FAQ on VLOG certification

Below you will find the most frequently asked questions and answers about the VLOG standard and the certification process.

Based on the VLOG standard, the FAQs are divided according to level. You will find an overview with navigation options in the right-hand column or below. The questions and answers are continuously updated and supplemented. The latest questions and updates can also be found on the right or below.

A - General

The “Ohne Gentechnik” Production and Certification Standard (the VLOG Standard for short) is divided into the following parts: General (A), Certification (Z), Logistics (B), Feed Manufacturing (C), Matrix Organisation (D), Agriculture (E), Agricultural Group Organisation (F), Food Manufacturing (G) and Retail (H). The first chapter of Parts B, C, E and G defines which activities are subject to certification and which are not.

 

You can find a document with all standards regarded as equivalent to the VLOG standard here.

 

The costs for VLOG certification depend on the certification body engaged by the business. VLOG does not charge for certification.

 

In principle, businesses in the EU may be certified according to the VLOG Standard because the reliability of feed labelling is ensured by EU Regulations (EC) nos. 1829/2003 and 1830/2003.

However, in the case of certification outside Germany, it is important to note that the audit documents must be submitted to VLOG in German and/or in English. The documents for agricultural operations which are members of a group certification may be submitted in the respective national language. Upon request from VLOG, the documents must be translated by the certification body and submitted to VLOG within five working days.

In the processing sector in particular (here: oil mills/refineries), is the issue is also contamination that can come from other species. Rapeseed/canola oil that was (partially) produced from genetically modified rapeseed/canola or is contaminated by genetically modified rapeseed/canola, for example, is a critical raw material that could cause contamination of “Ohne Gentechnik” sunflower oil.

Due to the risk of contamination, VLOG does not consider the advertising of such food (e.g., sunflower oil) with the “Ohne GenTechnik” to be “vacuous advertising”.

No. The “Ohne Gentechnik” label always has to refer to the entire product.

 

Certification according to the VLOG Standard is based on the German EC Genetic Engineering Implementation Act, EGGenTDurchfG, which in turn is based on European Regulations (EC) nos. 1829/2003 and 1830/2003. Therefore, certification outside the EU, where these Regulations do not apply, is generally not permissible.

In certain cases, after consultation with VLOG and in compliance with additional requirements, it may be possible to certify businesses in countries outside the European Union.

No special VLOG audit is necessary in this case if the following conditions are met:

•    An organic audit has already been carried out within the minimum feeding conversion period.
•    The organic certification body has confirmed the starting date of the conversion period in writing.

Z - Certification

In general, whether a valid Standard Usage Agreement has been concluded with VLOG must be checked during the audit. If this is not the case, this must be remedied by concluding an agreement and submitting it to the certification body. The VLOG certificate may not be issued until then.

If an auditing contract is terminated as of the end of the certificate validity period, the competent certification body will decide whether an audit should be conducted in the last year of validity – based, at least, on the business’ risk grade and any deviations found in previous audits. In so doing, the certification body will also decide

•    whether there must be a complete routine audit or whether only compliance with certain requirements must be audited and
•    whether the audit of the requirements must be performed on-site or an audit of all relevant documents/records will suffice.

If a VLOG audit is not conducted in the last year of certificate validity, the certification body must provide a documented reason.

If the auditing contract is terminated with an effective date prior to the end of the certificate validity period, the competent certification body must withdraw the VLOG certificate as of that date (cf. chapter Z 4.5).

No, such a test is not mandatory. However, many auditors carry out such a test because this is a way of checking the requirements for product tracking in the business. If a traceability test or complete quantitative balancing is too time-consuming, the auditor may also alternatively decide to conduct a spot-check test.

 

It must be assessed whether the problem is site-specific or systemic. In case of a systemic problem (for example in risk management), the KO can influence the certification of other sites and lead to a KO for the whole company.

 

“Ohne Gentechnik” and/or “VLOG geprüft” production may start once VLOG receives confirmation by email from the certifier indicating that, based on the audit result, a certificate can be issued.

 

Both methods are possible. Either, one certificate can be issued for the whole company (containing the VLOG ID of the company and listing all sites with their sub-IDs), or each site can receive its own certificate (containing the VLOG ID and its individual sub-ID).

 

The VLOG certificate may only provide information regarding the scope of application (cf. Annex 11). However, reference may be made to an annex containing product-specific information.

 

The audit may also be carried out during the mandatory minimum feeding conversion period.

