GMOs – Non-GM Consumer Guide

By Manon Godot, 16th of January 2011

Obligation of Labeling GMOs in the EU

In the EU, the labeling obligation for GM products exists since 1997, and was extended by the Food and feed Regulation of the European Parliament in 2003.

The Regulation (EC) No 1830/2003 of the European Parliament and of the Council of 22 September 2003 concerning the traceability and labeling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC defines the legal rules for labeling of human food and animal feed placed on the EU market.

According to the Regulation, human food and animal feed containing GMOs must be labeled. If a food product has been genetically modified, or contains genetically modified plants or microorganisms, it has to be labeled as such, so the consumer can make a choice.

According to R1830/2003 art. 4, B. 6. :

If the product is pre-packaged, the words ‘this product contains genetically modified organisms’ or ‘This product contains genetically modified [name of organism(s)]’ must appear on its label.

If the product is a non-pre-packaged product, the words ‘this product contains genetically modified organisms’ or ‘This product contains genetically modified [name of organism(s)]’   ’ must ‘appear on, or in connection with, the display of the product.’


There are however exceptions to the obligation of labeling GM food products:

  • If the product contains less than 0.9% of GMOs, and if the producer can prove upon request that all necessary measures were taken to bring the product to market separated from GM goods, the GM product won’t have to be labeled as such.
  • Products derived from animals fed with GM feed don’t have to be labeled. Meaning that all the meat, dairies and eggs derived from animals fed with GM animal feed don’t have to be labeled. No labeling requirement exists for foods that contain GMOs indirectly, so there is no way for the consumer to know if the animals have been fed with GMOs. The only solution to avoid it is to buy organic products when they are derived from animals.
  • Products produced with GM technology do not have to be labeled. Some enzymes are indeed produced with GM microorganisms, and are then used to make cheese, baked goods, juices, wine, grape sugar, and glucose syrup. These products do not have to be labeled as GM products. Some vitamins, flavours and additives are also produced from GM microorganisms, but do not necessarily contain them in their final form. In this case, they will not have to be labeled either.


In short, companies have the legal obligation to label GM products sold on the EU market. There are very few products labeled as GM products on the EU market, because many companies choose to change an ingredient rather than to include a GM ingredient in food products. The reason for this is that any company that would put a GM label on a product risks to compromise its image and to see the product’ sales fall.

Some products are however susceptible to contain GMOs without being labeled. There is no indication on these products label of the fact that they might contain GMOs. To make up for this weakness of the labeling system, some environmental organizations have investigated in order to elaborate a classification of products and marks that are likely to use GMOs without label.


GM products can be classified in 2 types; direct GM products that are labeled and indirect GM products that are not labeled. The purpose of the article is to help you to find out which products contain GMOs, in order to enable you to make a choice when you consume.

Non-GMOs European Shopper Guide


Labeled GM products:


The Shopper Guide on ‘products with or without GMOs’ written by Greenpeace French Section in 2006 and updated in January 2009, gives a list of products which label contains the mention “this product contains GMOs”. According to the guide, about 30 products are sold with a GM label. These products are:

  • Hunt’s (ketchup, sauce Hickory BBQ),
  • Classic Foods (Barbecue sauce, Steak sauce, Pancake syrup, Blue cheese sauce, Ranch sauce, Caesar sauce, 1000 Island sauce),
  • Post (Oreo O’s cereals with marshmallow),
  • Azteca Milling (maize flour, Maseca),
  • Fluff (marshmallow paste),
  • Added Touch Shirrif (muffins preparations, brownies or gingerbread),
  • Newman’s Own (popcorn Natural and Butter),
  • A&W Root Beer (soda in cans),
  • P. Dumortier Frères (Beffroi),
  • Lesieur (Alba, Maurel / Huilor),
  • Huileries de Lapalisse,
  • Huileries de Sérignan (Loumas),
  • Associated Oil Packers (Amphora).[1]

Unlabeled GM products

Greenpeace Shopper Guide also classifies all the other food products in three categories (green, orange and red), according to the level of likelihood that they contain GMOs. The point of this classification is to help the consumer to detect which products are more likely to contain GMOs, when they escape to the labeling legal obligation (see exceptions above). According to this classification, “green” products are the ones for which producers guarantee that they do not use GMOs. The “Orange” ones are the products that come from companies that guarantee being in the process of excluding GMOs from their products. The “red” ones come from fabricants that refused to answer the questionnaire or cannot guarantee that their products are GM free.

