Agric Hum Values (2009) 26:351363 DOI 10.

1007/s10460-008-9166-5

No alternative? The politics and history of non-GMO certication

Robin Jane Roff

Accepted: 28 May 2008 / Published online: 16 September 2008 Springer Science+Business Media B.V. 2008

Abstract Third-party certication is an increasingly prevalent tactic which agrifood activists use to help consumers shop ethically, and also to reorganize commodity 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 certication 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 alternative. This paper offers a different assessment of thirdparty certication, and points to interventions that are potentially more inuential that are currently available to activist groups. Exploring the evolution of the Non-GMO Projecta novel certication for foods that are reasonably free of genetically engineered (GE) materialI make two arguments. First, I echo the literatures critical perspective by illustrating how certication 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 neoliberalization and organizers places within the food system initially oriented the group towards the private sector, the choice to pursue certication arose directly from two industry partnerships. Consequently, current trends might
R. J. Roff (&) Department of Geography, Simon Fraser University, 8888 University Drive, Burnaby, BC, Canada V5A 1S6 e-mail: rroff@sfu.ca

favor market mechanisms, but certication is only one possible intervention that has emerged as a result of particular, 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 certication Alternative agrifood system Abbreviations FDA U.S. Food and Drug Administration GE Genetically engineered GFCA Global Food Chain Advisors GID Genetic ID GMO Genetically-modied 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 Cummings 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

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coalitions of activists, retailers and manufacturers who then advocate for third-party certication for non-GMO products.1 Led by Berkeley, Californias 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, NGMOPs 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 thirdparty certication 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 certications 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 benets of production to actors marginalized by common economic practices (Renard 1999; Goodman 2004; Shreck 2005). Others, such as organic and locally-produced labels, purport to embed commodities in specic geographies and preserve ecological and socio-economic qualities (Murdoch et al. 2000; Morgan et al. 2006). In either case, so the story goes, certication programs should foment alternative food networks that internalize the externalities of their more

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 specic references to the Non-GMO Project because although GMO is widely recognized to stand for GE, the two terms are not synonymous. GE refers specically 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 modied 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 biotechnology 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 signicant departure from past practices (Fedoroff and Brown 2004). 2 I focused only to third-party certication, a type of certication provided by private entities outside the manufacturing industry. It is beyond the scope of this discussion to explore similar trends in rst and second-party certication systems, although such a project is worthy of future investigation. For details on the difference between these certication types see Geref et al. (2001).

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 predominantly 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 certications reproduce neoliberal subjectivities and market 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 socioeconomic 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 problematically, when successful, third-party certiers experience downward pressure on standards as they attempt to attract manufacturers and compete with similar labels (Geref et al. 2001; Mutersbaugh 2005). The progressive weakening of evaluation criteria is particularly evident when certications emerge from industry (Raynolds et al. 2007) or from what Geref et al. (2001); see also Bartley 2003) call the NGO-industrial complex. Strict production standards 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 efciency as larger rms enter the market (and capture regulatory control) (Allen and Kovach 2000, p. 224). Running parallel to theses critiques are efforts to understand why certications are emerging at the present time. The majority of works focus on the macro-political context of national and international neoliberalizationin particular the elimination, weakening and obstruction of environmental and food safety regulations and the acceptance 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
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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 selfregulating 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).

