FAQ about the VLOG and its seals
Frequently asked questions about the VLOG, VLOG certification and the use of the “Ohne GenTechnik” and “VLOG geprüft” seal. The FAQs are divided into 19 chapters. An overview with navigation options can be found in the right column or below. The questions and answers are continuously updated and supplemented. The most recent questions and updates can also be found on the right or below. The date of the last update is indicated for each question.
Apart from the general requirements, the “Ohne Gentechnik” Production and Certification Standard is divided into the stages of Logistics, Feed, Matrix Organisation, Agriculture, Group Organisation Agriculture, Food Processing and Retail of bulk food. The first chapter of each stage (e.g. B1, C1 or E1) points out which activities require certification as well as those that don't require certification.
You can find a document with all standards recognized as equivalent to the VLOG standard here.
28 April 2021
Product groups as well as individual products (such as production on selected production lines) may be certified. The scopes for certification defined in the VLOG Standard have to be regarded and listed on the certificates. It is possible to specify the scopes for products or product groups further on the certificate or in an annex.
The costs for VLOG certification a charged by the VLOG-recognised certification body that is assigned to the certification of the business.In case the company wants to use the seal "Ohne GenTechnik" (food) or "VLOG geprüft" (feed), VLOG charges a licensing fee for the use of the seal. For food the fee depends on the turnover earned with the licensed products. For feed the fee depends on the total turnover of the company.
The delivery bill and, in the case of packaged products, the label on the product are defined as accompanying documents. On these the reference "VLOG" (food) / "VLOG geprüft" (feed) must be noted for VLOG certified products. Invoices and product specifications do not belong to the bills of lading, therefore a marking with "VLOG"/"VLOG geprüft" is here only optional.
In principle, businesses in the EU may be audited and certified according to the VLOG Standard because the labelling reliability of the feed labelling is ensured by the EU Directives No. 1829/2003 and 1830/2003.
However, in case of activities outside Germany, it is important to note that the audit documents are submitted to VLOG in German and/or in English. It has been agreed upon with the certification bodies that the documents for agricultural which are part of a group certification holdings may be presented in the national language but that upon request of VLOG the documents are tobe translated by the certification body and submitted to VLOG within five working days.
VLOG accepts the certification conditions in Austria with respect to freedom from GMOs equivalent to the VLOG Standard. For this purpose, we have concluded an agreement with ARGE Gentechnikfrei. However, our hands are tied when the German legislator, in its requirements for “Ohne Gentechnik” labelling, goes beyond the requirements of the Codex. For example, this is the case when it comes to the tolerated carryover of genetically modified organisms in food additives. In the current queries, this aspect is probably of special significance for you. The Codex follows the EC Directives No. 1829/2003 and 1830/2003. Accidental or technically unavoidable carryover of up to 0.9 percent per ingredient is tolerated. In conformity with the EC Genetic Engineering Implementation Act (EGGenTDurchfG), only carryover up to the detection limit of 0.1 percent per ingredient is tolerated in Germany.
For feed, certification procedures have been mutually recognised between Austria and Germany.
Businesses in countries outside the European Union may be certified only after consultation with VLOG. Differences in legislation are one reason, among others. EU Directives No. 1829/2003 and 1830/2003 apply for labelling of GMO feed and food within the EU. If there are no such legal regulations outside the EU, for example, the requirements for the process of feed procurement have to be revised because no farmer can gather from the delivery slip whether the feed purchased is GMO-free or contains GMOs.
For food with the “Ohne GenTechnik” seal, the animals used for the production of the food must not have received any genetically modified feed. The minimum feeding times are listed in the Annex of the EGGenTDurchfG and in the VLOG Standard (chapter E).
In terms of chickens used for meat production, for example, “ohne Gentechnik” conform feeding is required for the complete lifetime because the animals are slaughtered no later than approx. thirty days after hatching.
With respect to GMO-free milk, however, the farmer must not use genetically modified feed for three months beforehand. After conversion he has to continue feeding “ohne Gentechnik”.
In the conversion of cattle, both provisions have to be taken into consideration, i.e. twelve months as well as three-quarters of the lifetime.The starting point is the age of the animal at thebeginning of the conversion time.
Example: The cow is already 2.5 years (30 months) old at the time of conversion to "ohne Gentechnik" conform feeding. As from an age of ten years, the meat/animal can be marketed labelled as “Ohne Gentechnik”.
The audit may also be carried out during the requested minimum feeding time.
Of course, it would be desirable that the animals receive as little as possible or even no genetically modified feed at all.By means of the periods set the legislator has taken the situation into account that “Ohne Gentechnik” productionhas to gather momentum first. In this respect, the legislator has accommodated the farmers who want to convert to GMO-free production. The hurdles should not be too high; otherwise there is a risk that many food producers will not even make a start on “Ohne Gentechnik” production. Neither the environment nor the consumers would benefit in this case.
