Introducing due diligence obligations for GMO products

  • Dr. Jenny Teufel
    Senior Researcher / Head of Subdivision Sustainable Food Systems & Lifestyles Sustainable Products & Material Flows

Taking responsibility for risks in supply chains

Products that are manufactured using new genomic techniques such as genome editing present challenges regarding traceability in some cases. However, this challenge can be addressed effectively with appropriately adapted EU rules. Which approaches are expedient, and how might they be implemented? These questions are investigated in a new study by the Oeko-Institut and the Environment Agency Austria.

One of the challenges relating to new genomic techniques (NGTs) is that some NGT products cannot be clearly identified as such using analytical methods. With reference to other products whose marketing is regulated in the EU and whose regulated properties likewise cannot be proven analytically, such as conflict minerals, the project team reviewed various regulatory systems which establish a due diligence obligation for companies along their supply chains and thus reverse the burden of proof. This method can be transferred to agro-food products. A corresponding due diligence regulation could thus apply to all products developed using new genomic techniques.

Product traceability to fulfil due diligence obligations

Due diligence regulations can legally oblige companies to take responsibility for certain risks in their supply chains. With a reporting requirement, for example, companies must prove that they are fulfilling their human rights and environmental due diligence obligations. Proof of the regional origin of imported goods may also be required. These traceability systems can be applied to genetically modified organisms (GMOs) as well. Companies importing agricultural commodities must then endeavour to identify risks of unauthorised GMOs (including NGTs) in their supply chain and, where appropriate, take measures to minimise them. The aim is to ensure that a product’s ingredients can be traced back through the whole supply chain up to the agricultural production or even to the origin of the seed material used to grow the crops concerned. Traceability is thus a means to minimise the risk of GMO contamination in supply chains and serves as a prerequisite for due diligence.

The additional effort that more reporting entails may pose a challenge for companies.


Our exercise, which is based on a fictional company selling non-GMO products, reveals that companies selling certified non-GM products are already meeting many of the elements of a potential due diligence regulation. The additional effort should therefore be minimal.
Dr Jenny Teufel
Senior Researcher at the research division Sustainable Products & Material Flows

Furthermore, under the new EU Regulation on deforestation-free products, for example, food industry companies are already required to provide corresponding information about their supply chains for certain raw materials.

Supplement existing databases for easier identification of risks

In order to assess risks in the supply chain, a range of information on GMOs is required, such as a regularly updated overview of the main countries exporting plant products to the EU for which GM varieties are available worldwide. Preferably, these data should be made available in an international database that also contains automatically retrievable DNA sequence information on GMOs. “This information would enable importers of agricultural products to conduct the required non-analytical assessment of risks,” Dr Teufel explains.

Paper: "Strategies for traceability to prevent unauthorised GMOs (including NGTs) in the EU: State of the art and possible alternative approaches" by the Oeko-Institut, in cooperation with the Environment Agency Austria and the German Federal Environment Agency (UBA)