A multiplicity of national approaches:
During the last seven years, more than forty countries have adopted labeling regulations for GM food, but the characteristics of the regulations and their degree of implementation vary greatly. Among the countries with labeling laws, the only common feature is the requirement to label products derived from GM crops that are not substantially equivalent to their conventional counterparts, such as nutritionally enhanced GM crops. In contrast, for products that are considered substantially equivalent to conventional products (e.g., from 1st generation GM crops), there is a large international heterogeneity in labeling policies.
A first major dichotomy separates countries with voluntary labeling (e.g., Canada or Hong Kong) to those with mandatory labeling requirements (e.g., Australia, the European Union, Japan or China). Voluntary labeling guidelines dictate rules that define which foods are called GM or non-GM. They allow food companies to decide if they want to use such labels on their products. In contrast, mandatory labeling requires that food handlers (processors, retailers and sometimes food producers or
restaurants) display whether the targeted product/ingredient contains or is derived from GM materials.
Secondly, among countries with mandatory labeling, regulations differ widely according to the following characteristics:
a) Coverage: countries may require labeling for a list of particular food ingredients or all ingredients that include
detectable transgenic material; highly processed products derived from GM ingredients, even without quantifiable
presence of transgenic material; animal feed; additives and flavorings; meat and animal products fed with GM feed;
food sold at caterers and restaurants; and unpackaged food.
b) Threshold level for labeling of GM ingredients: can be applied to each ingredient or only to three or five major
ingredients; and its level ranges from 0.9% to 5% (with the exception of China).
c) Labeling content: “genetically modified” item on the list of ingredients, or in the front of food packages.
One of the major differences in regulations among countries with mandatory labeling depends on whether the regulation targets the presence of GM in the finished product or on GM technology as a production process. In the former case, only products with detectable and quantifiable traces of GM materials or ingredients are required to carry a label. In contrast, in the latter case, any product derived from GM crop will have to be labeled, whether or not it contains any traces of GM material. This difference is crucial for enforcement: a product-based system can be enforced with testing equipment to filter a cheater, whereas a process-based system requires viable and trustworthy documentation systems, which will lead to identity preservation or traceability requirements for the producers and importers, but do not guarantee the absence of fraud.
Lastly, national regulations differ by their degree of implementation. Most developing countries with mandatory labeling laws of GM food have not implemented the laws, or have only partially enforced the laws. So far, China can be considered the only developing country with a mandatory labeling policy in place.