No, under these circumstances the manufacturer may not be certified. The requirements of the EC Genetic Engineering Implementation Act (EGGenTDurchfG) must be met for all raw materials used in “Ohne Gentechnik” products. Thus, in case of milk as a raw material it has to be ensured that the minimum feeding time required by law is observed by the agricultural operations.
The requirements of the EC Regulation on Organic Production and Labelling and the EGGenTDurchfG on the feeding of animals are identical withrespect to the GMO-free status of the feed. For this reason, the conversion times required to convert to organic production may be taken into account in keeping with the EGGenTDurchfG. No double audit in conformity with the VLOG Standard and the EC Regulation on Organic Production and Labelling is required.
Exeption for Beef:
For cattle, however, it has to be looked into which conversion variant the organic farm has chosen. The EGGenTDurchfGdoes not contain any regulation for 24-month conversion of an entire farm. The minimum feeding time of twelve months and at least three-quarters of the lifetime always applies for cattle used for meat production. This means that not necessarily every converted organic cow may be automatically marketed as “ohne Gentechnik”.
So, for beef, the following documents have to be on file in the incoming goods department of the marketing company:
• Written confirmation from the certification body of the business stating the date as of which the business has fed organic and GMO-free feed exclusively in their cattle segment.
• If already on file: Certificate attesting the organic production of the farm
• Confirmation on the delivery slip of the supplying farm that the minimum feeding time of twelve months and three-quarter of the lifetime has been observed in conformity with the EGGenTDurchfG.
Under the following conditions, no special VLOG audit is required in this case:
- An audit has already been carried outwithin the minimum feeding time in conformity with the EGGenTDurchfG.
- The certification body has confirmed the starting date of the conversion time.
No, the supplier (e.g. trader or feed manufacturer) doesn't have to be VLOG-certified. If the feed is not risk prone (see E 4.9.1) and not compulsory to labelling according to (EC) No. 1829/2003 and 1830/2003 no further proof is required.
The checklist can for example be used in the following cases:
- Manufacturers that also want to convert feed into “VLOG geprüft”/”VLOG verified” feed (manufacturing and logistics have to be checked here)
- For feed manufacturer, which do also trade with feed it can make sense because of different analyses and to maintain a better overview
- Traders, which also have mobile grinding and mixing facilities
- Manufacturers which also offer storage/transport as external service providers for other VLOG-companies segregated from the own production.
Manufacturers, which only want to have their own storage/transport checked in the audit, the use of the normal feed manufacturing checklist is sufficient.
No. Companies which do not store certified feed but onlytransport or tradeit,donot have to take samples or commission GMO analyses. Table 3 of chapter B 5.2.2 (VLOG Standard V 20.01) describes the range of analyses to be carried out for companies that store feed.
But please note: If feed materialis converted into "VLOG geprüft" feed, sampling and GMO analysis have to be done by the company in the incoming goods section. Further information on this can be found in Chapter B 7.2 in Table 5.
Not certified single component feed, which can be analysed on GMO, can be converted into “VLOG geprüft”/"VLOG verified" quality by a VLOG-certified trader. For doing this, the trader has to fulfil the requirements of chapter B 7 in Standard 20.01).
If the "VLOG geprüft"/"VLOG verified" seal is to be put on the goods, the business must also submit an application to VLOG for use of the seal.
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 or 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 on the delivery slip for the “VLOG geprüft” designation according to the VLOG Standard section E 4.5.
In this case, the following exception applies:
According to the VLOG Standard section B 7.1, the converting drop shipper is in possession of a written confirmation from the supplier attesting no later than at the conclusion of the purchase agreement that the goods, as being 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:
A) Batch-specific confirmation
The supplier confirmation is to be supplemented in writing by the drop shipper, without a form, by the following points and must be forwarded to the agricultural business immediately:
• “VLOG geprüft” label
• Company name, address and telephone number/email of drop shipper, or contact person
• Company name and address of the customer or agricultural business
B) 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 the first delivery.
For every delivery of feed conveyed in “VLOG geprüft” quality, the drop shipper must immediately send the following information in writing informally to the customer:
• Designation of the purchased feed(s)/trading name
• Delivered quantity and date
• Unambiguous labelling with batch or lot number
• Labelling “VLOG geprüft”
• Company name and address of the supplier
• Company name, address and telephone number/email of the drop shipper, contact person (if possible)
• 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 in the event of an audit.
28 September 2021
Yes, the trader that is in possession of the milk and transports it must also be certified according to the VLOG Standard given the risk of commingling. That is if the "VLOG"-status of the milk shall be maintained. An exception to the obligation is defined in chapter B1 of the VLOG Standard.
• 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 the requirements for drop shipping with purchase from farmers in B 1 are 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 of 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 respect to farmers in B 1 are met. However, if one or more requirements are not met, the producer group is subject to a certification obligation.
