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Traceability for GM Food

S.I. No. 268 of 2013 implements the traceability requirements for food or food ingredients containing, consisting of or produced from GMOs, as set out in Regulation (EC) No 1830/2003. This Regulation requires that accurate information is available to food business operators and consumers to enable them to exercise freedom of choice in an effective manner as well as to enable control and verification of labelling claims. The Regulation requires that business operators must transmit and retain information about products that consist of or contain GMOs at each stage of the placing on the market of the product.

Under Article 4 of Regulation (EC) No 1830/2003, operators must ensure that the following information is transmitted in writing to the operator receiving the product: 

  • that it contains or consists of GMOs;
  • the unique identifier(s) assigned to those GMOs in accordance with Article 8 as a means of indicating its presence and reflecting the specific transformation event covered by the consent or authorisation for placing that GMO on the market (see below)

However, where specific identification systems such as lot numbers are in place, except for the first placing on the market, the transmission of this information is not necessary (Article 6).
Operators must have in place systems and standardised procedures to allow the holding of information and the identification of the operator by whom and the operator to whom the products have been made available.


Conventional food products may unintentionally contain traces of GMOs, for example, due to cross-pollination, or due to adventitious or technically unavoidable mixing of GM and non-GM ingredients during harvesting, storage, transport or processing. Such products are not subject to traceability or labelling requirements if the GMO traces are no higher than 0.9% of the individual ingredient and where the operator can demonstrate to the competent authority that they have taken appropriate steps to avoid the presence of GM material. 

Unique Identifiers

Commission Regulation (EC) No 65/2004 establishes a system for the development and assignment of unique identifiers for genetically modified organisms and applies to GMOs authorised for the placing on the market. The format for unique identifiers is set out in the Annex to that Regulation.