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No alternative? The politics and history of non-GMO certification
Robin Jane Roff
Accepted: 28 May 2008 / Published online: 16 September 2008
� Springer Science+Business Media B.V. 2008
Abstract Third-party certification is an increasingly
prevalent tactic which agrifood activists use to ‘‘help’’
consumers shop ethically, and also to reorganize com-
modity markets. While consumers embrace the chance to
‘‘vote with their dollar,’’ academics question the potential
for labels to foster widespread political, economic, and
agroecological change. Yet, despite widespread critique, a
mounting body of work appears resigned to accept that
certification may be the only option available to activist
groups in the context of neoliberal socio-economic orders.
At the extreme, Guthman (Antipode 39(3): 457, 2007)
posits that ‘‘at this political juncture… ‘there is no alter-
native.’’ This paper offers a different assessment of third-
party certification, and points to interventions that are
potentially more influential that are currently available to
activist groups. Exploring the evolution of the Non-GMO
Project—a novel certification for foods that are reasonably
free of genetically engineered (GE) material—I make two
arguments. First, I echo the literature’s critical perspective
by illustrating how certification projects become vulnerable
to industry capture. Reviewing its history and current
context, I suggest that the Non-GMO Project would be
better suited to helping companies avoid mounting public
criticism than to substantially reorient agrifood production.
Second, I explore the ‘‘politics of the possible’’ in the
current political economy and argue that while neoliber-
alization and organizers’ places within the food system
initially oriented the group towards the private sector, the
choice to pursue certification arose directly from two
industry partnerships. Consequently, current trends might
favor market mechanisms, but certification is only one
possible intervention that has emerged as a result of par-
ticular, and perhaps avoidable, circumstances. The article
offers tentative delineation of alternatives ways that
activists might intervene in agrifood and political economic
systems given present constraints.
Keywords Agricultural biotechnology � Labeling �Neoliberalism � Non GMO � Politics of consumption �Third party certification � Alternative agrifood system
Abbreviations
FDA U.S. Food and Drug Administration
GE Genetically engineered
GFCA Global Food Chain Advisors
GID Genetic ID
GMO Genetically-modified organism
NGC Natural Grocery Company
NGMOP Non-GMO Project
UNFI United Natural Food Inc.
Introduction
The plethora of shopping guides and books which intend to
help consumers identify and avoid genetically engineered
foods is testament to the prominence of market-based
tactics in American anti-biotechnology politics (see Cum-
mings and Lilliston 2000; Robbins 2001; Smith 2003;
Farlow 2004; Smith 2006; Kimbrell 2007; Stewart 2007;
True Food Network 2007). Although some groups continue
to agitate for mandatory positive labeling, arguing that
consumers have a right to know the origins and quality of
the food they consume, energy is shifting toward forming
R. J. Roff (&)
Department of Geography, Simon Fraser University,
8888 University Drive, Burnaby, BC, Canada V5A 1S6
e-mail: [email protected]
123
Agric Hum Values (2009) 26:351–363
DOI 10.1007/s10460-008-9166-5
coalitions of activists, retailers and manufacturers who then
advocate for third-party certification for non-GMO prod-
ucts.1 Led by Berkeley, California’s The Non-GMO
Project (NGMOP), the campaign is intended to increase
access to products without GE ingredients, to create and
expand the market for such products, and to minimize the
risk of genetic contamination in the organic and natural
food supplies (an increasing problem in the U.S.). As with
all labeling schemes, NGMOP’s transformative potential
rests on its ability to enroll industry members by promising
competitive advantage in the battle over consumers’
stomachs.
NGMOP is just one of an increasing number of third-
party certification efforts created to help consumers shop
ethically and, more broadly, to reorganize commodity
markets.2 Proponents argue that by making visible the
conditions of production, such certifications and labels
counter commodity fetishism and provide consumers a way
to agitate for environmental and social sustainability (Allen
and Kovach 2000; Hudson and Hudson 2003). Some
schemes, most notably ‘‘fair trade’’ endeavors, are meant to
redistribute the benefits of production to actors marginal-
ized by common economic practices (Renard 1999;
Goodman 2004; Shreck 2005). Others, such as ‘‘organic’’
and ‘‘locally-produced’’ labels, purport to embed com-
modities in specific geographies and preserve ecological
and socio-economic qualities (Murdoch et al. 2000; Mor-
gan et al. 2006). In either case, so the story goes,
certification programs should foment alternative food net-
works that internalize the externalities of their more
conventional counterparts (Marsden et al. 2000; Hines
2003).
Much is written about the proliferation of such voluntary
and incentive-based forms of agrifood activism (cf. Allen
et al. 2003; Mutersbaugh and Klooster 2005). This
emerging literature echoes broader discussions in political
economy (McCarthy and Prudham 2004) and takes a pre-
dominantly critical perspective on what appears to be a turn
away from the push by activist groups for direct regulatory
intervention. In particular, scholars caution that third-party
certifications reproduce neoliberal subjectivities and mar-
ket relations antithetical to the environmental and social
qualities they endeavor to protect (Guthman 2007; Brown
and Getz 2008). Alternatively such programs been shown
to propel expensive niche markets that perpetuate socio-
economic cleavages (Allen and Kovach 2000; Guthman
2003b) and create entry barriers that disadvantage small
and medium-sized producers (Mutersbaugh and Klooster
2005; Getz and Shreck 2006; Roff 2007). Most problem-
atically, when successful, third-party certifiers experience
downward pressure on standards as they attempt to attract
manufacturers and compete with similar labels (Gereffi
et al. 2001; Mutersbaugh 2005). The progressive weaken-
ing of evaluation criteria is particularly evident when
certifications emerge from industry (Raynolds et al. 2007)
or from what Gereffi et al. (2001); see also Bartley 2003)
call the NGO-industrial complex. Strict production stan-
dards are entry barriers for large companies with extensive
production lines, thus there is inevitable ‘‘pressure to
weaken’’ standards and to replace agro-ecological ideals
with ‘‘considerations of economic efficiency’’ as larger
firms enter the market (and capture regulatory control)
(Allen and Kovach 2000, p. 224).
