Our
NON-GMO PROMISE
EMERGEN-C COMMITMENT
Our dedication to high-quality and safety begins in the research laboratory and continues through manufacturing and delivery of our products to you. With this focus, we take pride in being built on a foundation of science & quality, which delivers you products in the forms and with the features you prefer.
At Emergen-C, we embrace curiosity. Consumers want to know what is (or isn’t) in their supplements before they take the next step for their health and well-being.
What Does "GMO” Mean?
When we refer to “GMO” (genetically modified organism), we mean an organism that was modified through genetic engineering, or other scientific means, that alters its natural state to one that could not have occurred naturally.
Emergen-C Non-GMO Standard
Although there is no federal guidance for making an affirmative non-GMO claim on foods or supplements,1 we’ve based our non-GMO standard on a careful evaluation of FDA guidance documents, existing and proposed standards from within and outside the U.S., standards set by independent organizations, along with the USDA National Bioengineered Food Disclosure Standard.
Our non-GMO verification is based upon a thorough evaluation of supplier documentation confirming the non-GMO status of the ingredients.
We allow for the use of starting raw materials, fermented ingredients or processing aids that are genetically engineered, as long as the genetic material is removed from the finished ingredient and is not present in the final product.
Common Definitions Related to GMOs
Genetic Engineering
The USDA uses the term “bioengineered” (BE) interchangeably with “modern biotechnology” and adopts the CODEX definition for Modern Biotechnology which means the application of:2
a) In vitro nucleic acid techniques, including recombinant deoxyribonucleic acid (DNA) and direct injection of nucleic acid into cells or organelles
b) Fusion of cells beyond the taxonomic family, that overcome natural physiological reproductive or recombinant barriers and that are not techniques used in traditional breeding and selection
Genetic modification happens when scientists insert DNA from one species into another in order to impart a trait that does not naturally occur in the modified species. Sweet corn, for example, is often engineered to resist insects by modifying its DNA with a bacteria strain known as Bacillus thuringiensis. This causes every cell in the corn plant to produce an insecticide that can’t be washed off.
Identity Preservation (IP)
Identity preservation is a practice that traces the identity of ingredients back to their original source. The United States Department of Agriculture (USDA) has a voluntary service through its Identity Preservation Program. The program ensures the integrity of ingredients supply by verifying the identification, segregation of seeds, and traceability of a product’s unique, value-added characteristic where verification is provided at every stage, including seed, production, processing and distribution.3
Non-GMO by Identity Preservation (IP) requires practices and processes for controlling contamination from at-risk GMO inputs and ingredients. While non-GMO by IP is acceptable for our standards, it is not required.
PCR(-) (PCR negative)
The Polymerase Chain Reaction (PRC) test detects genetic material (DNA) in a sample. A negative test result, or PCR(-) for short, means that no genetically modified DNA was detected in the finished product. While non-GMO by PCR(-) is acceptable for our standards, it is not required.
Processing Aids
According to the FDA definition, processing aids include:4
- Substances that are added to a food product during its processing but are removed in some manner before the food is packaged in its finished form.
- Substances that are added to a food product during processing and are converted into components that naturally occur in the food but don’t significantly change the natural makeup of the food.
- Substances that are added to a food product for their technical or functional effect in the processing but are present in the finished food at insignificant levels and do not have any technical or functional effect on that food.
Our standard allows, on a case-by-case basis, the use of raw materials, fermented ingredients and processing aids that are genetically engineered when unavoidable. For example, some B Vitamins (riboflavin and vitamin B12) are produced using a fermentation process that employs a genetically-engineered processing aid. Under our non-GMO standard, an ingredient manufactured using a genetically-engineered processing aid, such as riboflavin and B12, would not be considered genetically-modified as long as the nutrient medium itself is not genetically engineered and the genetically-engineered processing aid is filtered out.5
References
1. National Bioengineered Food Disclosure Standard Federal Register :: National Bioengineered Food Disclosure Standard
2. Codex Alimentarius Commission. 2003. Amendments in 2008, 2011. “Principles for the Risk Analysis of Foods Derived From Modern Biotechnology CAC/GL 44-2003” Biotechnology | CODEXALIMENTARIUS FAO-WHO
3. Identity Preservation Program | Agricultural Marketing Service (usda.gov).
4. Food exemptions from labeling, 21CFR101.100(a)(3)(ii) https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=101.100
5. Filtered out such that residual genetically-engineered DNA is present at <0.9% in the ingredient. This threshold of <0.9% is consistent with existing international standards when such GE DNA is present due to adventitious or technically-unavoidable contamination.