 

Product groups as well as individual products (such as production on selected production lines) may be certified. The scopes of application defined in the VLOG Standard (cf. Annex 12) must be taken into consideration in this case and listed on the certificate or in its annex.

 

Adjustment of the audit interval:

Upon the business’ request, the certification body can appropriately extend the validity period of the existing VLOG certificate even after the issue of the certificate.

Suspension/revocation of QS certification:

Case 1 - QS VLOG “Ohne Gentechnik/ VLOG geprüft“ add-on module:

With cancellation of the QS certificate, the concerned business’ VLOG certificate and/or the QS VLOG “Ohne Gentechnik/ VLOG geprüft” add-on module will  also be cancelled . Products may be marketed as “Ohne Gentechnik” and/or “VLOG geprüft” only when a QS certification with the VLOG add-on module and a new VLOG certificate have again been issued,

Case 2 - Own VLOG certification:

If the business’ QS certificate is cancelled, VLOG certification may be maintained if all conditions are fulfilled. If the validity period of the VLOG certificate was extended through QS certification, a new VLOG certificate with shortened validity period must be issued, unless the QS certificate is re-issued within one month. With a new issue of the VLOG certificate, the validity period is adjusted in accordance with the VLOG Standard.

If, when a new certificate is issued, it is noticed that the validity period has already been exceeded, a VLOG audit is to be undertaken immediately in order to maintain certification.

There is no time limit in the VLOG Standard and it is not determined in which order businesses have to be audited.

 

B - Logistics

This is explained below, based on the example of rapeseed/canola meal:

An agricultural business orders VLOG-certified rapeseed/canola meal from a trader. If the trader obtains the rapeseed/canola meal from a non-VLOG-certified oil mill and converts it as a drop shipper into “VLOG geprüft” quality, the rapeseed/canola meal is transported directly from the oil mill to the agricultural business. The drop shipper does not have any direct contact with the rapeseed/canola meal nor does he make any entry on the delivery slip, so that the rapeseed/canola meal arrives without being identified as “VLOG geprüft” on the delivery slip. It is thus not possible for the agricultural business to perform the incoming goods inspection by checking the delivery slip for the “VLOG geprüft” designation according to the VLOG Standard.

In this case, the following exception applies:

According to Section B 6.1 of the VLOG Standard, the converting drop shipper is in possession of written confirmation from the supplier attesting no later than at the conclusion of the purchase agreement that the goods, as they are free from GMOs, are not subject to compulsory labelling. The procedure, as outlined below, differs depending on whether the confirmation is for specific batches or for a certain time period:

1.    Batch-specific confirmation

The supplier confirmation is to be supplemented in writing (no form available) by the drop shipper by the following points and must be forwarded to the agricultural business immediately:

•    “VLOG geprüft” label
•    Company name, address and telephone number/email of the drop shipper or contact person
•    Company name and address of the customer or agricultural business

2.    Confirmation for a certain time period

The drop shipper must forward the supplier confirmation to the customer/agricultural business no later than at the time of first delivery.

For every delivery of feed converted into “VLOG geprüft” quality, the drop shipper must immediately send the following information in writing (no form available) to the customer:

•    Designation of the purchased feed(s)/trading name(s)
•    Delivered quantity and date
•    Unambiguous labelling with batch or lot number
•    “VLOG geprüft” label
•    Company name and address of the supplier
•    Company name, address and telephone number/email of drop shipper, or contact person
•    Company name and address of the customer/agricultural business

Preferably, the confirmation and information are sent to the customer via email or fax, since the customer must have them by the time of delivery for incoming goods inspection.

Incoming goods inspection of the delivered batch(es) is performed by the agricultural business based on the specified documents. This process is to be demonstrated to the certification body during an audit.

If the contract of sale and the execution (incl. issuing of delivery slip and checking of the certificate) occur directly between the certified company and its customer and only the issuing of invoices is outsourced to this third party, this party does not have to be VLOG-certified.

 

Example 1: A non-VLOG-certified dairy (drop shipper) sells milk from VLOG-certified farmers (whether individually certified or certified via a group organiser (e.g. a producer group)) to a VLOG-certified dairy.

->    The selling dairy is not subject to certification obligation for drop shipping if all requirements for drop shipping with purchase from farmers in chapter B 1 of the VLOG Standard have been met. However, if one or more requirements are not met, the selling dairy is subject to certification obligation.

Example 2: A dairy trader sells the milk of one VLOG-certified dairy to another. The dairy trader does not take physical possession of the goods and has one of the two dairies transport the milk.