Running parallel to theses critiques are efforts to
understand why certifications are emerging at the present
time. The majority of works focus on the macro-political
context of national and international neoliberalization—in
particular the elimination, weakening and obstruction of
environmental and food safety regulations and the accep-
tance of free trade ideologies by state decision makers and
the general public.3 For example, Cashore (2002, p. 506)
links labels to the ‘‘economic and political trends in the last
1 In this paper, GE foods and GMO foods refer to products with
constituents derived from seeds with genetic structure that has
somehow manipulated (e.g., genes added, deleted or reversed)
through recombinant DNA technology. Although GE technology is
slowly being applied to livestock, widespread use as meat of such
animals has not occurred to date. The paper, and the Non-GMO
Project, focus on plant products or livestock raised on plant products.
I reserve GMO for specific references to the Non-GMO Project
because although GMO is widely recognized to stand for GE, the two
terms are not synonymous. GE refers specifically to products created
through rDNA processes, while GMO is a more general term used to
denote any organism with a genetic structure that has been modified
through human intervention (e.g., plant breeding). The distinction is
important because the FDA prohibits the use of the term GMO and
recommends instead the use of the terms ‘‘agricultural biotechnol-
ogy’’ or ‘‘genetic engineering.’’ Also, proponents of these
technologies have capitalized on the slippage in GMO to argue for
that the technology does not represent a significant departure from
past practices (Fedoroff and Brown 2004).2 I focused only to third-party certification, a type of certification
provided by private entities outside the manufacturing industry. It is
beyond the scope of this discussion to explore similar trends in first
and second-party certification systems, although such a project is
worthy of future investigation. For details on the difference between
these certification types see Gereffi et al. (2001).
3 Very broadly, neoliberalization refers to the restructuring of
political economies along classical liberal lines. Although the process
works differently across space (owing in part from contestation by
civil society and their interactions with existing political economic
landscape), it is generally characterized by a retraction of state
intervention in economic functions, including environmental and
social regulation of production, a concomitant faith in the self-
regulating market to reach socially optimal forms, a focus on
individual choice and responsibility as the determinant of political
economic processes, and a reliance on civil society to redress market
failures (i.e., environmental and social problems) (Harvey 2005;
McCarthy 2006).
352 R. J. Roff
123
10 years that have given market-oriented policy instru-
ments greater salience’’ and Mutersbaugh (2005, p. 391)
calls certification an ‘‘emerging form of neoliberal gov-
ernmentality.’’ Fleshing out the specific mechanisms
propelling private governance, Allen et al. (2003, p. 65)
argue that the ‘‘neoliberal revolution’’ with its ‘‘political
culture of entrepreneurialism’’ weakened the financial
support for radical social movements and shifted attention
to consumer choice. Similarly, Gulbrandsen (2006,
pp. 480–481) suggests that certifications ‘‘compensate for
governments’ perceived unwillingness or inability to
address’’ social and environmental concerns (see also
Gereffi et al. 2001; Busch and Bain 2004; Raynold et al.
2007; Brown and Getz 2008).
I agree that the roll-back of state regulation under the
auspices of optimizing economic flows severely curtails the
range of interventions available to activists. However, I am
not convinced, as Guthman (2007, p. 457) recently stated,
that ‘‘there is no alternative’’ to certification even within
increasingly neoliberal political economies. Rather, in this
paper, I follow Bartley (2003), as well as Guthman’s earlier
work (Guthman 1998, 2004) and explore the macro- and
micro-political dynamics that converged to create the
NGMOP. Specifically, I illustrate that while neoliberal-
ization and organizers’ place within the food system
initially oriented the group towards the private sector, the
choice to create a certification arose out of two specific
industry partnerships. Consequently, the ‘‘politics of the
possible’’ (Brown and Getz 2008) might favor market
mechanisms, but certification is only one possible inter-
vention among many.
In making this argument I simultaneously examine the
ways the industry captured control of the NGMOP and
turned to towards profit generation. Organizers worked hard
keep the standard robust and independent, but were enticed
and induced to accept industry involvement. Consequently,
over the course of a few short months major manufacturers
took decision-making power. Since that time the label’s
ambitious criteria have been weakened and the NGMOP’s
purpose shifted from the elimination of GE foods to the
creation of a premium parallel market for non-GMO foods.
As such, this paper speaks both to conversations about the
origins of certification and what increasingly appear to be
unavoidable problems with choosing this path.
After outlining the current state of non-GMO certifica-
tion in the United States, I provide three snapshots of the
context in which the NGMOP emerged and the group’s
specific history. Section 2 sets the stage by outlining the
national and international regulatory environment that
proscribed direct policy interventions. Section 3 then turns
to the group’s initial manifestation and explores the way
organizers’ experience with food retailing focused their
tactics towards this sector. I illustrate that while the group
always endeavored to create demand for non-GMO prod-
ucts, organizers originally attempted to mobilize retailers to
boycott GE foods—an intervention they perceived as more
powerful and less problematic than certification. The fourth
section traces the NGMOP through two critical partner-
ships—first with Genetic ID (GID) and second with United
Natural Foods Inc. (UNFI)—that allowed the natural food
industry to take control and shift the group’s focus to a Non-
GMO certification. The penultimate section assesses this
transition and explores the potential of the current NGMOP
standard to meet the group’s original or present goals.
Unfortunately, it appears that despite the well-intentioned
efforts of organizers, criteria are weakening. Consequently,
the NGMOP is unlikely to significantly affect the future of
agricultural biotechnology. The paper concludes with a
tentative discussion of a range of more successful market
mechanisms currently used to oppose agricultural biotech-
nology. Ultimately, this work expands understandings of
how neoliberalism intersects with agrifood activism and
more importantly, the politics of the possible within the
current political economic context.
To make these arguments I drew from three datasets.
The insights derive predominantly from a series of in-depth
semi- and un-structured interviews with organizers of
NGMOP and other informants involved in the program’s
development and implementation. These interviews
occurred between August 2006 and August 2007, over
which time I also volunteered to work directly with the
campaign. While my participation was limited to contact-
ing retailers and I did not engage in making decisions,
organizers kept me abreast of current events. The inter-
views are complemented by participant observation;
electronic communications; and a personal archive of
documents including press releases, website texts, and
newspaper and trade journal articles. Second, this work is
informed by interviews with a broad cross-section of North
American food manufacturers, a majority of which claim to
produce products free of GE ingredients. I selected infor-
mants purposefully to ensure the sample included a
diversity of firms with a range of revenues, distribution
size, and product-type and worked within both the con-
ventional and natural food markets.
