NON-GMO PROJECT

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NON-GMOPROJECTSTANDARD12. 30. 2020 2020 The Non-GMO ProjectPublic comment periods on theNon-GMO Project Standard are held for 60 daysbeginning no later than April of revision years;for more information please visit our website.Comments received in the interim will be reviewedduring the next scheduled public comment period.Comments may be submitted through ourStandard Comment Form.

The Non-GMO Project Standard (Version 16)The Non-GMO ProjectCopyright 2020 by the Non-GMO ProjectAll rights reserved.Version 16 of the Non-GMO Project Standard was published and took effect onDecember 30, 2020. The Non-GMO Project Standard is a normative document under theProduct Verification Program. English is the original and official language of this document. Incase of any inconsistencies between this document and any translation, default to the officiallanguage version.The Non-GMO ProjectP.O. Box 5606Bellingham, WA 98227Phone: 1.360.255.7704E-mail: standard@nongmoproject.orgWebsite: www.nongmoproject.orgStandard Comment ation/the-standard/standard-comment-form/Social m/nongmoprojectwww.instagram.com/nongmoproject

Table of Contents1Introduction. 11.11.2Purpose . 1Methodology and Approach . 12Scope of Product Verification Program . 22.12.23Product Categories . 3Input and Ingredient Evaluation . 3Input and Ingredient Classification . 53.13.23.33.4Weight Percentage . 5Risk Status . 7Testability . 7Product Compliance by Input and Ingredient Classification . 84Chain of Custody . 114.14.24.34.44.5Activities . 11Global Chain of Custody Requirements . 11Segregation . 11Cleanout . 12Traceability . 125Onsite Inspections . 126Sampling and Testing . 136.16.26.36.46.5Action Thresholds. 13Global Sampling Requirements . 13Global Testing Requirements . 14Molecular Testing Methods . 15Immunological Testing Methods. 167Affidavits . 177.17.27.37.47.57.688.18.28.38.48.58.6Global Affidavit Requirements . 17Non-Testable High-Risk Inputs and Ingredients . 17Testable High-Risk Minor and Micro Inputs and Ingredients. 18Affidavit Compliance Based on Country of Origin. 19Monitored-Risk and Low-Risk Major, Minor, and Micro Inputs and Ingredients . 19Non-Risk Major, Minor, and Micro Inputs and Ingredients . 20Livestock and Poultry . 20Compliance of Livestock- and Poultry-derived Products, Ingredients, and Inputs . 20Life Cycle . 22Compliance of Feed Rations . 22Feed Sampling . 24Testing Methodology . 28Feed Compliance Through Compliant Seed . 28

8.78.8Feed Mills . 29Onsite Farm and Feed Mill Inspections . 299Special Requirements for Specific Products, Ingredients, and Inputs . 309.19.29.39.49.59.6Apiculture . 30Beer, Wine, and Liquor. 30Microorganisms. 31Probiotics . 31Seafood . 31Vitamins and Supplements . 3210Product Specifications and Labeling . 3211Quality Assurance . 3310.1 Specifications for Obtaining Inputs and Ingredients . 3210.2 Labeling . 3311.1 Total Quality Management Systems . 3311.2 Non-conformities and Corrective and Preventive Actions . 3411.3 Renewal . 35Appendix A –Terms and Definitions . 36Appendix B – High-Risk List . 40B.1Testable and Non-Testable High-Risk Inputs and Ingredients . 40Appendix C –Monitored-Risk List . 42C.1Testable and Non-Testable Monitored-Risk Inputs and Ingredients . 42Summary of Changes from Version 15 of the Standard (Hyperlinked) . SoC-1TablesTable 3-1Table 3-2Table 3-3Table 3-3Table 4-1Table 6-1Table 8-1Table 8-2Table 8-3The Five Risk Statuses . 7Compliance of Verified-Status, Monitored-Risk, Low-Risk, and Non-Risk Inputs,Ingredients, and Products . 8Compliance of Testable and Non-Testable High-Risk Major, Minor, and Micro Inputsand Ingredients . 9Compliance of Testable and Non-Testable High-Risk Major, Minor, and Micro Inputsand Ingredients, Continued . 10Activities Along the Chain of Custody . 11Action Thresholds . 13Compliance of Livestock- and Poultry-derived Products, Ingredients, and Inputs . 21Compliance of Inputs to Rations for Livestock- and Poultry-derived Products andMajors . 23Quarterly Sampling Density and Selection . 25

