KRAV’s GMO Risk List – Feed Production Background KRAV- certified companies must demonstrate that genetically modified organisms (GMOs) have not been used in certified production, and that the company has done everything it can to ensure that raw materials, additives and process aids do not contain GMOs.

The risk of GMO contamination and unintentional mixture into a product depends in part on the raw materials used in the production. This GMO risk list divides raw materials into two groups. Group 1 lists products with a high risk of GMO contamination and Group 2 lists products with a lower risk of GMO contamination. The documentation requirements for a company are different for each of these two groups (see below for each group).

A certificate showing that a raw material is organic also confirms that the product is not made with or from GMOs. For some products however there is a risk of GMO contamination in the handling chain, and in that case sampling and analysis is the safest way to show that the product is GMO free. If the feed is produced in a facility where GMO feed is also produced, the end product, i.e. the finished KRAV-certified feed, must also be analysed.

For organic feed, under certain conditions, small amounts of conventional ingredients can be included, at most 5%. In such cases, the manufacturer must submit a special confirmation that the raw material or additive is not made using GMOs. In addition, sampling and analysis is required for products with a high risk of GMO contamination.

According to the EU regulation, traces of authorized GMOs in organic produce and products are acceptable if the rate does not exceed 0.9%, on the condition that the presence is "adventitious or technically unavoidable." The KRAV standards prohibit this level of GMO contamination. For KRAV-certified products the maximum permitted GMO content is 0.1%, as this is the lowest concentration that can with certainty be determined using standard analytical methods.

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se

Risk List Group 1. Products with a High Risk of GMO Contamination

Group 1 includes the following types of products: 1. Products from crops where there is large-scale commercial or field-scale cultivation. 2. Products from GMO crops marketed in the EU in significant volumes. Note: If commercial cultivation does not occur in the EU, and takes place only in one to three other countries then "Only from" as well as the countries in question must be specified. 3. There are known cases of GMO contamination, possibly from a particular country (listed under "Only from"), though there is no commercial cultivation. raw materials and products

only from*

cotton products flaxseed and flaxseed products

comments e.g. cotton seed cakes

Canada

maize and maize products

e.g. linseed cake products often made from maize: maltodextrin, starch, fibre, HVP (hydrolysed vegetable protein)

canola and canola products

Canada, USA, Australia

rice products

China, USA, Iran

soy and soy products

products often made from soy: lecithin, HVP (hydrolysed vegetable protein), fibre

* ”Only from” refers to countries where the product is cultivated.

Verification Requirements

No further verification is required for KRAV-certified ingredients.

For organic raw materials that are not KRAV-certified* and for conventional raw materials:

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se

•

GMO-free certificate.

•

Sampling and analysis for each delivery of raw material. Analysis results should be traceable to the consignment concerned. The content of GMOs must not exceed 0.1%. (Read more under the heading "Sampling and Analysis") Where there is risk of contamination during production of the finished feed, each batch of finished product must be sampled and analysed. The content of GMOs must not exceed 0.1%.

and

•

* Certificates for organic raw materials certified by Soil Association or Bio Austria are adequate as these certifications are equivalent to KRAV certification with regard to GMOs. There may be other certifications that are equivalent with regard to GMOs, and these will be added in due course.

Group 2. Products with a Low Risk of GMO Contamination

Group 2 includes the following types of products: 1. Products from crops with experimental cultivation, but no commercial cultivation, at least not to any great extent. 2. Products from GMO crops approved for marketing in the EU, but with which there is no substantial trade. 3. Products that might be produced from genetically modified microorganisms (GMMOs).

2a Products that Might Be Produced With or Contain GMOs

raw materials and products

only from*

canola and canola products

all countries except: Canada, USA, Australia

rice products

all countries except: China, USA, Iran

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se

comments

fibres

sugar beet products

USA

sunflower seed products peanut products

USA

potatoes and potato products

Czech Republic

e.g. starch, potato protein, PROTAMYL

fishmeal from farmed fish

* ”Only from” refers to countries where the product is cultivated.

Verification Requirements

No further verification is required for KRAV-certified ingredients.

For organic raw materials that are not KRAV-certified* and for conventional raw materials: •

GMO-free certificate.

* Certificates for organic raw materials certified by Soil Association or Bio Austria are adequate as these certifications are equivalent to KRAV certification with regard to GMOs. There may be other certifications that are equivalent with regard to GMOs, and these will be added in due course.

2b Products that Might Be Produced With or Contain GMMOs (genetically modified microorganisms) additives and process aids

example

antioxidants flavourings bacterial preparations, microorganisms enzymes yeast preservatives

organic acids and their salts

stabilisers and emulsifiers

sodium alginate (fish feed), xanthan gum

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se

vitamins

Verification Requirements

For additives and process aids: •

A GMO-free certificate concerning the microorganisms used in the process. (For yeast and bacterial preparations, the certificate must be with reference to the product. The content of GMMOs must in that case be no greater than 0.1%.)

GMO-free Certificate

A GMO-free certificate can be based on that the crop is grown in a country where there is no GMO cultivation of the crop concerned, and that it can be shown that the segregation in further steps in the production have been maintained, i.e. that the consignment is only handled in systems where there are no GMOs or in closed containers.

A GMO-free certificate can also be based on that sampling takes place at critical control points according to the principles of the IP system (Identity Preservation System).

The certificate must state: the product’s name and consignment number.

The certificate can be one of the following two alternatives: •

self-declaration in Annex XIII (EC) No 889/2008 (see Appendix 1)

•

A certificate equivalent to the following: “I declare that this product was manufactured neither ‘from’ nor ‘by’ GMOs as those terms are used in Articles 2 and 9 of Council Regulation (EC) No 834/2007.

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se

I undertake to inform our customer and its control body/authority immediately if this declaration is withdrawn or modified, or if any information comes to light which would undermine its accuracy.”

Sampling and Analysis • •

Sampling and analysis must be done in accordance with EU Commission Recommendation 2004/787/EC. The documentation must show that the sample and results of the analysis are regarding the consignment.

Screening for GMOs with PCR analysis is the standard method of analysis. Parameters that must be checked are: - that the screening is done for all the relevant GMOs. - that the method is sensitive enough. KRAV requires a reporting limit of 0.1% and that samples are taken of raw materials with intact DNA.

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se

The KRAV Association Box 1037, SE-751 40 Uppsala, Street address: Kungsängsgatan 12, Uppsala Tel.: +46 (0)18-15 89 00, Pg: 165 78 28 -8 Bg: 5711-5487 Organisation number: 716422-5364, www.krav.se