The third dataset contains a set of interviews with
consumers living in Sonoma County, California who
endeavor to eat non-GMO as part of a larger program of
anti-biotechnology activism. These informants were cho-
sen based on opportunistic and snowball sampling,
beginning with a list of participants in GE-Free Sonoma, a
local anti-biotechnology group.
These three sets of interviews and other materials are
part of an ongoing project examining the social and polit-
ical-economic influence of anti-biotechnology activism in
the U.S., with a focus on California as a center of food
The politics and history of non-GMO certification 353
123
politics. I chose Sonoma County as a case study for mul-
tiple reasons; chief among which was the state’s attempt to
establish the County as a GE-Free zone. In total the dataset
includes 42 interviews with consumers and activists and 45
manufacturers, covering many more brands.
Non-GMO certification
It bears repeating from the outset that NGMOP was not
always about creating a novel certification; moreover, the
group’s goals were also not always as they were at the time
of the study. Founding organizers originally sought to hold
natural food retailers accountable to consumer expecta-
tions, reduce demand for GE crops, and curb the spread of
the use of genetic engineering in food production. They
saw public statements of any kind, including labels, shelf
tags or notices in stores, as tools to make the public aware
of GE foods and thereby bring more voices to the debate.
Geared as it currently is to certification, the NGMOP no
longer aims directly to curb the use of GE crops, but rather
to ‘‘offer consumers a consistent Non-GMO choice’’
(NGMOP 2008a, p. 5) and ‘‘ensure viable Non-GMO
alternatives long into the future’’ (NGMOP 2008a, p. 1).
The group’s primary goal is to reduce contamination in the
organic and natural food supply by ‘‘leveraging [food
manufacturers’] collective power’’ (NGMOP 2008b,
online). Guthman (2003) cogently cautions that incentive-
based schemes rely on the juxtaposition of certified and
conventional products and thus have a paradoxical interest
in preserving the production practices they ostensibly
oppose. This is perhaps no where more visible than in the
NGMOP’s focus on protecting the natural food industry’s
integrity as opposed to reducing harvests of GE crops. I
will return to such problems below. For now, let me briefly
review the certification standard, as it existed at the time of
writing.
The Non-GMO Project Working Standard (February
2008) outlines the purpose, scope and methods of assess-
ment for companies wishing to use the Non-GMO seal. To
begin, participants must submit ‘‘specification sheets’’ that
disclose all components of each input (NGMOP 2008b).
For ‘‘low-risk’’ inputs—ingredients derived from crops
with no commercial GE counterparts (e.g., wheat, green
peppers, or cherries)—assessment ends here.4 For ‘‘high-
risk’’ inputs—crops with commercial GE counterparts (e.g.
corn, soy, canola, cotton, papaya) or products derived from
animals subject to GE products (e.g. milk, meat, honey,
eggs)—participants must document segregation practices
and indicate active monitoring (PCR or Elisa test results)
along the commodity path. Testing can be conducted on
individual ingredients or final products, although producers
are responsible for monitoring points of contamination,
thus it is likely that testing will be delegated to suppliers
further up the chain.
Companies are permitted to use the seal (Fig. 1) if they
can show that the GE contamination of every ingredient
does not exceed the current ‘‘Action Threshold’’ for the
food sector in question. By 2013, the NGMOP aims for a
0.1% threshold for seed and propagation materials, 0.9%
for animal feed and supplements, and 0.5% for human food
and other products. Due to present rates of contamination,
however, ‘‘temporary variances’’ are currently set at 0.24,
1.5 and 0.9%, respectively.
Setting the stage: neoliberal limits
Raynolds et al. (2007, p. 148) suggest that third-party
certification fills the ‘‘regulatory vacuum’’ created by ‘‘the
spread of neo-liberal [sic] policies’’ and particularly
‘‘deregulation in agro-good sectors.’’ In the case of agri-
cultural biotechnology, a Non-GMO label does not fill a
previously occupied space, but a void in which regulation
never existed. The package of regulations governing GE
foods is a product of a time of federal de-regulation and
thus is limited, porous and largely reliant on industry self-
monitoring (Eisner 1993; Perrin 2006). Of particular note,
food safety assessments are based on voluntary disclosure
of test results generated by biotechnology firms and GE
foods are treated as substantially equivalent to conven-
tional counterparts. Nothing highlights the U.S. federal
government’s reticence to regulate the technology more
than the fact that what oversight exists was developed at
the behest of the biotechnology industry, which hoped that
regulation would bolster public confidence (Smith 2003).
The repeated attempts by anti-biotechnology groups to
strengthen regulations by instituting mandatory labelling,
shifting liability for contamination from farmers to bio-
technology firms, and enforcing stricter monitoring of
Fig. 1 The Non-GMO
Project’s original seal (top)
was replaced by a simpler,
more colorful version in 2008
(bottom). Source: NGMOP.
2008. The Non-GMO Project.
http://www.nongmoproject.org.
Accessed 18 May 2008; and
NGMOP 2007. The Non-GMO
Project. http://www.nongmo
project.org. Accessed 20 August
2006. Reprinted with
permission
4 The Board of Directors hoped to expand assessment in future to
include end-product testing.
354 R. J. Roff
123
pharmaceutical (‘‘pharm’’) crops have failed (Guthman
2003; Smith 2003). The two federal labelling bills intro-
duced by Representative Denis Kucinich (in 1999 and then
again in 2006) and Senator Barbara Boxer (in 2000),
gained little traction with the FDA, despite wide sponsor-
ship from Congress and public support.5 Taking a
strikingly contrary position, the FDA continually curtails
efforts to distinguish GE foods from their counterparts. For
example, when Oregon Citizens for Safe Food succeeded
in getting Measure 27 placed on the 2002 ballot, which
would have required the labelling of GE foods produced
and sold in the state, the Agency sent a letter to Governor
Kitzhaber counselling that any such move would violate
current guidelines. FDA Deputy Commissioner Lester M.
Crawford warned that the proposed legislation ‘‘would
impermissibly interfere with manufacturers’ ability to
market their product on a nationwide basis’’ and thus
impede the ‘‘free flow of commerce between the states’’
(Crawford 2002). This action is a testament to the lengths
to which the Agency has gone in order to preserve the
current regulatory environment.