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10 years that have given market-oriented policy instruments greater salience and Mutersbaugh (2005, p. 391) calls certication an emerging form of neoliberal governmentality. Fleshing out the specic mechanisms propelling private governance, Allen et al. (2003, p. 65) argue that the neoliberal revolution with its political culture of entrepreneurialism weakened the nancial support for radical social movements and shifted attention to consumer choice. Similarly, Gulbrandsen (2006, pp. 480481) suggests that certications compensate for governments perceived unwillingness or inability to address social and environmental concerns (see also Geref 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 ows 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 certication even within increasingly neoliberal political economies. Rather, in this paper, I follow Bartley (2003), as well as Guthmans earlier work (Guthman 1998, 2004) and explore the macro- and micro-political dynamics that converged to create the NGMOP. Specically, I illustrate that while neoliberalization and organizers place within the food system initially oriented the group towards the private sector, the choice to create a certication arose out of two specic industry partnerships. Consequently, the politics of the possible (Brown and Getz 2008) might favor market mechanisms, but certication is only one possible intervention among many. In making this argument I simultaneously examine the ways the industry captured control of the NGMOP and turned to towards prot 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 labels ambitious criteria have been weakened and the NGMOPs 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 certication and what increasingly appear to be unavoidable problems with choosing this path. After outlining the current state of non-GMO certication in the United States, I provide three snapshots of the context in which the NGMOP emerged and the groups specic 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 groups 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 products, organizers originally attempted to mobilize retailers to boycott GE foodsan intervention they perceived as more powerful and less problematic than certication. The fourth section traces the NGMOP through two critical partnershipsrst with Genetic ID (GID) and second with United Natural Foods Inc. (UNFI)that allowed the natural food industry to take control and shift the groups focus to a NonGMO certication. The penultimate section assesses this transition and explores the potential of the current NGMOP standard to meet the groups original or present goals. Unfortunately, it appears that despite the well-intentioned efforts of organizers, criteria are weakening. Consequently, the NGMOP is unlikely to signicantly 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 biotechnology. 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 programs 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 contacting retailers and I did not engage in making decisions, organizers kept me abreast of current events. The interviews 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 informants purposefully to ensure the sample included a diversity of rms with a range of revenues, distribution size, and product-type and worked within both the conventional 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 chosen 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 political-economic inuence of anti-biotechnology activism in the U.S., with a focus on California as a center of food

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R. J. Roff Fig. 1 The Non-GMO Projects 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

politics. I chose Sonoma County as a case study for multiple reasons; chief among which was the states 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 certication It bears repeating from the outset that NGMOP was not always about creating a novel certication; moreover, the groups 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 expectations, 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 certication, 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 groups 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 incentivebased schemes rely on the juxtaposition of certied 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 NGMOPs focus on protecting the natural food industrys integrity as opposed to reducing harvests of GE crops. I will return to such problems below. For now, let me briey review the certication standard, as it existed at the time of writing. The Non-GMO Project Working Standard (February 2008) outlines the purpose, scope and methods of assessment for companies wishing to use the Non-GMO seal. To begin, participants must submit specication sheets that disclose all components of each input (NGMOP 2008b). For low-risk inputsingredients derived from crops with no commercial GE counterparts (e.g., wheat, green peppers, or cherries)assessment ends here.4 For highrisk inputscrops 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)
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along the commodity path. Testing can be conducted on individual ingredients or nal 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 certication lls the regulatory vacuum created by the spread of neo-liberal [sic] policies and particularly deregulation in agro-good sectors. In the case of agricultural biotechnology, a Non-GMO label does not ll 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 selfmonitoring (Eisner 1993; Perrin 2006). Of particular note, food safety assessments are based on voluntary disclosure of test results generated by biotechnology rms and GE foods are treated as substantially equivalent to conventional counterparts. Nothing highlights the U.S. federal governments 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 condence (Smith 2003). The repeated attempts by anti-biotechnology groups to strengthen regulations by instituting mandatory labelling, shifting liability for contamination from farmers to biotechnology rms, and enforcing stricter monitoring of

The Board of Directors hoped to expand assessment in future to include end-product testing.

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pharmaceutical (pharm) crops have failed (Guthman 2003; Smith 2003). The two federal labelling bills introduced 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 sponsorship 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 ow 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 difcult for antibiotechnology 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 provision 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. Justied with calls to level the playing eld 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 Zonesone of the most successful tactics used to date to slow the spread of agricultural biotechnology 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 international politics. While numerous jurisdictions across Europe and Asia have labelling legislation and testing protocols in excess of U.S. requirements, groups were unable to
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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 EUs de facto moratorium on GE foods and crops exemplies these limits. Despite widespread citizen support for the trade barriers, European regulators were prevented from restricting GE products under the auspices that stricter oversight violate international law. With policy making environments as they are, the NGMOPs 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 limitations about GMOs. So you can target the government but it doesnt get very far.6 Later when asked who should take responsibility for the adventitious presence of GE material he noted: They [biotechnology rms and the federal government] should be responsible for that. But theyre not, and none of us are really going to be able to make them. We have a much better shot at inuencing natural food companies to do something about it than at inuencing 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. Neoliberal 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, individual choice and a consumers right to know product qualities are sacrosanct. Almost all the activists and consumers 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.

