Bioengineering Statement
Hi, one of our customer requested a Bioengineering Statement from our plant. I am just now looking into this and I have one question - if our product doesn't contain the items identified AMS developed the List of Bioengineered Foods (alfalfa, apple (Arctic varieties), canola, corn, cotton, eggplant (BARI Bt Begun varieties), papaya (ringspot virus-resistant varieties), pineapple (pink flesh), potato, salmon (AquAdvantage®), soybean, squash (summer), and sugarbeet.) - Do I just mark it as "Does not contain or consist of ingredients from potentially BE sources". OR do I have to get non-gmo and/or organic statement for each ingredient regardless of the list.
There is no need to provide a statement on the packaging if your ingredients do not contain any of these bio engineered ingredients.
Only disclosure of the above mentioned bioengineered foods is required.
I would type out a blanket statement that outlines the complete list of bioengineered foods and which ones are processed/handled at your site & send out to the customer.
If I were you I would do your due diligence for each ingredient. Meaning, determine if any of your ingredients contain any of those items in the list that are under the rule. Based on that information you can send out your documentation / letter to your customer. The link below breaks down the implication the rule pretty well.
You have the option of simply making the statement this does not apply, no applicable etc. However I warn you if there is ever an issue and you have made a statement and signed off on it - you will be held liable in court.
As Ryan said - do your due diligence.
Just a reminder, don't forget about ingredients that are potentially derived from bioengineered foods. For example, my company uses alcohol derived from corn, so every time I fill out one of these forms, I have to check the box for corn and write a statement about how alcohol is PCR negative for GMOs. Starch, maltodextrin, and dextrose are also typically corn derived, unless otherwise stated, ex. tapioca starch vs starch.
Also remember, BE labeling applies to ingredients that are not on the BE list as well. If you have a product that is bioengineered and is not on the "BE list" you still have to label it BE.
The list is not all encompassing, just the most likely.
getting others' insight on this:
our suppliers cannot provide any test document of BE ND/Detectability so our management decided to state it as due diligence.
if my company (confections), has dextrose candies, and baked goods with soy lecithin, etc. - our appropriate BE statement would be "Derived from BE food ingredients" ...? Since it's not exactly corn or soy, but a processed form of it?