De-regulatory agendas make it equally difficult for anti-
biotechnology activists to intervene in sub-national policy
making. The Federal government has repeatedly used its
authority over inter-state commerce to prevent municipal,
county and state decision makers from implementing
environmental and social regulations. For example, the
National Uniformity for Food Act of 2005 requires ‘‘the
laws of a State or a political subdivision of a State [contain]
substantially the same language as the comparable provi-
sion under this Act [the Federal Food, Drug and Cosmetic
Act] and that any differences in language do not result in
the imposition of materially different requirements’’ [H.R.
4167 Sec. 2 c § (1)]. More immediately felt were the 15
pre-emption bills introduced across the US in 2006. Justi-
fied with calls to ‘‘level the playing field’’ for agricultural
producers and food manufacturers, these bills transferred
jurisdiction over seeds and nursery stock from county and
municipal governments to state legislatures. As I discussed
elsewhere (Roff 2008), this shift disabled the possibility of
establishing GE Free Zones—one of the most successful
tactics used to date to slow the spread of agricultural bio-
technology and increase public awareness of the issue and
thus has profound implications for those advocating against
GE foods.
Anti-biotechnology activists fared no better in interna-
tional politics. While numerous jurisdictions across Europe
and Asia have labelling legislation and testing protocols in
excess of U.S. requirements, groups were unable to
translate these victories into global food safety regulations.
To the contrary, the proliferation of free trade agreements
and their stringent enforcement by the WTO limits states’
abilities to regulate environmental and social protections
(Bartley 2003; Busch and Bain 2004). A recent successful
WTO challenge of the EU’s de facto moratorium on GE
foods and crops exemplifies these limits. Despite wide-
spread citizen support for the trade barriers, European
regulators were prevented from restricting GE products
under the auspices that stricter oversight violate interna-
tional law.
With policy making environments as they are, the
NGMOP’s organizers believed they had few options other
than the private sector. Discussing why the group chose to
work within the market rather then targeting regulators, one
informant stated, ‘‘There are no requirements, no limita-
tions about GMOs. So you can target the government… but
it doesn’t get very far.’’6 Later when asked who should take
responsibility for the adventitious presence of GE material
he noted:
They [biotechnology firms and the federal govern-
ment] should be responsible for that. But they’re not,
and none of us are really going to be able to make
them. …We have a much better shot at influencing
natural food companies to do something about it than
at influencing the government.7
Indeed, anti-biotechnology groups have been successful
at stalling or preventing the commercial release of GE
crops by cajoling conventional manufacturers, such as
McDonalds and Gerber, to reject such products. Yet, it
would be incorrect to portray this market orientation as
merely the product of a rational strategic analysis. Neo-
liberal ideologies of consumer choice and the power of
market demand infused my conversations with NGMOP
members. Such concerns are in line with broader shifts in
contemporary environmentalism and food activisms away
from state institution building (Dryzek 1997; Allen et al.
2003; McCarthy and Prudham 2004). Accordingly, indi-
vidual choice and a consumer’s right to know product
qualities are sacrosanct. Almost all the activists and con-
sumers with whom I spoke emphasized the value of choice
and information. Regardless of whether the solution to GE
foods proposed was collective, such as community gardens,
or overtly individual, such as purchasing organic foods, the
basic assumption was that power came from the individual
acting differently. Thus, to a certain extent the choice of
market mechanisms is at once materially and ideologically
driven.
5 In a 2001 ABC poll, 93% of respondents supported mandatory
labeling of GE foods. Similarly high levels of support have been
reported since (Hallman et al. 2004; PIFB 2005).
6 Personal interview, 17 August 2006.7 Personal interview, 17 August 2006.
The politics and history of non-GMO certification 355
123
Using the market from within: position and place
While market strategies appeared to be the only avenue of
intervention available to NGMOP founders, third-party
certification was not pursued immediately by organizers.
Even after a label scheme was proposed, my informants
perceived it as a feasible but limited strategy. Pervasive as
neoliberalization is, any explanation of why third-party
Non-GMO certification is being attempted is incomplete
without understanding the ways organizers’ personal con-
texts and desires shaped the groups’ evolution. In this
section, I trace NGMOP’s initial manifestations and
explore the role of individuals in determining the group’s
strategy.
Like many eco-certification programs, the Non-GMO
Project grew from the modest efforts of a handful of con-
cerned individuals. In 2002 workers at The Natural
Grocery Company (NGC) in Berkeley, California, received
word from a supplier that their bulk soy lecithin powder
was produced from GE beans. Workers at the store were
appalled that the manufacturer and the NGC would
knowingly carry such an item. This sentiment was shared
by customers, who began to question NGC’s ethics and
pressure representatives to remove all such ‘‘unnatural’’
foods. A petition circulated among concerned consumers
demanding that something be done. After engaging in a
frank conversation with employees, the store’s manage-
ment agreed to a wholesale product review.
The extensive project fell on the shoulders of three
dedicated employees who diligently cataloged every prod-
uct, from soymilk to skin cream to granola, for ‘‘at-risk’’
ingredients. Following the work of Tucson, Arizona’s, The
Food Conspiracy; and Brattleborough, Vermont’s Food
Coop, the group planned to contact manufacturers for
information about their sourcing practices and, when pos-
sible, find alternative suppliers for products known or
suspected to contain GE ingredients. The three realized,
however, that a request from a single small grocer was
unlikely to concern major manufacturers. So in early 2003
the group established the ‘‘People Want to Know’’ cam-
paign and began mobilizing support from the American
natural retail industry. The group contacted cooperatives
and food stores across the country asking that they endorse a
letter which would be sent to manufacturers requesting
information regarding their use of GE ingredients.
‘‘People Want to Know’’ was amazingly successful and
the letter was soon ‘‘signed’’ by 161 retailers from across
the country.8 The effort also expanded into Canada where
Toronto’s Big Carrot Natural Food Market took the lead in
mobilizing that country’s retailers. Internationalization has
been extremely important. The Big Carrot, having already
successfully run a non-GMO campaign in 2001, brought its
expertise and significantly increased the number of par-
ticipating stores. The ability to draw on discourses of cross-
border solidarity also strengthened the campaign’s position
as the voice of the average North American consumer.
The group’s early orientation towards the market was
not, therefore, strictly a consequence of political economic
constraints on other forms of organizing. The need for
retailer actions certainly stemmed from the repeated failure
to secure labeling legislation, but the decision to work
through retailers was largely a product of the group’s initial
purpose and activists’ position within the agrifood system.