10 September 2021
The certification obligation applies only up to the business that does the packaging for the consumer. Thus, legally independent distributors are not subject to certification.
However, an application for use of the “Ohne GenTechnik” seal must be submitted to VLOG by the business.
If the contract of sale and the execution (incl. issuing of bills of lading and checking of the certificate) areorganised directly between company and customerand only the issuing of invoices is outsourced to the independent company, this company does not have to be VLOG-certified.
According to chapter B 1 of the VLOG Standard, the transportation business does not require a separate certification, provided that all of the following three requirements are fulfilled with sufficient proof:
- The order is given by a VLOG-certified dairy
- Transportation is part of the risk management of the VLOG-certified dairy
- There is an agreement between the transporter and the certified dairy operator for complying with the logistics requirements of the VLOG Standard.
To be eligible for a “VLOG geprüft” labelling or seal, the feed and the warehousing/handling business must undergo VLOG certification. Purchased feed/raw materials have to be certified according to the VLOG Standard or have to be converted into "VLOG geprüft"/"VLOG varified" by a certifiedtrader or commissioned by a certified trader. Converting is only possible for single component feed that can be analysed on GMO (see chapter B of the VLOG Standard).
If the warehousing/handling business is not the owner of the single component feed, conversion is only possible if it is carried out by the owner. The owner can assign certain tasks, e.g. sampling, to the warehousing/handling business.
If the "VLOG geprüft"/"VLOG verified"-seal is to be put on the feed, a license agreement with the VLOG must be available.
Feed used in the “ohne Gentechnik” system may not be obligatory to labelling according to the rules of Regulations (EC) No. 1829/2003 and/or No. 1830/2003. Therefore, it must neither be labelled nor be subject to labelling obligations if it were brought into the market. Feed that is certified against VLOG Standard may always be used for the production of “ohne Gentechnik” food.
It is urgently recommended that affected businesses operating in the “VLOG geprüft” sector take the following measures:
• 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 (different labelling provisions)
• Request the analysis results for testable source products from the producer
• Inform the supplier of the obligation to label products containing GMOs in the EU and emphacise the importance of proper labelling to “VLOG geprüft” production
 Suitability of Testing for GMOs in Raw Materials, Feed- and Food Ingredients
10 September 2021
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 processing products are not subject to compulsory labelling pursuant to the regulations mentioned. Products of animal origin may thus be used in the "Ohne Gentechnik" production and in the production of VLOG-certified feed. These include, for example, skim milk powder, milk powder but also processed animal proteins (animal meal) from poultry in pig feed or from pigs in poultry feed.
VLOG has recognised the following standards as equivalent to the VLOG “Ohne Gentechnik” Production and Certification Standard. Other standards may not be considered as equivalent without further consultation with the VLOG office. For this to happen, thorough benchmarking by the VLOG office is required. Please contact VLOG if necessary.
28 April 2021
Manufacturers and dealers must not fear any legally induced product recalls. The legislator has taken measures to clearly reduce the liability risk. Even if the analysis of the feed used by an agricultural holding reveals that contrary to the statement on the delivery slip or accompanying document the feed should have been labelled as being genetically modified,it is not mandatory to recall the goods already produced. The EGGenTDurchfG constitutes the legal framework for the “Ohne Gentechnik” labelling. In Section 3a, Paragraph 4, it says:
“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 of the animals and not how the feed should have been labelled. Even if it turns out later on 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. Depending on the amount of the feed and its GMO-content it can be necessary to start the conversion period anew. For further information please see the VLOG guideline for handling mislabeled feed.
The risk assessment (at-risk or not at-risk) has to be doneby the farmer according to chapter E 4.9.1 of the VLOG standard. Feed that does not contain soy, corn/maize, sugar beet, cotton or rapeseed/canola can always be graded as not at-risk.
Rapeseed/canola or its processed products* (feed material) are not graded as risk-prone if
- they are certified according to the VLOG Standard or a standard recognised by VLOG as equivalent (see the document “Standards recognised as equivalent”) or
- they originate directly from the producer and
o were cultivated in a country in which cultivation of genetically-modified varietals is prohibited (e.g. in Germany)
o no processing (e.g. milling) was done by third-party businesses
o no commercial carrier was used to transport them
Rapeseed/canola that is already VLOG-certified (“VLOG geprüft” label on the bills of lading) can also lose this certification status. In such a case, this rapeseed/canola must be graded as risk-prone. Examples of this are as follows, when the rapeseed/canola is:
- traded as bulk goods via a non-VLOG-certified (drop) shipper
- stored as bulk goods by a non-VLOG-certified business
- purchased from a VLOG-certified oil mill, however without clear labelling attesting to VLOG-certification, as indicated by the wording “VLOG geprüft” on the bills of lading
* E.g. post-extraction rapeseed/canola meal, rapeseed/canola press-cake, rapeseed/canola seed protein concentrate, rapeseed/canola oil
27 May 2021
The following criteria must be fulfilled:
a) The feed (in this case the bread) may only be used as animal feed in VLOG production if it is not subject to compulsory labelling in accordance with Regulations (EC) 1829/2003 and (EC) 1830/2003.
b) The farmer must have a confirmation from the supplier that the food (e.g. bread) is not subject to compulsory labelling pursuant to the above-mentioned regulations.