1IntroductionThe Non-GMO Project is a nonprofit organization whose mission is to offer rigorous productverification and trustworthy education that empowers people to care for themselves, theplanet, and future generations.In support of our mission, the Non-GMO Project offers a Product Verification Program (PVP)whereby Participants may enroll wholesale goods and retail consumer goods as Products forevaluation against, and determination of compliance with, the Non-GMO Project Standard. ThePVP also includes a written agreement between the Participant and the Non-GMO Project, andwhere applicable, a written agreement between the Participant and one or more TechnicalAdministrators (TAs). If all elements of the PVP are satisfied, including meeting the compliancerequirements set forth by the Non-GMO Project Standard, goods may attain Non-GMO Projectverification.To monitor compliance with the PVP, the Non-GMO Project maintains surveillance and auditingprograms. The surveillance program routinely tests Verified Products and Inputs andIngredients to same, for compliance with the Action Thresholds outlined in the Non-GMOProject Standard. The auditing program is in place to ensure that the appropriate supportingdocumentation associated with Verified Products is on file and fulfills the requirements of thePVP.Hereafter, the Non-GMO Project will be referred to as “the Project” and the Non-GMO ProjectStandard as “the Standard.”English is the original and official language of the Standard. Terms defined in Appendix A andused in the Standard are capitalized throughout. Requirements listed under headers titled“Global Requirements” apply to the entirety of the section in which they appear (e.g.,v16 Section 4.2, Global Chain-of-Custody Requirements, applies to all of v16 Section 4).1.1Purpose1.2Methodology and ApproachThe purpose of the Standard is to offer meaning and value to the marketing claim“Non-GMO Project Verified” by creating, maintaining, and keeping publicly available, a set ofrigorous requirements against which all Non-GMO Project Verified Products are measured.The Project’s PVP is based on a practice-oriented and process-oriented Standard that uses bothtesting and Affidavits as key strategic tools to confirm that practices and processes meetexpectations.Continuous improvement on the part of Participants is required with the common goal ofeliminating any Inputs and Ingredients derived from Genetically Modified Organisms (GMOs)from their supply chains.A Product is a unique branded formula and process, where process could be either themanufacturing or facility process. Product refers to wholesale goods and retail consumer goodsthat are enrolled in the PVP.Version 16Page 1 of 42December 30, 2020

The breadth and depth of Product evaluation is informed by the nature of the Inputs andIngredients that are represented in, or present in, the Product formulation. Inputs andIngredients are classified according to three attributes: 1) weight percentage as represented in,or present in, the Product, 2) likelihood that they are derived from a GMO, and 3) whether atestable precursor exists at any point in the supply chain. These three attributes are termedWeight Percentage, Risk Status, and Testability, respectively. Compliance of all Inputs andIngredients associated with a Product, and whose evaluation is mandatory, is required forverification.Activities occurring along the chain of custody (CoC) for Products and their Ingredients andInputs are reviewed for compliance with the segregation, cleanout, traceability, and qualityassurance requirements outlined in the Standard. Products must comply, on an ongoing basis,with the labeling requirements outlined in the Standard and cannot carry competing claims or100% GMO absence claims. Before using the Non-GMO Project verification mark in connectionwith any Product, Participants will be required to sign a written agreement with the Project.Although requiring the compliance of all Inputs and Ingredients to Products, the PVP is highlyfocused on Products, Ingredients, and Inputs that are or are likely to be derived from GMOs.Testable High-Risk Products, Ingredients, and Inputs must comply with the appropriate ActionThreshold and Non-Testable High-Risk Products, Ingredients, and Inputs must comply withAffidavit requirements.Addressing the contamination of seed is a stated priority of the Project. Although traceabilityback to tested seed is not required for Product verification in general, the Project is activelydeveloping sources of compliant seed as the basis for a sustainable Non-GMO supply chain.In summary, all Project Verified Products must have systems in place for: Labeling: Accurate and clear Product labeling Quality assurance: Maintaining operational consistency and addressing Non-conformitiespromptly Procurement: Obtaining Inputs and Ingredients in accordance with uniform and meaningfulspecifications Testing: Meaningful, ongoing testing of Major High-Risk Inputs and Ingredients Segregation and Cleanout: Protecting compliant Inputs and Ingredients from comminglingwith non-compliant materials Traceability: Supply chain traceability, especially following Input and Ingredient testing orthe establishment of a compliant Affidavit2Scope of Product Verification ProgramThe scope of the Standard and the PVP encompasses the following Product categories,including their Inputs, Ingredients, and associated activities.Version 16Page 2 of 42December 30, 2020