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).

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Personal interview, 17 August 2006. Personal interview, 17 August 2006.

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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 certication 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 certication is being attempted is incomplete without understanding the ways organizers personal contexts and desires shaped the groups evolution. In this section, I trace NGMOPs initial manifestations and explore the role of individuals in determining the groups strategy. Like many eco-certication programs, the Non-GMO Project grew from the modest efforts of a handful of concerned 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 NGCs 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 stores management agreed to a wholesale product review. The extensive project fell on the shoulders of three dedicated employees who diligently cataloged every product, from soymilk to skin cream to granola, for at-risk ingredients. Following the work of Tucson, Arizonas, The Food Conspiracy; and Brattleborough, Vermonts Food Coop, the group planned to contact manufacturers for information about their sourcing practices and, when possible, nd 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 campaign 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
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Torontos Big Carrot Natural Food Market took the lead in mobilizing that countrys retailers. Internationalization has been extremely important. The Big Carrot, having already successfully run a non-GMO campaign in 2001, brought its expertise and signicantly increased the number of participating stores. The ability to draw on discourses of crossborder solidarity also strengthened the campaigns position as the voice of the average North American consumer. The groups 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 groups 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 grocery 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 atly, Who [better] can we go to as, as employees of a natural grocery store to, to nd out about this than the companies? Later he explained that founding members: [were] in a unique position to inuence companies because, you know, companies have a bottom line and thats sales to the stores that carry their products.And retailers are dependent upon their customers loyalty and their customers faith in what therere selling them.And everyone assumes, coming into a natural grocery store, that everything theyre getting there [is natural]. What this project is doing really calling both the stores and the companies to, to take responsibility 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 rm 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 rms competing ercely 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 distinguish themselves from conventional companies based on their ability to provide high quality, nutritious and
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While People Want to Know ofcially called participating retailers signators no one ever actually signed anything. Rather, stores just agreed to have their names added to a list of supporting rms.

Personal interview, 17 August 2006.

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environmentally-friendly goods. Non-GMO Project activists capitalized on this vulnerability by offering retailers a new way to attract consumers and publicly reafrm 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 certication. Moreover, 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.

youre saying you do something about it but youre 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 worlds leading Non-GMO certication rm. GID suggested the campaign shift from enrolling retailers to developing a standardized verication process for non-GMO products. To this end, GID offered its technical assistance and access to its existing infrastructure 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), GIDs parent rm, maintained control of verication and certication. With GIDs 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 nal Working Standard was amended to accommodate manufacturer concerns and released with a new seal in February 2008 (Fig. 1). Initially, GIDs representatives appeared committed to limiting the food industrys involvement in setting the standard. They repeatedly agreed that NGMOP was not here for the manufacturers.11 However, shortly after Christmas 2006 the rm began stressing the need for industry buy in. John Fagan, GIDs founder and CEO, actively involved natural food manufacturers and sought their advice on how criteria should be developed. The NGMOPs purpose was reframed from living up to consumer expectations and protecting human and environmental health, to providing a competitive edge to companies in an increasingly crowded food market. Promotional material stressed the nancial benets of participation and the huge number of consumers waiting to purchase certied products. For example, by fall 2007 the NGMOPs website promised that the Non-GMO label would give companies a way to guarantee the GMO-free
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From People Want to Know to The Non-GMO Project When I met with NGMOPs 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 inuence. What started as a grassroots effort to capitalize on retail power transformed into a protable 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 certication: the rst 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 attracting widespread participation by manufacturers and retailers, in combination these events have signicantly altered the NGMOPs long term transformative potential. Despite the long list of endorsements from natural food retailers, manufacturer response to the groups initial letter was extremely uneven. Large manufacturers, those that arguably hold more inuence in the food system, paid little attention to the People Want to Know campaign. As one informant lamented during our rst meeting: Well, the bigger companiessaid they had [nonGMO practices] but they wouldnt detail it for us. They justthats what I mean, where they would say, We dont carry GMOs. Or they would just photocopy their website and send it to us. And its like, that doesnt tell us anything because its just youre,

Personal Interview, 17 August 2006. Personal correspondence, 31 May 2007.

