Implementing 1-day traceability and 5-year retention under Non-GM

Regulatory scope and mandatory prerequisites

The GLOBALG.A.P. Non-GM or Ohne Gentechnik add-on Module 2 establishes mandatory compliance criteria for livestock and aquaculture producers supplying non-genetically modified markets. Operating under Module 2 requires an active Integrated Farm Assurance certificate for aquaculture or livestock as an indispensable prerequisite. The add-on applies to producers located in EU member states where Regulation EC 1829/2003 and Regulation EC 1830/2003 apply, countries with equivalent legislation, or jurisdictions prohibiting commercial cultivation and import of genetically modified organisms.

This regulatory framework directly affects quality managers, compliance leads, and internal auditors managing certified production sites. Certification bodies conduct annual audits against Module 2 control points and compliance criteria. Upon successful audit completion, the certification body issues a formal letter of conformance verifying that farm production processes satisfy non-genetically modified production rules.

Compliance leads must understand that Module 2 rules extend beyond general farm assurance. Operational requirements enforce strict controls across facility descriptions, risk assessments, staff training, documentation retention, feed segregation, and crisis management protocols. Failing to maintain verifiable traceability or document retention risks immediate non-conformance and forfeiture of the letter of conformance.

Practical execution of one-day traceability and feed controls

Control point NON-GM FARM 5.1 mandates that producers must operate a traceability system capable of tracing labeled products back to the farm of production within one working day. The system must unmistakably identify all non-genetically modified animals and compile quantitative evaluations demonstrating product flow plausibility. Quality managers must test this one-day trace-back mechanism annually to verify operational readiness.

Feed management is governed by strict incoming verification and physical segregation rules. Control point NON-GM FARM 5.2 requires the incoming goods department to verify via delivery notes that all purchased feed meets non-genetically modified specifications. Delivery bills for acquired feed must be examined for completeness and filed chronologically:

• Feed segregation: Control point NON-GM FARM 5.3 requires physical segregation during receipt, storage, internal transport, and feeding. Simultaneous storage of genetically modified and non-modified feed is permitted only if permanent physical separation is maintained.
• Parallel feeding prohibition: Control point NON-GM FARM 5.4 strictly prohibits simultaneous storage and feeding of genetically modified feed to the same animal category on the same production site.
• Outgoing declarations: Control point NON-GM FARM 6.1 requires all delivery notes and invoices to state that products are suitable for the production of food labeled Non-GM or Ohne Gentechnik.
• Crisis management: Control point NON-GM FARM 6.2 mandates a documented procedure to block and relabel dispatch batches if analytical testing reveals genetically modified content above 0.9 percent.

Document retention standards and species conversion timelines

Documentation management is governed by control point NON-GM FARM 4.1, which mandates that all records concerning non-genetically modified labeling must be retained for at least five years. During the initial five years of certification, producers must maintain records for the entire active production period. At the initial audit, historical documentation must cover the mandatory species conversion feeding timelines defined in Annex 1.

Mandatory document retention applies to specific administrative and operational files:

• Required record types: Control point NON-GM FARM 4.1 specifies that delivery bills, supplier invoices, purchase orders, seed declarations, feed specifications, and crop growing records must be preserved for five years.
• Aquaculture conversion period: Annex 1 requires farmed fish to be fed non-genetically modified feed for their entire lifetime from hatching onwards.
• Livestock conversion periods: Annex 1 establishes minimum feeding periods of twelve months and at least three quarters of lifetime for beef cattle, six months for small ruminants, and four months for pigs.
• Internal self-assessment: Control point NON-GM FARM 2.5 requires completing at least one documented internal self-assessment against Module 2 criteria annually before the certification body inspection.

Summary of Non-GM Add-on compliance requirements

What to do now

• Establish 5-year archiving systems: Secure physical and digital archives for all feed invoices, delivery notes, seed declarations, and crop logs.
• Test 1-day trace-back procedures: Conduct mock traceability exercises to confirm that farm origin and mass balance data can be compiled within one working day.
• Verify species conversion feeding logs: Review feeding records to ensure all stock fulfill Annex 1 conversion timelines prior to commercial dispatch.
• Audit incoming feed delivery notes: Ensure incoming feed shipments contain complete non-genetically modified declarations and are filed chronologically.

Reference documents

• GLOBALG.A.P. Non-GM / Ohne Gentechnik Add-on – Module 2: Farm/Producer, v1.1_Jan20, Section NON-GM FARM 1, Section NON-GM FARM 2, Section NON-GM FARM 3, Section NON-GM FARM 4, Section NON-GM FARM 5, Section NON-GM FARM 6, Annex 1