are certified to the USDA organic regulations at 7 CFR part 205, an establishment may add a statement to the label of such a product about the non-use of genetically engineered ingredients or genetically engineered feed provided to animals used in the product if the establishment notifies FSIS’s Labeling and Policy Delivery Staff (LPDS) by letter on company letterhead that it will be doing so using the following procedures:

Step 1 – The establishment submits a notification letter that includes:

1. 1. The FSIS approval number for their current organic label and a copy of the current label. 
   2. The “Non-Genetically Engineered” statement that the company will be applying.  The statement may relate to the ingredients in a multi-ingredient product or the feed given to the animals during their raising.   The statement also needs to reference the fact that the USDA organic regulations do not permit the use of genetically engineered ingredients or meat from animals that were fed genetically engineered ingredients to bear an organic claim.  An example of a claim that FSIS may permit is: “The beef used in this product is fed a diet that contains non-genetically engineered ingredients.  The USDA organic regulations prohibit the use of Genetically Engineered Feed Ingredients.” Under 7 CFR part 205, the claim must be truthful and not misleading.

Step 2 -LPDS verifies that the organic approval is valid, and sends an acknowledgment letter to the establishment.  The acknowledgment letter will advise the establishment that it needs to amend its labeling record to include the letter to LPDS and a copy of the updated label that includes the “Non-Genetically Engineered” statement in its final form before the product moves into commerce. Once Step 2 is completed, the establishment may begin using its updated label on products in commerce.

Step 3 - FSIS will verify that the labeling record is complete during inspection.  The establishment will be given a non-compliance record during label verification activities under FSIS Directive 7221.1 if this action is not properly documented in the establishment’s labeling records.

For additional information about FSIS labeling policies and programs, review the FSIS Web Site at:  http://www.fsis.usda.gov/wps/portal/fsis/topics/regulatory-compliance/labeling or contact the Labeling and Program Delivery Staff at (301) 504-0878.