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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 rms increased sales and premium prices: Because of the dangers, and because of the lack of sufcient 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 verication.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 manufacturers to participate because [c]ompanies know that consumers are concerned. They know that being GMOFree adds value to their products (Fagan, in Lewandowski 2004, p. 1). In our many conversations, my informants were adamant that the partnership with GID was not meant to change the groups focus so radically. While they agreed that a third-party certication would be benecial, they did not believe that it should rely on premiums to attract participants but rather that companies should certify their products because consumers and retailers demand nonGMO 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 industrys role and, despite Fagans attempt to ease their fears by arguing that manufactures shared the groups 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 manufacturers and accepted GIDs 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, UNFIs interest came as a surprise to activists, who were still skeptical of receiving support from industry leaders. Even more surprising was Whole Foods enthusiastic interest in the review process. When I rst met the NGMOP founder in August 2006 he expressed little hope for the retail giants participation because, as he put it, its such a highly charged political thing.14 Yet, when UNFIs 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 UNFIs sponsorship altered the NGMOPs trajectory again. As the Expo neared, staff and volunteers found themselves further removed from the planning process. Their original format was replaced with a new list of speakers and NGMOP representatives were allocated only 5 min to speak at the sessions end. The group was shocked to nd 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 certication process. While NGMOPs volunteers managed to pressure UNFI to x this minor oversight, the presentation remained dominated by industry representatives. On 9 March 2007 it was Michael Funk, UNFIs founder and CEO, who ofcially introduced, explained and promoted NGMOP. In his speech to the overow 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 discursively eliminated NGMOP founders again: The Non-GMO Project was originally a retailer initiative, but we asked that it be industry-wide, including farmers, processors, manufacturers, distributors 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-prot organization, created by leaders representing all sectors of the organic and natural products industry in the U.S. and Canada (NGMOP 2007).
14

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.

Personal interview, 28 October 2006.

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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 certication system.15 When the group refused to appoint representatives of major food rms 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. NGMOPs Board of Directors now reads like a Whos 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 (Natures Path) as well as John Fagan and Michael Funk. Consequently, the certication is being explicitly designed by and for major manufacturersa fact materially evidenced by the use of six major food rms Strauss Family Creamery, Eden Foods, Lundberg Family Farms, Natures Path, Whole Foods Market and United Natural Foodsto test and ne-tune the [initial] verication process (Fagan, in Roseboro 2007b, p. 3).16

Assessing the transition In light of scholars critiques of third-party certication 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 certication. Retail power is many times greater than the sum of consumer choices. As food manufacturers primary customer they are the doorkeepers to prots and thus can force widespread and rapid change. Third-party certications, on the other hand, rst require groups to stimulate sufcient consumer demand to attract initial participants. Retailers and the broader agrifood industry must then recognize that a protable market exists. However, their recognition is hampered by the inconsistency of individual sales and thus consumption must reach signicant levels before market signals are perceptible. In essence, certication 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 labels credibility, but there are important
15

reasons to be wary of the present situation. Rather than signaling a major step for the anti-biotechnology movement, it threatens the standards 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 certications. 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 NGMOPs 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 signicant move in this direction. In place of a single strict threshold, the Board established a series of action thresholds to provide realistic interim denitions of non-GMO (NGMOP 2007, p. 3). These small changes are signicant. NGMOP initially wanted to use retailer buying power to eliminate GE foods and crops. While eliminating GE products remains the projects outward goal, the reliance on industry and the move from a demand-push to premium-pull system magnied the already-limited transformative potential of certications as a class and introduced many of the tensions noted by agrifood scholars. The shifting threshold is particularly worrisome. It tacitly accepts trace contamination insofar as it sets requirements according to what is available. 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 geographic extent and harvest volume. Some observers already argue that the complete absence of GE material unrealistic (Roseboro 2006).18 As contamination increases, the NGMOPs threshold is poised to increase accordingly. In so doing, it minimizes pressure on manufacturers and growers to nd ways to completely eliminate GE

Personal Communication, Non GMO Project, 28 May 2007. 16 Soon after the board of directors was re-populated by industry representatives, the Projects 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 companys herbicide, Liberty Link. 18 This is the logic behind the high tolerance thresholds for mandatory labeling laws in Europe and elsewhere.