2.1Product Categories2.1.1 The following types of wholesale or retail goods are eligible for verification:2.1.1.a Seed and vegetative propagation materials2.1.1.b Wholesale or retail goods for human or pet use that are either ingestedor topically applied2.1.1.b.i2.1.1.cOver-the-counter (OTC) drugs and homeopathic remediesWholesale or retail goods for human or pet use that are not ingested ortopically applied2.1.1.d Livestock, poultry, bee, and seafood feed and supplements2.1.2 The following types of goods are ineligible for verification:2.1.2.a Controlled substances under U.S. or Canadian law and all otherprohibited Inputs and Ingredients listed under Section 2.2.32.1.2.b Goods that are not sold in the U.S. or Canada2.1.2.cCertain medicines and other medical goods2.1.2.d Live animals2.1.2.e Synthetic pesticides2.1.2.fGoods composed entirely of Non-Risk Inputs and Ingredients and thatare part of a Non-Risk Category2.1.2.f.iNon-Risk Categories include, but are not limited to,100% salt goods, unflavored still beverages, unflavoredcarbonated beverages, and unflavored electrolyte beverages2.1.2.g Goods making a voluntary or mandatory disclosure under The NationalBioengineered Food Disclosure Standard 12.2Input and Ingredient Evaluation2.2.1 Mandatory Input and Ingredient categories (categories to Product formulationsthat must be evaluated and found compliant):2.2.1.a Seeds and vegetative propagation materials ONLY when the same seedsor vegetative propagation materials are the Products seekingverification.2.2.1.b All Inputs and Ingredients represented in, or present in, the Productformulation from the following categories must comply with therequirements of the Standard in order for the finished Product to beVerified.17 CFR § 66 (2018).Version 16Page 3 of 42December 30, 2020

2.2.1.b.iUnprocessed raw agricultural materials such as vegetables,grains, fruit, greens, herbs, other fresh foods, fibers2.2.1.b.ii Manufacturing Inputs and Ingredients, including flavorings,seasonings, colorings, additives, and all other substancespresent in final, manufactured Products2.2.1.b.iii Animal derivatives including dairy, meat, eggs, wool, andhides; derivatives of apiculture including, but not limited to,honey and beeswax; derivatives of seafood2.2.1.b.iv Processed agricultural Inputs and Ingredients2.2.1.b.v Packaging that is directly immersed in or combined withliquid for the purpose of making the Product available forhuman consumption including tea, coffee, spice, and soupbags but not including any part of the packaging other thanthe bag2.2.1.b.vi Rations and supplemental feed for livestock, poultry, bees,seafood, and other animals2.2.1.cOther Inputs and Ingredients used in personal care and cosmeticProducts, and textiles2.2.1.d Dietary supplements, vitamins, and herbal preparations2.2.1.e Microorganisms, Enzymes, and Growth Media2.2.1.fProcessing Aids present in the finished Product at 0.5% or more2.2.1.g Processing Aids listed on the Ingredient panel of a retail consumergood, or Input/Ingredient disclosure documentation of a wholesalegood2.2.2 Input and Ingredient categories that are out of the scope of the Standard(categories that do not affect the evaluation of the overall Product formulation,including Weight Percentage, Risk Status, and Testability, do not need to beevaluated and do not need to demonstrate compliance with the Standard.)2.2.2.a Processing Aids used in the manufacture or processing of a finishedProduct, Ingredient, or Input are out of the scope of review if present inthe finished Product at less than 0.5% and not declared on the retailIngredient panel or t

The Non-GMO Project is a non profit organization whose mission is to offer rigorous product verification and trustworthy education that empowers people to care for themselves, the planet, and future generations. In support of our

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