Options For CFIA Verification Of Russian GMO Regulations V2

Option for Industry Discussion and Comment CFIA Oversight of Compliance for Russian GMO Regulations Russian GMO Regulations As we understand it, pet food is licensed in Russia as ‘feeds for non-food producing animals’. Feeds produced without using GMO ingredients may contain unregistered (unintentional) lines at a level of 0.5% or less or registered lines at a level of 0.9% or less. GMO’s of concern are those strains found in corn, soy, rapeseed. The following is the suggested wording to provide CFIA for a proposed approach to verify compliance to the Russian GMO regulations. Options for CFIA Verification of Compliance Companies can provide the following to the CFIA during their annual inspection of the facility(ies): A company issued letter, declaration or notarized affidavit stating that the company does not intentionally formulate products using ingredients containing GMOs, and that any GMO’s found in products are unintentional. To support this statement, companies can provide a risk-based validation of their products, which could include documentation from their suppliers and other validation of their internal processes as required. Each company will be unique in what processes they take to ensure compliance, and each will be unique in how they validate these processes. The CFIA can review and verify each validation protocol on a case by case basis. Questions and Comments for CFIA Will this verification process by CFIA be applied on ALL exported product to Russia, or only those companies that are new to the market or have been temporarily suspended? Some companies have been exporting for over a decade with no issue. The industry would like clarification on what specific GM lines are of concern to Russia? If any new process is put in place by CFIA to ensure compliance, the industry wants to ensure that business will continue as usual and there will be no interruption of the Russian market during the process of finalizing any such process.