Dual use is to be understood as the use of the same mixer for VLOG feed/feed not subject to compulsory labelling (pursuant to Regulation EC 1829/2003 and 1830/2003) on the one hand and feed subject to GMO labelling on the other hand.
Alternating use of the feed mixer for GMO and non-GMO feed is possible only after thorough (wet) and documented cleaning after the GMO feed or a system purge with feed exempt from mandatory labelling.
If a business decides to use system purges, it is responsible for ensuring that the system purge is sufficient in terms of quantity and technical characteristics. The system purge is regarded as efficient if it prevents commingling/carryover, such that the labelling obligation according to EU Regulations 1829/2003 und 1830/2003 does not apply. If doubts arise, auditors may verify the functionality of the system purges (or have it verified) by analysis.
Facilities that rely on dual use of feed mixer trucks are to be classified in Risk Class 2.
For “VLOG geprüft” production or labelling, feed businesses are obligated according to the “Ohne Gentechnik” Production and Certification Standard to carry out an individual risk assessment (risk-prone/not at risk) of the feed material used. In doing so, the following document may be used as an assessment aid. Feed that does not contain soy, corn/maize, sugar beet, cotton or rapeseed/canola can generally be graded as not at-risk.
The "VLOG geprüft" seal (and also "Ohne GenTechnik" seal) may be used on delivery slips or other internal/external documents if the business has concluded a Licence Agreement with VLOG.
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, then the farmer must save both the labelled feed bag AND the delivery slip.
Apart from the labelling in the article description, it is also possible to use a footnote, asterisk (*) or similar which is explained on the slip. If a delivery only contains VLOG certified feed, it is also possible to add a sentence that makes clear thatall feed on the delivery slip is “VLOG geprüft”/”VLOG verified”.
Vitamins and additives produced with the help of genetic engineering, such as amino acids, may be used in animal feed. This corresponds to the EU labelling regulations for genetically modified feed: Only feed that contains or is produced from genetically modified plants must be labelled as “genetically modified”.
Vitamins and amino acids are added to the feed of livestock to keep the livestock healthy and productive. Genetically produced vitamins and additives are not themselves genetically modified and therefore may be used in the "ohne Gentechnik" production.The genetically modified microorganisms used for this production may not itself be contained in the feed.
The feeding of the dry cows is relevant for “Ohne Gentechnik” production, and for this reason the “relocation cow stable” has to be included in the audit process.
One audit has to take place at this stable within the scope of the initial audit and it has to be reported when animals are relocated. The “relocation cow stable” and/or the feeding must be audited if this option is used during the audit period. The farmer’s reports are to be checked against the reports in the HIT lists; VLOG considers a spot-check of “temporally” matching cows in the stock register and their whereabouts to be expedient.
The risk grade must then be chosen according to the criteria found in both farms.
Grading into risk category 0 is possible only when the feed is non-swappable feed subject to labelling.
Assuming that the cultivation of the species as GMO is forbidden in the country and the farmer canshow the seed declarations in the audit, this feed can be graded as not at risk. If there are no other genetically modified components on the farm, the risk category 0 can be applied.
If any of the conditions below are met, separate VLOG registration of the piglet rearing farm is not required.
- A VLOG certified pig fattening farm produces piglets for its own fattening. The rearing farm and the fattening farm run under the same company name and no piglets are sold to another VLOG certified fattening farm that wants to be credited for "non-GMO" compliant feeding.
- The farm is already certified to the VLOG Standard (or a standard recognized as equivalent) for piglet rearing.
- The "non-GMO" compliant feeding on the rearing farm is not to be credited as part of the minimum feeding period on the fattening farm
01 January 2021
It is permissible to perform a document check (2) 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 current VLOG Standard 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 in 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 if the period of outsourcing is to be credited toward compliance with the minimum feeding conversion period.
(1) Alpine farm, including mountain pastures: privately, collectively or cooperatively owned farms with mountain pastures that can only be used during the summer months.
(2) Prerequisite for a document check: The conclusion of a Standard Usage Agreement with VLOG and an audit agreement with a certification body recognised to perform document audits, see list on p. 4/4.
10 September 2021
Yes, alternatively to sending the report via Mail, Email, Fax or similar, it is also possible to have it available for download on a website. Three conditions have in this case to be fulfilled: the member is informed where to find the report, the member has access to the website and the security of data is assured.