->    The dairy trader is not subject to certification obligation if all the requirements of B 1 regarding the exception provision are met. However, if one or more requirements are not met, the dairy trader is subject to certification obligation.

Example 3: A non-VLOG-certified producer group (drop shipper) sells VLOG milk from individually certified VLOG farmers to a dairy. The dairy transports the milk.

->    The producer group is not subject to certification obligation for drop shipping if all the requirements for drop shipping with collection from farmers in B 1 are met. However, if one or more requirements are not met, the producer group is subject to a certification obligation.

No, an additional VLOG certification is not required for these transport business. The certification according to GMP+ B4/TS 1.9 and QS, together with other transport certifications, are recognised as equivalent by VLOG. Thus bulk VLOG-certified feed or food may also be transported.  A respective overview can be found in the VLOG document "Standards recognised as equivalent by VLOG".

Note: This recognition is limited to the logistics sub-stage Transport and does not apply to Trade, Drop shipping, Storage and Handling (cf. VLOG Standard chapter B1).

C - Feed Manufacturing

Feed businesses are obligated according to the VLOG Standard to carry out an individual risk assessment of the raw materials/single component feed used (risk-prone/not at risk) for purposes of “VLOG geprüft” production or labelling.

The assessment is to be based on the following three points:

•    Checking of documentation status
•    Assessing the origin of the feed
•    Considering the packaging, transportation, storage and processing

Additional information may be found here: Assessment aid – Risk-Prone Feed

VLOG-certified products must be labelled as "VLOG" or "VLOG verified" on the bills of lading. In the case of packaged products, the claim can be made on the packaging (e.g. product label) instead.

Invoices and product specifications do not belong to the bills of lading, so that labelling with "VLOG"/"VLOG geprüft" is optional.

 

It is recommended that the following measures be taken:

•    Secure proof of the origin of the products and that they are not subject to compulsory labelling under Regulations (EC) 1829/2003 and 1830/2003 by obtaining a written confirmation from the supplier, particularly if the goods do not originate in the EU
•    Request the test results for testable source products from the producer
•    Inform the supplier of the obligation to label products containing GMOs in the EU and emphasise the importance of proper labelling to “VLOG geprüft” production

The VLOG Assessment Aid for Suitability of Testing for GMO provides an overview of feed, raw materials and products that can be tested for GMO or not. The responsible analysis laboratory must also be consulted about the analysability of feed and raw materials.

 

Grinding and Mixing Facilities

No, there is no certification obligation unless the operator wants to label mixed feed as “VLOG mixture”. However, certification influences the farmers’ grading into the risk categories from 0 to 2.

 

No, feed mixing vehicles that are used, for example, for daily feeding of silage and concentrated feed are not mobile grinding and/or mixing facilities in terms of the VLOG Standard. They are used only for dry feed components such as grains.

 

If the same mixtures are regularly produced in a farm’s mixing facility, it is sufficient to have a (digital) recorded mixing instruction, provided it is possible to prove that each single mixture can be clearly associated with the instruction. In case the single mixture differs from the instruction, this change has to be documented on the mixing protocol/delivery slip (e.g. “today 300 kg instead of 400 kg wheat have been used”).

 

As there is no template for this consent, it may be created as needed. The consent must clearly explain which parties it concerns.

The permission must be submitted to the facility operator.

The following wording can be used: “I/We, [name and address of the farm] allow the company, [name, address of the grinding and mixing facility], to take samples from “VLOG mixtures”, which have been ground and mixed by the company. These samples may be tested for GMOs in a laboratory.”

Refined oil can’t be tested for GMO. Therefore, the farmer or operator of grinding and/or mixing facilities does not need to take (retention) samples.

 

No. Provided that both measures to prevent contamination are carried out in these cases, there is no need to carry out both the entry into VLOG production and the regular carry-over tests.

 

E - Agriculture

The food must not be subject to compulsory labelling under EU Regulations nos. 1829/2003 and 1830/2003. Therefore, at incoming goods inspaction, the farmer must check for the absence of a label.

 

Feed must not be subject to compulsory labelling according to Regulations (EC) No. 1829/2003 and/or No. 1830/2003. All VLOG-certified feeds, or feeds with certification recognised as equivalent to VLOG, must meet this criterion and may be used for the production of “Ohne Gentechnik” food.