Among the companies and brands that sell unlabeled GM products, Nestlé, Unilever, Weight Watcher, Affinity Petcare, Lu, Campbell, Panzani, Blédina, Findus, Léonidas, Kellogg’s, Weetabix,  Ferrero, Haribo, Candia, Celia, Danone, Yoplait, Agrial, ABC group (Charal non-organic beef meat), Aoste and Madrange are a few. See the full Greenpeace French Section list of unlabeled GM products


GM-Free Irish Shopper Guide

Labeled GM products


Some products sold on the Irish market are labeled as containing GMOs. There are however not many, and the mentioning of it is often hidden. So when you consume products that are susceptible to contain GMOs, be attentive to the label. The GM mention might appear on the back of the label in small letters, rather than in the list of ingredients. Ingredients susceptible to be GMOs are:

  • Soya beans
  • Maize
  • Rapeseed oil
  • Cottonseed oil

The Food Safety Authority in Ireland (FSAI) identified GM ingredients in the following type of food (non-comprehensive list):

  • Breadcrumbs for chicken and burgers
  • Corn snacks derived from maize
  • Gluten-free reduced sugar rusks
  • Lecithin granules derived from soya bean and maize meal
  • Soya protein mince
  • Soya protein chunks
  • Soya biscuits and cakes
  • Soya bran
  • Soya flour
  • Infant formula
  • Soya Cream
  • Soya Yogurt
  • Soya drink
  • Soya dessert
  • Taco shells
  • Tortilla chips
  • Vegetable casserole
  • Bread
  • Biscuits
  • Cereals
  • Chocolate products
  • Bakery products
  • Beer
  • Margarine

Meaning that when you buy these kind of food, be especially attentive to the label.

Tesco Ireland is currently selling “Lifeforce pure Soya Oil” made from GM Soya. The mention of GMOs is hidden in small letter on the back of the label.

Musgrave Cash and Carry is also selling GM soya and GM rapeseeds oil. This company owns Supervalu, Centra, Budgens, Londis, and Musgrave wholesale services. These products are manufactured by Lifeforce Foods Ltd, Marley’s Lane, Drogheda, Co. Louth. [2]

Unlabeled GM products


Many Irish hostels, restaurants and caterer (including members of the Irish Hotels Federations and the Restaurants Association of Ireland) serve food cooked with GM oils (rapeseed, soya or maize) without saying it, even if these products are submitted to the obligation to be labeled.

Chef members of the Euro-Toques Ireland do not use GM products. They however use products derived from GM fed animals, as these products are not considered GM, because the link between animal feed and products derived from animals is indirect.

Most of the Irish retailers sell products derived from animals fed with GM soya, GM maize gluten and GM oilseed rape. The only exceptions are certified organic products and fresh meat & dairy products sold by Marks & Spencer. “In April 2007, thousands of tones of illegal GM maize products entered the EU through Ireland and were sold to farmers for animal feed. The Department of Agriculture’s Animal Feedstuffs Section said most imported animal feed products are not tested for GM content.” [3]

So basically if meat, dairy or egg products are not organic, it is reasonable to consider that they are derived from animals fed on GMOS. If you want to make sure that you are not indirectly consuming GMOs, the best option is to consume certified organic animal products. You might want to be especially attentive to the origin of products such as lamb, beef, pork, milk, butter, cream, ice-cream, yogurt and cheese.


In Summary:


  • When you are shopping, be attentive to the labels of the products you buy, especially while buying products containing soya, maize, rapeseed and cottonseed oils. Search for the mention: “this product contains GMOs”, that has legally to appear on the product.
  • When you buy products derived from animals fed on GMOs, there is no legal obligation of labeling as GMOs. The only way to avoid consuming GMOs that way is to buy certified organic animal derived food.



[1], p.1

[2] Irish Seed Savers Association –

[3] Irish Seed Savers Association –


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One Response to “GMOs – Non-GM Consumer Guide”

  • Guillaume:

    Hi everybody,
    Thanks for this very complete article !

    I wish to add what I learned today in course : For the European Union one of the three genetic modifications made by mankind is NOT considered as a GMO process whereas it is producing GMO. It therefore never labelled as GMO.
    In fact, three process are followed to produce GMO :
    – DNA recombination
    – DNA injection directly in a cell
    – cell fusion in vitro
    The last one is considered as selection by natural crossing but it’s done in laboratories !
    When this very used process will be considered as GMOs making and labelled as such ?
    Very soon, let’s hope.


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