Yes, the company can be converted into a group member. The following steps are necessary:
- Certification has to be transferred to the new certification body (if different from the former certification body): an exchange of relevant documents/information between the certification bodies has to take place (see chapter A 3.11.4 in VLOG standard). The contract with the former certification body has to be abrogated.
- The individual certification is converted into a group certification: the group organiser and the new certification body take the company into the group (e.g. adding to the member list, checking/correcting the risk category, including into risk management, contract between group organiser and company...)
- The company abrogates the standard usage agreement with VLOG (information to info(at)ohnegentechnik(dot)org including the information, that the company will go into group XY) and does no longer have an own VLOG-ID.
After a successful transfer of the data, the new certification body can decide to acknowledge the last audit of the company as an audit inthe group certification --> the new audit period is than calculated based on the date of the last audit.
If a group member is audited in an earlier calendar year than necessary. the following audits also have to take place earlier.
Example: a farmer in risk category 0 had his last audit in 2019 and the next audits have to take place in 2022 and 2025. Now the audit does take place in 2021 instead of 2022. Therefore, the next audit (and all following) has to take place one year earlier, too (in this case 2024 instead of 2025). By this, it is secured that an audit always takes place at latest in the third year after the last audit.
No, VLOG sees no reason to allow an exception from an on-site audit by a neutral auditor.
On-site inspections by the group organiser are a clear requirement of the "Ohne Gentechnik" Production and Certification Standard.
There are not yet any further requirements for the qualifications of the group organisers' employees. The company Quant Qualitätssicherung, which also does the auditor training, offers training for companies (e.g. internal auditors). If you are interested, please contact Quant Qualitätssicherung directly at vlog.fra(at)tentemus(dot)com.
There is no temporal limitation in the VLOG Standard and it is not determined in which order the companies have to be audited. The initial certification of the group is possible only if at least 25% or 100% of the facilities and the group organiser itself have been audited. If the initial certification-process takes so long that the audit interval of a farmer has already endedat the time of the initial certification, the farmer can only be added to the group without another audit.
No, a certification body can’t be group organiser of a group that is audited by the same certification body. An independent control is in that case would no longer be possible.
Within the scope of the risk management and the analysis plan that is part of it, the group organiser must secure and prove that the farmer fulfils the testing requirements of the VLOG Standard. For every farmer and audit interval the test results demanded in part E have to beon hand. In the event of deviations/positive results, it may be necessary for the group organiser to arrange further analyses as corrective measures. The certification body can take care of sampling and sending samples to a laboratory.
It is urgently recommended that affected businesses operating in the “Ohne Gentechnik” sector take the following measures:
• 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 (different labelling provisions)
• Request the analysis results for testable source products from the producer
• Inform the supplier of the obligation to label products containing GMOs in the EU and emphacise the importance of proper labelling to “Ohne Gentechnik” production
 Suitability of Testing for GMOs in Raw Materials, Feed- and Food Ingredients
10 September 2021
Provided that no parts of the boiling water of the not conform meat (e.g. fat) enter the “VLOG” meat and no parts of the saline bath of the not conform cheese enter the “VLOG” cheese, the scalding water and the saline bath may be used for both qualities.
For dyed eggs, the EGGenTDurchfG not only contains requirements for the eggs, but also for the dye. If dyed eggs shall be brought into the market with the “Ohne GenTechnik” seal, an extension of the existing licensing agreement is necessary. By using the print numbers, it has to be documented that only VLOG-certified eggs are used. Furthermore, the manufacturer of the dye has to submit a supplier declaration for the dye, stating that the criteria of the EGGenTDurchfG are complied with. If these provisions are fulfilled, the dye factory does not have to be certified to obtain the licence for the “Ohne GenTechnik” seal for dyed eggs.
Annex I of the "Ohne Gentechnik" Production and Certification Standard contains, the VLOG GMO-free certificate. Since 01 January 2019, only this certificate is permissible for VLOG certification.
According to the EGGenTDurchfG, the definition of the depth of review back to the last organism capable of reproduction (pursuant to Regulation 834/2007), 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 "using 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) may, however, not have been subject to compulsory labelling pursuant to Regulations (EC) 1829/2003 and 1830/2003 (cf. Chapter A1.4 of the VLOG Standard).
The use of annex I is obligatory, own declarations are not accepted. If the certificate is not filled in by the supplier, then it may be filled out by the business itself. This can only be done based on GMO test results, a risk assessment or similar.
In many cases, an InfoXgen declaration will be sufficient as proof for use in "Ohne Gentechnik" products. However, in several cases, the requirements of the EGGenTDurchfG and the VLOG Standard go beyond that of Regulation (EC) No 834/2007 on Organic Production and Labelling. Please see FAQs about the topic “Organic and VLOG” for further information.
