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GMO safety
Synthetic biology
Adaptive Risk Assessment

There exist "GM-free labels" pointing out that, in addition to what is laid down by the EU legislation on GMOs, specific measures have been taken on a voluntary basis to strictly exclude the presence or the use of GMOs in some food or feed products. Such voluntary labels are possible provided that they are not misleading for the consumer.

In view of the development of these voluntary GM-free labels in a number of Member States in the past years, the Commission has asked an external contractor, ICF/GHK, to perform a study in order to take stock of existing labels and their specifications, in the EU-28 Member States and in third countries, and to identify whether, and to what extent, the existence of these different GM-free labelling schemes impact the access of European consumers to food information and the functioning of the internal market. The study also aimed to identify and analyse the core elements to be considered in the context of a potential EU harmonised approach to GM-free labelling.

The evidence for preparation of the report was gathered via a literature review, desk research and consultations with Member States, third countries and stakeholders, including 70 interviews and 9 survey responses. 6 country case studies were also performed (Austria, France, Germany, Italy, Sweden, Netherlands, and United Kingdom).


Key findings

  1. Many different types of schemes exist, including well-established national and private operator-led schemes that aim to facilitate GM-free labelling, as well as national legislations that restrict or ban such labelling.
  2. Technical specifications of GM-free labels vary, especially on the threshold levels for adventitious or technically unavoidable GM presence, minimum feeding times for animals fed on non-GM feed, and exceptions allowed for use of GM inputs when non GM inputs are unavailable.

  3. Variations across GM-free labelling schemes suggest potential underlying single market and consumer protection/information issues. A majority of stakeholders and Member States show an interest in harmonisation. However the assessment of the current evidence, including the fact that GM-free labels markets are still predominantly national with limited intra-EU exchanges, does not indicate a clear need for harmonisation at the present time.

  4. The existing GM-free schemes contain most or all of the following 6 elements, which should be considered in priority in the context of a potential EU harmonisation of the field: (1) Labelling rules (wording, label format, logo); (2) Indication of the scope of products covered; (3) Threshold levels for adventitious or technically unavoidable presence; (4) Specifications of inputs to be excluded and exceptions; (5) Minimum non-GM feeding times for animals fed on non-GM feed; (6) Certification, inspection and monitoring procedures.


The role of LIS Consult
The Netherlands case study was performed by LIS Consult.


State of play in the EU on GM-free food labelling schemes and assessment of the need for possible harmonisation:

- Final report (5 MB)

- Case studies (2 MB)



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