 

For feed, the labelling obligation pursuant to EU Regulations No. 1829/2003 resp. 1830/2003 is relevant. Products from animals that have been fed with GMO feed or the respective processed products are not subject to compulsory labelling pursuant to the regulations mentioned. Such products of animal origin may therefore be used as feed or in the production of VLOG-certified feed. They include, for example, skim milk powder, milk powder but also processed animal proteins (e.g. animal meal).

 

It is permissible to perform a document check on such alpine farms, instead of an on-site audit, for the purpose of auditing/certifying activities subject to certification under the VLOG Standard, regardless of the size of the farm.

The audit must be based on a written agreement between the client (agricultural business) and the contractor (alpine farm), containing at least the following items:

•    Details regarding the commissioned activities and their scope,
•    Obligation on the part of the alpine farm to comply with the VLOG Standard in its current version, and
•    Confirmation of such compliance upon return of the animals to the farm/owner under Annex (2) to the VLOG Standard: “Certificate of ‘Ohne Gentechnik’-compliant feeding of animals”

Note: Currently no VLOG certification or document check is necessary for the outsourcing of young cattle and animals during their first lactation. Proof in accordance with Annex (2): “Certificate of ‘Ohne Gentechnik’-compliant feeding of animals” is sufficient in this case to confirm the “Ohne Gentechnik”-compliant feeding of animals. This also applies if the period of outsourcing is to be credited toward compliance with the minimum feeding conversion period.

This depends on the certification of the feed that the farmer orders to be mixed/ground in the facility. If only feed that is certified organic is processed in the grinding and/or mixing facility, no additional VLOG-certification of the facility is necessary to be graded into risk category 0. If the feed is not certified organic, VLOG certification of the facility is necessary to let the farmer reach risk category 0. Otherwise, the farmer is graded into risk category 1.

(Requirement: No other criteria warrant classification in a higher risk category.)

The starting point is the age of the animal at the beginning of the conversion period.

Example: The cow is already 2.5 years (30 months) old at the time of conversion to “ohne Gentechnik” conform feeding. The meat/animal can be marketed labelled as “Ohne Gentechnik” from the age of 10 years.

 

No. The labelling exemption pursuant to EU Regulations 1829/2003 and 1830/2003 is sufficient for feed that is not potentially risk-prone.

Please note the additional classification criteria in chapter E 2.

 

The document on which the feed is declared is relevant. Often, that is the delivery slip. However, if the ingredients are NOT listed on the delivery slip and there is no separate declaration, the farmer must save BOTH the labelled feed sack and the delivery slip.

 

It is not required for the supplier and the client to take a sample of the feed together. It is therefore possible for the shipper to retain the reference sample. However, in this case, the farmer assumes the responsibility for the way of proceeding and has to decide whether he wants to relinquish the security of his own or joint sampling.

 

The test results provided by a business that is VLOG-certified or certified under a standard recognised as equivalent to VLOG can be credited by the business being supplied provided that the batch is verifiably the batch that was delivered and that the sample was tested in compliance with the VLOG Standard.

 

Upon request by the business, the validity period can be extended even after the issue of the certificate by the certification body if the relevant requirements are fulfilled. Information on the audit interval for the animal transport and livestock trade sub-stage can be found in chapter Z 3.4.

 

The VLOG Assessment Aid for Suitability of Testing for GMO provides an overview of feed, raw materials and products that can be tested for GMO or not. The responsible analysis laboratory must also be consulted about the analysability of feed and raw materials.

 

F - Group Organisation Agriculture

No, a certification body must not be the group organiser of a group that it audits. This would compromise the independence of the auditing process.

 

Yes, a business with individual certification can be admitted to a group organisation in compliance with the following points:

•     Certification must be transferred to the new certification body if necessary: The certification bodies must exchange the relevant audit documents/data (see VLOG Standard Part Z). The contract with the former certification body must be cancelled.
•    The group organiser and any new certification body will admit the business to the group (contract between the group organiser and the facility, review of the documents and the risk category, incorporation into risk management, inclusion in the members’ list, etc.)
•    The business must terminate its Standard Usage Agreement with VLOG (notice to info@ohnegentechnik.org indicating that the business will be a member of Group XY in the future)

After successful transfer of all data, the certification body will decide whether to recognise the last audit of the business for the group certification audit.

G - Food Manufacturing/Preparation

As of January 1st 2019, only Annex 1 (GVO-free certificate) is admissible for VLOG certification.

 

The use of Annex 1 is obligatory; since January 1st 2019, informal declarations are no longer accepted. If the certificate is not filled out by the supplier, it may be filled out by the business itself. This can only be done based on GMO test results, a risk assessment or similar.