VLOG recognises a certification against the following standards as equivalent to a certification against the VLOG “Ohne Gentechnik” Production and Certification Standard. Other standards may not be considered as equivalent without further consultation with the VLOG office. The recognition requires thorough benchmarking by the VLOG office.
09 February 2021
The "Ohne GenTechnik" seal can be used on billls of lading, invoices or other business documents if the business has concluded a Sub Licence Agreement with VLOG.
If the products are clearly labelled as “Ohne Gentechnik”, a label with the “Ohne GenTechnik” seal on the outer packaging is not compulsory. The identifiability/separation may be ensured also by the following measures, for example:
- Unique product number which the “Without genetic engineering” quality is attributed to in the EDP system
- Pallet identificationas “ohne Gentechnik“/”VLOG”
- Defined pallet colour as “ohne Gentechnik“/“VLOG“
Apart from the labelling in the article description, it is also possible to use a footnote, asterisk (*) or similar which is explained on the slip. If a delivery only contains VLOG certified products, it is also possible to add a sentence that makes clear that all food on the delivery slip is “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.
In cases where necessary additives such as vitamins are demonstrably not available in the market in “ohne Gentechnik” quality, additives produced by GMOs may be used. Prerequisite for this exception is that these substances be listed by the EU Commission according to the procedure provided by Regulation (EC) No. 834/2007. At the moment (October 2019) this list is empty. If a certain additive or other substance is only available as a GMO, then the producer must request that this substance be listed in the Regulation (EC) No 834/2007 on Organic Production and Labelling.
Pursuant to the VLOG Standard, for producers of inorganic products (e.g. sodium chloride) there is no certification duty. However, businesses which wish to use these ingredients in "Ohne Gentechnik" products, require a VLOG GMO-free certificate from the supplier in order to use the ingredient in "Ohne Gentechnik" products.
Natural rennet can be used for the production of "Ohne Gentechnik" food if the animals from which the rennet comes were not genetically modified. It is irrelevant what the animals were fed. 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. Prohibiting the use of substances created using GMOs applies to this (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 rennet it is the calf - was genetically modified.
For microbial rennet, however, the production by GMO is especially relevant. A VLOG GMO-free certificate is necessary in this case to use the rennet in "VLOG" products.
The group description does not need to be on file at the branches in printed form if the branch can technically access it at any time (e.g. business server).
It is possible that the supplier list is on file only at headquarters if the branches can order bulk goods in “Ohne Gentechnik” quality only using the goods management system and if only recognised suppliers can be ordered from through that system. This process must be described in the group description.
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 (see chapter E 2.1 of the VLOG Standard).
No, feed mixer that are used, for example, for daily feeding of silage and concentrated feed are not mobile grinding and mixing facilities in terms of the VLOG Standard. Mobile grinding and mixing facilities are used only for dry feed components such as grains.
This depends on the certification of the feed that the farmer orders to be mixed/grinded in the facility. If organic certified feed is processed no additional VLOG-certification of the facility is necessary to reach risk category 0. If the feed is not organic-certified a VLOG-certification of the facility is necessary to let the farmer reach risk category 0. If no additional VLOG certification is available, the farmer gets in risk category 1.
If the company does only trade with VLOG-certified oil but no with other “VLOG geprüft”-feed, the certification for Feed Manufacturing – mobile grinding and mixing facility is sufficient and no additional certification for trade is necessary.
A confirmation from the manufacturer in which information regarding the preciseness of the work/removal of residues/carryover is sufficient as an alternative to a facility report. Such a document should be requested by the business unless it is already on file. If there is evidence that the grinding and mixing facility is used only for VLOG-certified goods or goods not subject to compulsory labelling, such a confirmation is dispensable.
In Version 20.01 of the VLOG standard an obligatory carryover test is implemented for mobile grinding and/or mixing facilities (see chapter C 6.2). Facilities that are already certified have to conduct this carryover test before 01.01.2021. At the beginning of 2020 VLOG will publish a guideline for conducting the carryover test. This guideline will be available online under “Further Documents/Instructions”.
By Version 20.01 of the VLOG standard it is possible for grinding and mixing facilities to adapt the VLOG audit interval to the audit interval of QS. The preconditions and further information can be found in chapter C 2.1. Upon request, the validity period can be extended even after the issuance of the certificate by the certification body if the requirements are fulfilled.
Case 1 - QS VLOG add-on module "Ohne Gentechnik/ VLOG geprüft": With revocation of the QS certificate the VLOG certificate and/or the QS VLOG add-on module "Ohne Gentechnik/VLOG geprüft" is also revoked from the business concerned. Only if again a QS certification with VLOG add-on module and a new VLOG certificate are present, products may be marketed as „Ohne Gentechnik“ and/or „VLOG geprüft“.
