The ‘free-from’ – ‘without’ this or that ingredient – is one of the most popular claims on labels and advertisements of pet food. In line with current food marketing trends, in the broader context of ‘natural’ food for human beings and their two- or four-legged friends. But what does it mean?
A considerable competitive advantage is undoubtedly associated with this type of promotional messages. Thanks also to the fact that today companion animals, like their biped friends, are often obese or overweight and therefore there is widespread search for foods at least apparently more suitable.
The absence of certain ingredients and substances in foods as in pet foods, is generally associated by the general public with benefits – real or presumed – for nutrition and health.
These indications, furthermore, must be transparent – that is truthful and demonstrable, to authorities upon request – as well as clear and not misleading. Also in force are bans on:
- attributing to the product effects and properties that it does not possess (e.g. health claims),
- boasting characteristics common to the category, thus not distinctive of the individual product. (1)
The indication ‘without-GMOs’, in particular, is one of the free-from most popular. European consumers indeed hold significant reservations about the safety of genetically modified foods and try to avoid them when possible. (2)
The legitimacy of the claim ‘without GMOs’ must however be carefully verified. First of all, it is important to underline that feed containing or derived from GMOs must carry a specific indication on the label. (3). Pet food labeled as ‘without GMOs’ must therefore have a corresponding ‘potentially GMO’ matrix from which it distinguishes itself.
As for the plant ingredients, it is possible to admit the claim ‘without GMOs' where the pet food contains non-GMO soy, corn, rapeseed (considering the actual spread of GMOs in the related crops), but not in the case of wheat, rice, sunflower (given that in Europe the use of derivatives from wheat, rice, and sunflower genetically modified).
Animal-derived ingredients designated as non-GMO, in turn, must come from farms where the use of GM feeds has been excluded. Whether it is meat and related by-products or farmed fish or shrimp.
Tolerance on traces (<0.9%) of GMOs in ingredients not designated as such, it should be noted, can only be applied when the responsible operator is able to demonstrate having adopted every appropriate measure to avoid contamination.
Accidental presence and/or technically unavoidable traces of GMOs can therefore be tolerated – within the indicated quantity limit – provided that the operator demonstrates, for example, having purchased IP (Identity Preserved), such as Italian soy.
Dario Dongo and Paola Cane
Notes
(1) The criteria of fairness in information practices are, in fact, similar to those defined for information on food products (EU regulation 1169/11, article 7)
(2) It will be much more difficult to distinguish the so-called 'new GMOs' as the EU Court of Justice might exclude them from authorization, traceability, and specific notification rules.
(3) Cf. EC reg. 1829/03, 1830/03
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT – Food Times) and Égalité.