That the founding members were all employees of a natural
food retailer gave them privileged access to retailers and
insight into the agrifood political economy. As employees
they were particularly attuned to the vulnerability of gro-
cery companies to consumer concerns, which they
consciously leveraged. When I asked why the group chose
to target manufacturers using retail purchasing power, one
of my informants stated flatly, ‘‘Who [better] can we go to
as, as employees of a natural grocery store to, to find out
about this than the companies?’’ Later he explained that
founding members:
[we’re] in a unique position to influence companies
because, you know, companies have a bottom line and
that’s sales to the stores that carry their products….And
retailers are dependent upon their customers’ loyalty
and their customers’ faith in what there’re selling
them….And everyone assumes, coming into a natural
grocery store, that everything they’re getting there [is
natural]…. What this project is doing … really calling
both the stores and the companies to, to take respon-
sibility for that assumption.9
As evidenced by the almost complete elimination of GE
foods from Europe after leading supermarkets refused to
stock them, mobilizing retailers in this way is a potentially
powerful tactic. Since the 1990s the market size and
spatial scope of supermarket firm grew precipitously in
response to the reduction of barriers to international trade
(Morgan et al. 2006). Highly oligopolistic, this sector is
the central pivot of agrifood production, with firms com-
peting fiercely on the basis of non-price aspects such as
service, convenience, variety and quality (Dixon 2002;
Freidberg 2003; Busch and Bain 2004). The last factor is
particularly crucial to natural food retailers who distin-
guish themselves from conventional companies based on
their ability to provide high quality, nutritious and8 While ‘‘People Want to Know’’ officially called participating
retailers ‘‘signators’’ no one ever actually signed anything. Rather,
stores just agreed to have their names added to a list of supporting
firms. 9 Personal interview, 17 August 2006.
356 R. J. Roff
123
environmentally-friendly goods. Non-GMO Project activ-
ists capitalized on this vulnerability by offering retailers a
new way to attract consumers and publicly reaffirm their
corporate philosophies.
What is important about these early moments is that
while the group pushed for the private regulation of GE
foods, they did so in a different and potentially more
transformative way than third-party certification. More-
over, this history suggests that market tactics derive not
just from the limits imposed by neoliberalization, but from
the particular knowledge and position of individuals
involved.
From ‘‘People Want to Know’’ to ‘‘The Non-GMO
Project’’
When I met with NGMOP’s organizer for a third time in
August 2007, the optimism he had expressed a year earlier
was gone and he spoke with thinly-veiled anger of having
experienced corporate take-over and industry co-optation.
Indeed, what occurred between October 2006 and July
2007 was remarkable and troubling. In the span of a few
months, ‘‘People Want to Know’’ transformed into the
Non-GMO Project and moved from the grassroots to the
corporate scene. The ensuing struggle for power shifted
control into the hands of the industry that NGMOP had
intended to influence. What started as a grassroots effort to
capitalize on retail power transformed into a profitable
marketing tool with weak requirements and a high-entry
barrier.
This section traces the NGMOP through two critical
partnerships that precipitated the move to third-party cer-
tification: the first with Genetic ID (GID) in the spring of
2006, and the second with United Natural Food Inc.
(UNFI) later that fall. While each was essential to attract-
ing widespread participation by manufacturers and
retailers, in combination these events have signifi-
cantly altered the NGMOP’s long term transformative
potential.
Despite the long list of endorsements from natural food
retailers, manufacturer response to the group’s initial letter
was extremely uneven. Large manufacturers, those that
arguably hold more influence in the food system, paid little
attention to the ‘‘People Want to Know’’ campaign. As one
informant lamented during our first meeting:
Well, the bigger companies…said they had [non-
GMO practices] but they wouldn’t detail it for us.
They just—that’s what I mean, where they would say,
‘‘We don’t carry GMOs.’’ Or they would just pho-
tocopy their website and send it to us. And it’s like,
that doesn’t tell us anything because it’s just you’re,
you’re saying you do something about it but you’re
not saying what it is you do.10
Smaller companies, for whom the loss of a single retail
outlet could be potentially devastating, were far more
forthright and many provided stacks of documents attesting
to the purity of their supply chains. However, with limited
resources the campaign faltered under the mounting
workload of compiling, standardizing and assessing the
responses. As time passed and volunteers moved to other
projects and employment, the campaign stalled. Energies
revived, when organizers received an unexpected offer to
partner with GID, the world’s leading Non-GMO certifi-
cation firm. GID suggested the campaign shift from
enrolling retailers to developing a standardized verification
process for non-GMO products. To this end, GID offered
its technical assistance and access to its existing infra-
structure at a reduced cost.
While generous, this offer should not be construed as
altruism. For GID, the NGMOP was an opportunity to
expand its clientele beyond companies exporting to the
European Union and Asia and stimulate a domestic market
for non-GMO products for which it would be the principal
certifying body. Indeed, although testing is decentralized,
Food Chain Global Advisors (FCGA), GID’s parent firm,
maintained control of verification and certification. With
GID’s guidance, the ‘‘People Want to Know’’ campaign
was re-christened The Non-GMO Project and the group
released an initial standard and shopping cart seal in late
summer of 2006. After public and private consultation a
final Working Standard was amended to accommodate
manufacturer concerns and released with a new seal in
February 2008 (Fig. 1).
Initially, GID’s representatives appeared committed to
limiting the food industry’s involvement in setting the
standard. They repeatedly agreed that NGMOP was ‘‘not
here for the manufacturers.’’11 However, shortly after
Christmas 2006 the firm began stressing the need for
industry ‘‘buy in.’’ John Fagan, GID’s founder and CEO,
actively involved natural food manufacturers and sought
their advice on how criteria should be developed. The
NGMOP’s purpose was reframed from living up to
consumer expectations and protecting human and envi-
ronmental health, to providing a competitive edge to
companies in an increasingly crowded food market. Pro-
motional material stressed the financial benefits of
participation and the huge number of consumers waiting to
purchase certified products. For example, by fall 2007 the
NGMOP’s website promised that the Non-GMO label
would give companies a way to ‘‘guarantee the GMO-free
10 Personal Interview, 17 August 2006.11 Personal correspondence, 31 May 2007.
The politics and history of non-GMO certification 357
123
nature of their products to a public who has consistently
polled in favor of labeling for informed choice regarding
GMOs.’’ An information brochure distributed through
retailers also assured participating firms increased sales and
premium prices:
Because of the dangers, and because of the lack of
sufficient testing, an overwhelming majority of our
customers do not want GMOs in their food and are
eager to invest in their health and food safety by
buying products that have 3rd party Non-GMO
verification.12
Fagan expresses this sentiment succinctly in an earlier
editorial in the Natural Food Merchandiser. The non-GMO
label would provide a necessary incentive for manufac-
turers to participate because ‘‘[c]ompanies know that
consumers are concerned. They know that being GMO-
Free adds value to their products’’ (Fagan, in Lewandowski
2004, p. 1).