Case 2 - Own VLOG certification: If the QS certificate is withdrawn from the business, the VLOG certification can be maintained further if all conditions are fulfilled. If the validity period of the VLOG certificate was extended by the QS certification, a new VLOG certificate with shortened validity period must be issued, if the QS certificate is not again issued within one month. With a new issue of the VLOG certificate the validity period is adapted in accordance with chapter A 3.11.3 of the VLOG standard, i.e. from the date of the last VLOG audit to the issuing of a new certificate, at the latest however up to the end of the following year (referred to the audit date).
If a new issue should lead to the fact that the validity period was already exceeded, then immediately a VLOG audit is to be accomplished, in order to maintain the certification.
If the same mixtures are periodically produced for the farmerby the mixing facility, it is sufficient to have a (digital) deposited mixing instruction. By using that instruction, it has to be possible to examineafterwards which instruction the single mixture can be clearly associated with. In case the single mixture differs from the instruction, this change has to be documented on the mixing protocol/bill of lading (e.g. “today 300 kg instead of 400 kg wheat have been used”).
It is possible for the operator to use up documents with the wording “VLOG geprüft” that have been purchased/printed out until 31.12.2020. This only applies to documents, that have been purchased/printed out before 01.01.2020, more recent documents have to be labelled with the wording “VLOG mixture”.
As there is no template for this consent, it may be created as needed. The consent must clearly explain which party it concerns.
Refined oil can’t be tested on GMO. Therefore, the farmer or operator of grinding and mixing facilities does not need to take (retention) samples.
It is not necessary to have the permission (or a copy) available on the farm. The permission will be checked by the auditor of the facility during its audit. In special cases, the certification body ofthe farmer can demand for the permission to be handed in by the farmer (e.g. sent in after the audit). This should only be done to spot-check or in case of problems/suspicion.
Livestock trade does not need to be VLOG-certified for the following:
- Livestock for which the minimum conversion feeding period has not yet started (e.g. calves, young cattle for milk production)
- Animals that will not be marketed as “VLOG”
In this case, the requirements in 20.01 of the VLOG Standard differ depending on the respective stage of the buyer.
1. Animal-based Production (Chapter E 4.6): This includes animals for food production and, according to the Standard. Until 31.12.2019 there is the possibility that VLOG-compliant feeding at the (non-VLOG-certified) previous owner can be taken into consideration if the previous owner fills in the confirmation in Annex II of the VLOG Standard.
2. Livestock trade (Chapter E 6.1): For the previous owner, proof of VLOG certification or the integration in a VLOG group certification for the Animal Scope of Applicability (e.g. cattle) must be provided if the "ohne Gentechnik" conform feeding may be taken into account.
3. Food (Chapter G 3.5): When accepting animals, a VLOG or equivalent certification must be provided.
So, if a farmer purchases an animal for the purpose of actual facility production (e.g. purchase of breeding animals, dairy cows on a dairy farm), then VLOG-compliant feeding by the previous owner can be taken into account until 31.12.2019 even if he is not certified.
If the animal is purchased for the purpose of trade (this is assumed in this case due to the short time at the agricultural operator), then the animal must come from a VLOG-certified agricultural operation in the animal sector (here: cattle). Taking into account VLOG-compliant feeding by a non-VLOG-certified supplier is not possible in this case.
By Version 20.01 of the VLOG standard it is possible for animal transport and livestock trade to adapt the VLOG audit interval to the audit interval of QS. The preconditions and further information can be found in chapter C 2.2. Upon request, the validity period can be extended even after the issuance of the certificate by the certification body if the requirements are fulfilled.
Case 1 - QS VLOG add-on module "Ohne Gentechnik/VLOG geprüft": With revocation of the QS certificate the VLOG certificate and/or the QS VLOG add-on module "Ohne Gentechnik/VLOG geprüft" is also revoked from the business concerned. Only if again a QS certification with VLOG add-on module and a new VLOG certificate are present, products may be marketed as „Ohne Gentechnik“ and/or „VLOG geprüft“.
Case 2 - Own VLOG certification: If the QS certificate is withdrawn from the business, the VLOG certification can be maintained further if all conditions are fulfilled. If the validity period of the VLOG certificate was extended by the QS certification, a new VLOG certificate with shortened validity period must be issued, if the QS certificate is not again issued within one month. With a new issue of the VLOG certificate the validity period is adapted in accordance with chapter A 3.11.3 of the VLOG standard, i.e. from the date of the last VLOG audit to the issuing of a new certificate, at the latest however up to the end of the following year (referred to the audit date). If a new issue should lead to the fact that the validity period was already exceeded, then immediately a VLOG audit is to be accomplished, in order to maintain the certification.
The VLOG Assessment Aid for Suitability of Testing for GMO provides an overview of feed, raw materials and products that can be tested on GMO or not. The responsible analysis laboratory is also consulted about the analysability of feed and raw materials.
