Download To: Deerland Enzymes customers From : Hope Hanley, VP of QA

To:
Deerland Enzymes customers
From :
Hope Hanley, VP of QA and Regulatory Affairs
Date :
September 25, 2014
Subject :
Clarification on Non-GMO Position Statements
With the recent momentum of the non-GMO Project (NGP) we have been receiving significantly
more inquires about the status of our non-GMO enzymes and associated products contained
within our applicable formulations. The rigorous NGP guidelines have also created a lot of
confusion across many Dietary Supplement ingredients and hence, I felt the need to provide the
following update:
Historically, Deerland has obtained statements from each supplier indicating that the products
(both enzymes and non-enzymes) we purchase are considered non –GMO. In light of this, I
wanted to provide the following as guidance and clarification to Deerland’s non-GMO position
statements. Currently, our product specifications in many cases may include verbiage that
states “all ingredients used in the formulation are certified by the manufacture to be non-GMO.”
To ensure there is an across the board understanding of what we mean when we say this, please
find the following:
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All enzymes used in Deerland formulations are from non-GMO strains (microorganism)
If the formulations contains corn maltodextrin added by Deerland, it is produced in a
documented IP system
If the formulations contains probiotics, each probiotic consists of non-GMO strains
(microorganism).
For all other ingredients, we have vendor confirmation that it is non-GMO, but we do
not confirm their statement, nor do we know the legal or published standard used as a
basis for their statement.
Please note that our position above DOES NOT mean:
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That the formulation meets the requirements laid out in the NON-GMO PROJECT
VERIFIED Standard. This is primary due to ongoing changes made by the NGP on the
status of non-GMO traceability, which most recently includes the need to provide that
second and third generation ingredients are non-GMO validated; which is not something
our suppliers or many other DS ingredient suppliers are willing to do at this time.
That the ingredients used in the formulation meet any other international
legal/regulatory standard.
As a result of this, we feel it is necessary to revise the statements on our specifications. An
example of the new statement is “The microorganisms used to produce the enzymes in this
formulation are certified by the manufacturer to be non-GMO.”
We will of course monitor changes to the non-GMO statutes in the industry and work with our
vendors to further clarify their non-GMO statements as needed/able. Until such time, if a
customer is requesting a non-GMO statement, we will evaluate each ingredient and issue an
appropriate statement based on the information provided. We will attempt to confirm that the
product meets one of two standards, either the EU standard, which specifically exempts
processing aids and will allow for up to 0.9% of unintentional GM “contamination” or the USDA
National Organics Program standard that requires ingredients not contain or be produced from
GM ingredients.
As an FYI, below is a list of high risk crops, for which GM versions are being researched, and
typical high risk ingredients. If a customers’ formulation contains product derived from any of
these crops or ingredients (with the exception of our maltodextrin), we will highly recommend
that they do NOT label their formulation as non-GMO.
High- Risk Crops (in commercial production)
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Alfalfa (first planting 2011)
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Canola (approx. 90% of U.S. crop)
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Corn (approx. 88% of U.S. crop in 2011)
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Cotton (approx. 90% of U.S. crop in 2011)
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Papaya, i.e. papain (most of Hawaiian crop; approximately 988 acres)
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Soy (approx. 94% of U.S. crop in 2011) – used extensively as fermentation media for
enzymes.
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Sugar Beets (approx. 95% of U.S. crop in 2010)
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Zucchini and Yellow Summer Squash (approx. 25,000 acres)
Monitored Crops (those for which suspected or known incidents of contamination have
occurred)
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Beta vulgaris (e.g., chard, table beets)
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Brassica napa (e.g., rutabaga, Siberian kale)
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Brassica rapa (e.g., bok choy, mizuna, Chinese cabbage, turnip, rapini, tatsoi)
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Cucurbita (acorn squash, delicata squash, patty pan)
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Flax
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Rice
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Wheat
Common Ingredients Derived from GMO Risk Crops
Amino Acids, Aspartame, Ascorbic Acid, Sodium Ascorbate, Vitamin C, Citric Acid, Sodium
Citrate, Ethanol, Flavorings (“natural” and “artificial”), High-Fructose Corn Syrup, Hydrolyzed
Vegetable Protein, Lactic Acid, Maltodextrins, Molasses, Monosodium Glutamate, Sucrose,
Textured Vegetable Protein (TVP), Xanthan Gum, Vitamins, Yeast Products.
If a customer wishes to pursue certification through the NON-GMO VERIFIED PROJECT, we
encourage them to allow us to evaluate their formulation prior to submission. The Project
requires payment before they will evaluate a formulation and we would like the opportunity to
educate them on the possible obstacles to obtaining this certification prior to them incurring
this cost. Based on recent discussions, we are doubtful that enzymes will be approved unless
the customer is offering the enzymes in very small amounts (less than .9% of a formula) and do
not plan to market the enzymes as actives; which basically negates the reason they are used in
the first place.