 

For dyed eggs, the EGGenTDurchfG not only contains requirements for the eggs, but also for the dye.

For the dye, at least one GVO-free certificate (Annex 1 of the VLOG Standards) must be submitted by the dye supplier, confirming that the criteria of the EGGenTDurchfG were complied with. If these provisions are fulfilled, VLOG holds that the dye factory does not have to be certified.

 

Provided that no parts of the water used for scalding the non-conform meat (e.g., fat) enter the “VLOG” meat and no parts of the saline bath of the non-conform cheese enter the “VLOG” cheese, the scalding water and the saline bath may be used for both qualities.

 

No, under these circumstances, the manufacturer cannot be certified. All raw materials must comply with VLOG requirements.

 

 Legislators have taken measures to significantly reduce the liability risk in this case. It is not legally mandatory to recall goods already produced. The EU Genetic Engineering Implementation Act (EGGenTDurchfG), which provides the legal basis for “Ohne Gentechnik” labelling, states as follows in Sec. 3a, (4):

“In case of food or food ingredients of animal origin, the animal which is processed into food must not have been given feed which is marked pursuant to Articles 24 and 25 of the EU Directive 1829/2003 or Articles 4 or 5 of the EU Directive 1830/2003...”

Quite deliberately, the wording refers to the actual state of the declaration of feed at the moment of feeding the animals and not how the feed should have been labelled. Even if it turns out later that the feed should have been declared, the milk, the eggs and the meat are considered produced in conformity with the EGGenTDurchfG and may be marketed with the “Ohne Gentechnik” label.

Of course, incorrectly declared feed still available must not be used further for “Ohne Gentechnik” production.

 

The business has to spread the 12 analyses among all at-risk raw material that can be tested for GMO. If only the paprika extract is concerned, that has to be analysed.

The number of samples can only be reduced if the number of batches received in the audit period is smaller than the minimum number of samples of 12 (e.g. 5 batches = 5 analyses). Sampling and GMO-testing can also be reduced if the raw material and products are not at risk. In this case, a corresponding risk analysis must be available.

If the products are clearly labelled as “Ohne Gentechnik”, a label on the outer packaging is not compulsory.

The identifiability/separation may also be ensured by the following measures, for example:

•    Unique product number which is attributed to “Ohne Gentechnik” quality in the EDP system
•    Pallet identification as “Ohne GenTechnik”
•    Defined pallet colour as “Ohne Gentechnik”/”VLOG”.

The absence of GMOs from “Ohne Gentechnik” food also extends to bacteria and yeasts that produce additives such as enzymes, aromas and vitamins. E.g., the rennet enzyme for the production of cheese may not stem from genetically modified bacteria.

 

Natural rennet can be used for the production of “Ohne Gentechnik” food if the animals from which the rennet stems were not genetically modified. It is irrelevant what the animals were fed.

(More specifically: The requirements for feeding animals only applies to ingredients (Sec. 3 a Par. 4 EGGenTDurchfG). According to food law, rennet is not an ingredient because it is used as a processing aid. However, the prohibition of the use of substances created using GMOs applies (Sec. 3 a Par. 5 EGGenTDurchfG). A substance is produced using GMOs if the last living organism in the manufacturing process – In the case of natural rennet it is the calf – was genetically modified.

However, production “by GMOs” is relevant with respect to microbial rennet (i.e. rennet produced by bacteria). In this case, a GMO-free certificate (Annex 1) is necessary for use in “Ohne Gentechnik” products.

The following measures must be taken by affected businesses operating in the “Ohne Gentechnik” sector:

•    Obtain proof of the origin of the products and ensure that they are not subject to compulsory labelling under Regulations (EC) 1829/2003 and 1830/2003 by obtaining a written confirmation from the supplier, particularly if the goods do not originate in the EU (different labelling provisions)
•    Request test results for testable source products from the producer with a maximum threshold value of 0.1 % GMOs approved in the EU
•    Inform the supplier of the obligation to label products containing GMOs in the EU and emphasise the importance of proper labelling for “Ohne Gentechnik” production

According to the EGGenTDurchfG, the definition of the extent of review back to the last organism capable of reproduction (pursuant to Regulation (EU) 2018/848), refers only to production “by GMOs” and not “from GMOs”.