In our many conversations, my informants were ada-
mant that the partnership with GID was not meant to
change the group’s focus so radically. While they agreed
that a third-party certification would be beneficial, they did
not believe that it should rely on premiums to attract par-
ticipants but rather that companies should certify their
products because consumers and retailers demand non-
GMO foods. To them, the seal was meant to precipitate a
politics of consumption by providing choice and making
shoppers aware that GE foods existed. Non-GMO was not
meant to be simply another alternative niche, but rather a
statement of opposition that would eventually become the
norm.
Thus, NGMOP organizers were increasingly concerned
about the industry’s role and, despite Fagan’s attempt to
ease their fears by arguing that manufactures shared the
group’s opposition to agricultural biotechnology, activists
struggled to maintain some measure of independence. They
established an ‘‘Educational Network’’ and ‘‘Technical
Committee’’ to draw together representatives of academia,
consumer advocacy groups, farmers, individual consumers
and the food industry. GID rebuffed these efforts and in
their stead created an ‘‘Advisory Board’’ dominated by
food industry leaders.13 Nevertheless, in the end the group
was lured by the possible participation of major manufac-
turers and accepted GID’s guidance.
Meanwhile, UNFI, the U.S.’s largest manufacturer and
distributor of natural and organic products, solicited
NGMOP organizers in Fall 2006. UNFI offered to sponsor
a public debut at the Natural Products Expo West in
Anaheim, California. As with GID, UNFI’s interest came
as a surprise to activists, who were still skeptical of
receiving support from industry leaders. Even more sur-
prising was Whole Foods’ enthusiastic interest in the
review process. When I first met the NGMOP founder in
August 2006 he expressed little hope for the retail giant’s
participation because, as he put it, ‘‘it’s such a highly
charged political thing.’’14 Yet, when UNFI’s president and
CEO, Michael Funk, called on natural food manufactures
‘‘to eliminate GMOs from natural and organic products’’ at
the Natural Products Expo, Whole Foods and other
industry leaders were quick to lend their weight to the
effort.
Accepting UNFI’s sponsorship altered the NGMOP’s
trajectory again. As the Expo neared, staff and volunteers
found themselves further removed from the planning pro-
cess. Their original format was replaced with a new list of
speakers and NGMOP representatives were allocated only
5 min to speak at the session’s end. The group was shocked
to find that the original online abstract did not mention the
Non-GMO Project by name, but rather referred only to the
need to develop some sort of certification process. While
NGMOP’s volunteers managed to pressure UNFI to fix this
‘‘minor’’ oversight, the presentation remained dominated
by industry representatives. On 9 March 2007 it was
Michael Funk, UNFI’s founder and CEO, who officially
introduced, explained and promoted NGMOP. In his
speech to the overflow crowd he framed NGMOP as an
initiative created by and for the industry. Later, in an
interview with the Organic and Non-GMO Report, he
reiterated his ‘‘call to action’’ and in the process discur-
sively eliminated NGMOP founders again:
The Non-GMO Project was originally a retailer ini-
tiative, but we asked that it be industry-wide,
including farmers, processors, manufacturers, dis-
tributors and retailers….We will be putting our own
products through the process to verify that they are
non-GMO. We will also encourage vendors and food
manufacturers whose products we distribute to verify
their products as non-GMO. (Funk, in Roseboro
2007a, p. 1)
This framing is repeated on the website which currently
introduces NGMOP as, ‘‘a non-profit organization, created
by leaders representing all sectors of the organic and nat-
ural products industry in the U.S. and Canada’’ (NGMOP
2007).
12 I was given a copy of this pamphlet in August, 2007. While this
particular brochure is not electronically available as of 1 October
2007, the same text may be found at: http://www.ghorganics.com
/CampaigntoTestNaturalFoodsSupplements.htm.13 Since this time the Board of Directors created a Technical
Advisory Board; however, the majority of members are major natural
food manufacturers and retailers. 14 Personal interview, 28 October 2006.
358 R. J. Roff
123
Over the fall and winter the struggle for control raged.
GID and UNFI repeatedly asked NGMOP members to
‘‘give over control of the standard to the industry’’ and
volleyed threats that without input the industry would
likely develop their own certification system.15 When the
group refused to appoint representatives of major food
firms to the Board of Directors, GID and UNFI threatened
to cancel the Anaheim presentation.
It is unclear to what extent it was these injunctions or the
lure of enrolling major manufacturers that convinced
activists to open the doors to industry, but the effect has
been profound. NGMOP’s Board of Directors now reads
like a Who’s Who of the natural foods market. Among its
members are Joe Dickson (Whole Foods Market), Michael
Potter, (Eden Foods), George Siemon (Organic Valley),
and Arran Stephens (Nature’s Path) as well as John Fagan
and Michael Funk. Consequently, the certification is being
explicitly designed by and for major manufacturers—a fact
materially evidenced by the use of six major food firms—
Strauss Family Creamery, Eden Foods, Lundberg Family
Farms, Nature’s Path, Whole Foods Market and United
Natural Foods—to test and ‘‘fine-tune the [initial] verifi-
cation process’’ (Fagan, in Roseboro 2007b, p. 3).16
Assessing the transition
In light of scholars’ critiques of third-party certification it is
important to assess the effect of the transitions from relying
on retailer- to consumer-purchasing power driven by a
grassroots effort, to industry-controlled certification. Retail
power is many times greater than the sum of consumer
choices. As food manufacturers’ primary customer they are
the doorkeepers to profits and thus can force widespread
and rapid change. Third-party certifications, on the other
hand, first require groups to stimulate sufficient consumer
demand to attract initial participants. Retailers and the
broader agrifood industry must then recognize that a
profitable market exists. However, their recognition is
hampered by the inconsistency of individual sales and thus
consumption must reach significant levels before market
signals are perceptible. In essence, certification adds
another barrier through which public concerns must travel
to be heard.