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materiala necessity if the NGMOP is to signicantly slow or prevent the spread of GE technology. The shifting threshold also opens a space for the material implications of Non-GMO to be distanced from the labels 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 signicant amount of contamination, creating a protable gap that allows major manufacturers to capitalize on consumer concerns without signicantly altering their practices. This gap undermines anti-biotechnology activism in three related ways. First, it obscures genetic contaminationa 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 Ventria Life Sciences pharmaceutical rice and Monsantos Roundup Ready alfalfa. Unless the NGMOP highlights its inability to guarantee zero GE presencesomething it has no incentive to doa Non-GMO label gives the impression that contamination is currently preventable and thereby undermines this essential and inuential public concern. Second, a non-GMO label weakens demands for mandatory 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 discursively compelling fact around which to mobilize public opposition. Not only would a non-GMO label quell consumer concern, but it would do so without necessarily changing the content of the food supply. In essence, the gap between the labels meaning and its effects may prevent radical changes that could occur if individuals continued to be dissatised with offerings on their grocery shelves. Third, by allowing potentially large amounts of contamination, a shifting threshold undermines efforts to trace the health effects GE foods. With more than 70% of processed 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 introduced through GE. My purpose is not to say that non-GMO as a concept is meaningless. Non-GMO companies must avoid GE products at some level and through this search have spurred alternative supply networks. Endeavoring to reduce contamination, 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 international markets. Chinas policy of zero tolerance for the adventitious presence of GE traits is far more onerous than Japans 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 productiona problem scholars have repeatedly noted regarding industry-dominated certication (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 certication or is there another way out? The story of the Non-GMO Project underscores the difculties of using third-party certication as a tactic in agrifood activism. Despite committed efforts to the contrary, 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 project 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 NGMOPs potential as a mechanism to prevent the spread of GE products. Moreover, industry control supports the tendency for certications to re-legitimize dominant agrifood actors and reduce public debate insofar as it tempers criticism by satisfying consumers perception that they can eat non-GMO, and thus are participating in the effort to eliminate GE products. It would be easy to condemn NGMOPs emphasis on private regulation and call for a return to policy-focused activism. However, the groups story suggests why activists 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. Certication was not, however, chosen because

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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 certiers and food manufacturers. In essence, it emerged not from activists, but from institutions that were poised to gain nancially from its implementation. If certication is not the necessary outcome of a neoliberal context, what alternatives exist? A cursory review of the anti-biotechnology movements past successes suggests that there are many. In particular, directly targeting retailers and food manufacturers by highlighting procurement policies or threatening to do so has forced leading rms to publicly reject GE ingredients. McDonalds refusal to accept Monsantos GE potatoes single-handedly ended the crops development. More recently, Anheuser Buschs 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 supermarkets, it is arguable that they offer the best point of intervention. However, it is also important to note, that NGMOP organizers were open to GIDs suggestion in large measure because their initial effort did not promise to be lucrative enough to attract major retailers. This problem did not necessitate certication; rather it was a matter of mobilizing sufcient and visible criticism to force movementas Michael Pollans 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 solution 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 targeting investor condence by using socially responsible investment funds to redirected capital or investor groups to introduce proxy resolutions to corporate boards of directors. 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 modied 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 ingredients (ICCR 2007). It has also used its network of religious groups to foster crucial boycotts of food manufacturers, such as Nestle, to change socially and environmentally practices (Ermann and Clements II 1984). Broadening denitions 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 condence. As privatization and competition run apace in education and healthcare the importance of reputation rises concomitantly. 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 radically 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 certication is equally defeatist. The market offers manifold points of interventionmore than I suggest hereand 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 decisions that intersected in this particular instance, this paper grounds the politics of food in the lives of real people, occurring in real time. Accordingly, certication was not a strategy decided upon a priori, but the outcome of muddling through a series of political economic contingencies. Thus, critical gaze might be best focused on the specic situations that re-direct potentially benecial 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 condential informants for their time and insights during my eld 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 University 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 inuence of the American anti-biotechnology movement and was funded by the Social Science and Humanities Research Council of Canada.

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