In practice, that would mean, for example:

1.    Example: Dextrose that is prepared microbially may not be produced using GM microorganisms. The nutrient solution in which the microorganisms were grown, however, is no longer taken into account when considering the question of being GMO-free.
2.    Example: Maltodextrin is produced using enzymes that were synthesised using GM microorganisms. Maltodextrin, which is used as a carrier for aromas, for example, was thus produced “by GMOs” and is thus not conform with the EGGenTDurchfG or the VLOG Standard.
3.    Example: Ethanol, which is used as the carrier of an aroma and is produced from GM corn, for example, would be compliant with the regulations of the EGGenTDurchfG. According to the VLOG Standard, the source material (here corn) must however not have been subject to compulsory labelling pursuant to Regulations (EC) 1829/2003 and 1830/2003.

The criteria in the Codex Guidelines and those in the EGGenTDurchfG are not identical. The EGGenTDurchfG excludes carryovers with GMOs that are above the limit of detection of 0.1% per component. The Codex Guidelines do not regulate this in detail.

Food of plant origin produced in Germany according to the VLOG Standard for sale using the Austrian “Ohne Gentechnik hergestellt” seal can be recognised if there is a warranty declaration, such as the InfoXgen form or a certificate according to the VLOG Standard, for food or food ingredients that require no certification under the Codex Guidelines.

The same applies to the recognition of food ingredients of plant origin which were produced in Germany according to the VLOG Standard for use in “Ohne Gentechnik produced” food as long as the same proofs are available for these food ingredients.

Food of plant origin produced in Austria under the Codex Guidelines for sale using the German “Ohne GenTechnik” seal or food ingredients of plant origin produced in Austria under the Codex Guidelines for use in “Ohne GenTechnik” food can be recognised if there is a GMO-free certificate according to Annex 1 of the VLOG Standard in its currently valid version for food or food ingredients that do not require certification according to the VLOG Standard. In this case, an InfoXgen certificate is not sufficient. As an alternative to the GMO-free certificate, verified proof from a certification body recognised by ARGE Gentechnik-frei can be submitted, which confirms that the requirements of the EGGenTDurchfG were met in the production of the product.

Pursuant to the VLOG Standard, there is no certification duty for producers of inorganic products (e.g. sodium chloride).

Businesses that wish to use ingredients not of animal origin (including mineral raw materials) in “Ohne Gentechnik” food need a GMO-free certificate (Annex 1) for the relevant raw materials.

The VLOG Assessment Aid for Suitability of Testing for GMO provides an overview of feed, raw materials and products that can be tested for GMO. The responsible analysis laboratory is also to be consulted about the analysability of feed and raw materials.

 

H - Retail Stage – Sale of Bulk Food of Animal Origin

If the goods management system ensures that branches can only order bulk goods of “Ohne Gentechnik” quality from VLOG-approved suppliers, it is sufficient for the supplier list to be available only at headquarters.

Otherwise, the supplier list must be available in every branch.

 

If VLOG-certified cheese is cut, prepacked and labelled with the “Ohne GenTechnik” seal at food retailers, this is permissible using one of the two following options, while complying with the stated requirements:

Use of the “Ohne GenTechnik” seal on decorative labels

The “Ohne GenTechnik” seal is presented on decorative labels, which are supplied to the stores by the VLOG-certified cheese manufacturer.

Requirements to be fulfilled by the manufacturer:

• These decorative labels are the responsibility of the cheese manufacturer and also specify the cheese brand/cheese manufacturer aside from the “OhneGenTechnik” seal, thus clearly attributing each label to the prepacked cheese and the information on the scale label.
• The manufacturer specifies the VLOG quality of the cheese in the (digital) specification for the cheese.
• The manufacturer informs VLOG of the first time the “Ohne GenTechnik” seal is used on decorative labels for cheese.

Recommendations for the manufacturer:

• VLOG recommends that the manufacturer label the VLOG-certified cheese itself or the outer packaging as “VLOG” or “Ohne Gentechnik” (e.g. envelope film, cheese sticker, film label, label on cardboard).
• To prevent improper labelling, VLOG recommends that the manufacturer inform the workers at the food retailer of the correct use of the decorative labels and their attribution to the various types and varieties of cheese.

Use of the “Ohne GenTechnik” seal on scale labels

The “Ohne GenTechnik” seal is presented on labels for which the food retailer is responsible (e.g. scale label).

Requirements to be fulfilled by the food retailer:

• The food retailer, or respectively, the relevant stores, are certified according to the VLOG Standard Stage G Food Processing and Stage H – Retail.