On the surface the entrance of major manufacturers and
retailers gave NGMOP a certain amount of authority and
increased the label’s credibility, but there are important
reasons to be wary of the present situation. Rather than
signaling a major step for the anti-biotechnology move-
ment, it threatens the standard’s rigor and further
centralizes control of agrifood regulation in the hands of
industry. For example, the initial assessment fee has
increased substantially, potentially pricing-out smaller
manufacturers already burdened with the cost of existing
certifications. In addition, the originally strict tolerance
level has been replaced by a shifting threshold. The current
Board of Directors is adamant that the total absence of GE
material (or at the very least a maximum tolerance 0.5%
contamination) is NGMOP’s ultimate goal. However, it is
also quick to amend all statements to this effect with the
caveat that the ‘‘current agricultural climate’’ in which the
contamination of non GE products with GE material is
nearly unavoidable, prohibits a significant move in this
direction. In place of a single strict threshold, the Board
established ‘‘a series of action thresholds … to provide
realistic interim definitions of non-GMO’’ (NGMOP 2007,
p. 3).
These small changes are significant. NGMOP initially
wanted to use retailer buying power to eliminate GE foods
and crops. While eliminating GE products remains the
project’s outward goal, the reliance on industry and the
move from a demand-push to premium-pull system mag-
nified the already-limited transformative potential of
certifications as a class and introduced many of the tensions
noted by agrifood scholars. The shifting threshold is par-
ticularly worrisome. It tacitly accepts trace contamination
insofar as it sets requirements according to what is avail-
able. The recent LLRICE 601 and 62 debacles, in which
conventional long-grain rice supplies were contaminated
by two unapproved variety of GE rice, underscores a
mounting body of evidence documenting the widespread
existence of GE traits in purportedly non-GE seed and food
stocks (Haslberger 2001; Bouchie 2002; Villar 2002;
Mellon and Rissler 2004; Vermij 2006; Vogel 2006;
Greenpeace 2007).17 Preventing mixing either through
cross-pollination or in post-harvest processing is quickly
becoming impossible as GE harvests increase in geo-
graphic extent and harvest volume. Some observers already
argue that the complete absence of GE material unrealistic
(Roseboro 2006).18 As contamination increases, the
NGMOP’s threshold is poised to increase accordingly.
In so doing, it minimizes pressure on manufacturers
and growers to find ways to completely eliminate GE
15 Personal Communication, Non GMO Project, 28 May 2007.16 Soon after the board of directors was re-populated by industry
representatives, the Project’s founder quit the campaign. He continues
to mobilize against GE crops and foods, but no longer believes the
Project will achieve this goal.
17 LLRICE is the short-hand given to a series of rice varieties (in this
case 601 and 62) developed by BayerCrop Science to resist the
company’s herbicide, Liberty Link.18 This is the logic behind the high tolerance thresholds for
mandatory labeling laws in Europe and elsewhere.
The politics and history of non-GMO certification 359
123
material—a necessity if the NGMOP is to significantly
slow or prevent the spread of GE technology.
The shifting threshold also opens a space for the mate-
rial implications of ‘‘Non-GMO’’ to be distanced from the
label’s popular meaning. Consumers already expect that
Non-GMO products are free of GE traits. Indeed, this
expectation will drive premiums in the market. However,
under the current system thresholds allow a significant
amount of contamination, creating a profitable gap that
allows major manufacturers to capitalize on consumer
concerns without significantly altering their practices.
This gap undermines anti-biotechnology activism in
three related ways. First, it obscures genetic contamina-
tion—a process with potentially grave ecological and, with
the introduction of pharmaceutical-producing crops, health
effects (Andow et al. 2004; Mellon and Rissler 2004). In
recent years activists have used this issue to successfully
slow the introduction of novel GE products, such as Ven-
tria Life Science’s pharmaceutical rice and Monsanto’s
Roundup Ready alfalfa. Unless the NGMOP highlights its
inability to guarantee zero GE presence—something it has
no incentive to do—a Non-GMO label gives the impression
that contamination is currently preventable and thereby
undermines this essential and influential public concern.
Second, a non-GMO label weakens demands for man-
datory labeling, which is problematic in two senses. First,
demands for labeling keep biotechnology on the states’
agenda. Second, the inability for consumers to quickly
assess the quality of their food is a materially and discur-
sively compelling fact around which to mobilize public
opposition. Not only would a non-GMO label quell con-
sumer concern, but it would do so without necessarily
changing the content of the food supply. In essence, the gap
between the label’s meaning and its effects may prevent
radical changes that could occur if individuals continued to
be dissatisfied with offerings on their grocery shelves.
Third, by allowing potentially large amounts of con-
tamination, a shifting threshold undermines efforts to trace
the health effects GE foods. With more than 70% of pro-
cessed food containing GE material (Kimbrell 2007), the
non-GMO market is the only control group against which
to judge the long term consequences of GE products.
However, given that non-GMO products will also contain a
level of GE material whatever effects may occur would
also occur in people eating non-GMO, thereby limiting the
likelihood of being accurately attributed to changes intro-
duced through GE.
My purpose is not to say that non-GMO as a concept is
meaningless. Non-GMO companies must avoid GE prod-
ucts at some level and through this search have spurred
alternative supply networks. Endeavoring to reduce con-
tamination, actors in these networks, such as the National
Grain and Feed Association, North American Export Grain
Association and Organic Trade Association, are pressuring
decision makers to tighten regulations governing the
commercial and experimental release of GE crops. While
having only limited legislative effect so far, these efforts
are bringing increased attention to the inadvertent spread of
GE traits between crops, and from crops to wild relatives.
Yet companies’ concern for regulations and contamination
is a function of the requirements of domestic and interna-
tional markets. China’s policy of zero tolerance for the
adventitious presence of GE traits is far more onerous than
Japan’s 5% threshold. A threshold that shifts according to
the ‘‘reasonable’’ presence of GE material in non-GMO
products will not stimulate as much pressure to increase
oversight as would a strict and preferably low tolerance
level.
In sum, NGMOP is now better suited to help companies
avoid mounting public criticism than to substantially
reorient agrifood production—a problem scholars have
repeatedly noted regarding industry-dominated certification
(Renard 2005; Raynold et al. 2007). Indeed, by requiring
manageable change and promising higher prices it opens a
space for yet another alternative market and provides little
overt opposition to the present system.
Conclusion: choosing certification or is there another
way out?
The story of the Non-GMO Project underscores the diffi-
culties of using third-party certification as a tactic in
agrifood activism. Despite committed efforts to the con-
trary, NGMOP was taken over by industry interests. What
was once an effort to push manufacturers to eliminate GE
ingredients was transformed into an incentive-based pro-
ject aimed at pulling the industry with premium prices.
Industry control has also shifted criteria from what is
technically feasible to what is economically possible. On
the one hand, this shift increased industry interest. On the
other hand, it weakened NGMOP’s potential as a mecha-
nism to prevent the spread of GE products. Moreover,
industry control supports the tendency for certifications to
re-legitimize dominant agrifood actors and reduce public
debate insofar as it tempers criticism by satisfying con-
sumers’ perception that they can eat non-GMO, and thus
are participating in the effort to eliminate GE products.
It would be easy to condemn NGMOP’s emphasis on
private regulation and call for a return to policy-focused
activism. However, the group’s story suggests why activ-
ists might choose this avenue despite knowing its dangers.
The current state of affairs resulted from a set of particular
people acting, and events unfolding, within a context in
which consumer activism was one of the few options that
existed. Certification was not, however, chosen because
360 R. J. Roff
123
there was no alternative. The climate of lax regulation and
state support of product commercialization and industry
development circumscribed the range of possible political
interventions. Yet, the label itself emerged at the behest of
certifiers and food manufacturers. In essence, it emerged
not from activists, but from institutions that were poised to
gain financially from its implementation.
If certification is not the necessary outcome of a neo-
liberal context, what alternatives exist? A cursory review of
the anti-biotechnology movement’s past successes suggests
that there are many. In particular, directly targeting
retailers and food manufacturers by highlighting procure-
ment policies or threatening to do so has forced leading
firms to publicly reject GE ingredients. McDonald’s refusal
to accept Monsanto’s GE potatoes single-handedly ended
the crop’s development. More recently, Anheuser Busch’s
threat to stop buying Missouri rice if the state allowed the
cultivation of pharmaceutical varieties, severely curtailed
the crops’ commercial fate.
As mentioned, retail boycotts in Europe have been
instrumental in slowing the introduction of GE foods and
plants in the U.S. and abroad. Given the power of super-
markets, it is arguable that they offer the best point of
intervention. However, it is also important to note, that
NGMOP organizers were open to GID’s suggestion in
large measure because their initial effort did not promise to
be lucrative enough to attract major retailers. This problem
did not necessitate certification; rather it was a matter of
mobilizing sufficient and visible criticism to force move-
ment—as Michael Pollan’s successful shaming of
WholeFoods into buying local products illustrated (Mackay
2006; Ness 2006). The answer to this dilemma, therefore,
should not be a turn toward ‘‘buycotts’’ but to boycott or
what Raynolds et al. (2007, p. 149) call a tactic of ‘‘name
and shame’’ (see also Guldbrandsen and Holland 2001).
Moreover, from my conversations with manufacturers and
retailers across the U.S. it is clear that well-timed consumer
inquiries (e.g., emails, telephone calls, letters, etc.) can
have a major effect on company policy. Perhaps the solu-
tion is for activists to ‘‘go underground’’ and voice their
concerns rather than purchasing their way to a better world.
Other potentially powerful market tactics include tar-
geting investor confidence by using socially responsible
investment funds to redirected capital or investor groups to
introduce proxy resolutions to corporate boards of direc-
tors. For example, on 5 March 2008, the Interfaith Center
on Corporate Responsibility called on its members to
threaten to retract support for 63 major food manufacturers
if they do not publicly ‘‘announce that [they] will NOT use
sugar from genetically modified sugar beets’’ (Lowe 2008).
The group has successfully leveraged its $110 billion of
cumulative investments in the past to spur anti-sweatshop
policies in the textile industry (Bartley 2003) and force
Pepsi Inc. to draft a policy regarding its use of GE ingre-
dients (ICCR 2007). It has also used its network of
religious groups to foster crucial boycotts of food manu-
facturers, such as Nestle, to change socially and
environmentally practices (Ermann and Clements II 1984).
Broadening definitions of ‘‘consumer activism’’ is also
important. Institutional purchasing programs, like those of
retailers and manufacturers, function at much larger scale
than individual shopping. Targeting schools, churches,
state agencies, sporting venues or hospitals is in some ways
easier than shifting millions of practices insofar as they are
singular objects and dependent on public confidence. As
privatization and competition run apace in education and
healthcare the importance of reputation rises concomi-
tantly. In some ways, therefore, activists can leverage
neoliberalization to their advantage.
I do not mean to imply that activists should forgo policy
making and the state completely. To do so is defeatist and
essentially gives up on broader efforts to construct radi-
cally different political economic systems that do not
reproduce the social and environmental legacies of late
twentieth century capitalism. My point is simply that to
believe that there is no alternative to certification is equally
defeatist. The market offers manifold points of interven-
tion—more than I suggest here—and narrowing the focus
to one with so many problematic consequences belies what
is truly possible, even in a neoliberal world.
In sum, by examining the forces, structures and deci-
sions that intersected in this particular instance, this paper
grounds the politics of food in the lives of real people,
occurring in real time. Accordingly, certification was not a
strategy decided upon a priori, but the outcome of mud-
dling through a series of political economic contingencies.
Thus, critical gaze might be best focused on the specific
situations that re-direct potentially beneficial interventions
towards projects that perpetuate the power of elites and
provide limited relief from agro-ecological problems.
Acknowledgements This research was supported in part by the
Social Science and Humanities Research Council of Canada. I would
particularly like to thank my confidential informants for their time and
insights during my field research, and Geoff Mann, Harvey James and
two anonymous reviewers for their comments on early drafts of this
paper.
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Author Biography
Robin Jane Roff is a PhD Candidate in the Department of Geography
at Simon Fraser University, British Columbia, Canada. She received a
Bachelors of Art in Geography and Political Science from the Uni-
versity of Toronto in 2003. Her research focuses on the dimensions of
counter-culture and environmental activism in late capitalist societies.
Her dissertation critically explored the power and influence of the
American anti-biotechnology movement and was funded by the
Social Science and Humanities Research Council of Canada.
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