First it must be taken into consideration which measures the business has introduced following the positive analysis results (Were there direct and long-term measures? Evaluation of the analysis results and assessment of the process?). If no concrete and effective measures were taken, that would be a reason not to issue a certificate. Corrective measures must be taken and their efficiency must be proven through analyses. If necessary for the evaluation ofcorrective measures, a follow-up audit has to be carried out by the certification body.
It is not required for the supplier and the client to take a sample of the feed together. So, it is possible for the deliverer to provide the reference sample. Please note, that in this case the farmer takes the responsibility for the process and has to decide if he wants to relinquish the security of a joint sampling.
The analyses conductedby companies that are certified against VLOG or a standard recognised as equivalent to VLOG may be taken into account by the customer. This is possible, if the samples were taken from the specific batch delivered to the customer and if they have been analysed according to the requirements of the VLOG-standard.
If the supplier was informed in writing about the test result, an additional statement can be waived. When giving out the information, it is recommended to explicitly ask the supplier to give feedback if it should turn out that thefeed is subject to labelling requirements. For example, the following wording can be used: "If it should turn out that this is a contamination requiring labelling in accordance with ECRegulations 1829/2003 and 1830/2003, please inform us immediately".
The number of samples in chapter G 4 (between 2 and 12 per year) relates to the whole amount of raw material used in the VLOG-production.
The business has to distribute the 12 analyses among all at-risk raw material that can be tested on GMO. If this only concerns the paprika extract, this is the only material, 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, that lead to 5 analyses). Additionally, sampling and GMO-testing can be reduced if the raw material and products are not at-risk. In this case a risk assessment according to chapter G 4.1.1 has to be created.
Only certification bodies approved by VLOG may issue certificates according to the VLOG Standard. All certification bodies approved by VLOG are listed here.
No, before VLOG audits can be performed, the VLOG training must be completed. It is not mandatory to wait for the training certificate to be issued, but the training must have been successfully attended.
Each site that is relevant for the VLOG production must be audited. I.e. every site through which “VLOG” food/"VLOG geprüft/verified" feed pass and on which activities that require VLOG-certification take place.
In general, it must be checked during the audit whether a Standard Usage Agreement has been concluded with VLOG. If this is not the case, this must be remedied by concluding an agreement and submitting it to the certification body before the certificate can be issued.
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 also alternatively decide to conduct a spot-check test.
It has to be assessed if the problem is site-specific or systematic for the whole company. In case of a systematic problem (for example in the 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 a written confirmation from the certification body indicating that, based on the audit result, a certificate can be issued but has not been issued yet for other reasons.
Corrective actions and deadlines must be presented by the audited business within 4 weeks after the audit and are to be approved by the competent certification body. Deadlines for the fulfillment of corrective actions, have to be coordinated between certification body and company and at latest until the next inspection. In case of safety-relevant corrections, the certificate will only be issued after the corrective actions have been implemented.
Both methods are possible. On the one hand, one certificate can be issued for the whole company (including the VLOG-ID of the company and all sites with their Sub-IDs). On the other hand each site can get its own certificate (including name of the company with general VLOG-ID and the specific site with its Sub-ID).
Product-specific information may be added to the certificate in the form of an annex to the certificate. However, on the VLOG certificate, it is only possible to provide the information about the scope of applicability with reference to the annex.
No. Membership is required only to have a right to vote in the VLOG association; a licence is the prerequisite for the use of the seal. At present, neither is obligatory in order to be certified according to the “Ohne Gentechnik” Production and Certification Standard.
The signature of the company is sufficient on the last page of the facility description.
The auditor has to sign every page. Anyway, the signature on the last page can be sufficient, if the facility description is scanned, photographed or copied after the audit and retained by the certification body. In this case, the missing signatures on the preceding pages do not present a problem, because the audited version can be checked retrospective changes can be identified afterwards.
If there are no substantial differences between the current and the new version, the current version can be used further on. It there are substantial differences between the current and the new version, either a new version has to be filled out or the differences/additions have to be added to the current version. In doing so, the comprehensibility and clarity have to be hold up.
A business that wishes to use the “Ohne GenTechnik” or “VLOG geprüft” seal may start the process of applying for use of the seal in the course of the certification process. As soon as the VLOG-certification or a certification according to a standard recognised as equivalent was passed (confirmed by a valid certificate), the application for use of the seal can be submitted to VLOG. The awarding of the licence normally takes two to four weeks, depending on the extent of the check. This is, if all other required documents/information (e.g. licence agreement, scope of application) were submitted to VLOGcompletely. In urgent cases it can be possible to shorten the duration of the process.
For the use of the protected "Ohne GenTechnik" or "VLOG geprüft" trademark, an annual licence fee is to be paid to VLOG. For food, the annual fee is calculated based on the turnover of the products labelled with the “Ohne Gentechnik” seal. For “VLOG geprüft“ feed the annual fee is based on the total turnover of the company. Detailed information regarding the fee amount is available in the current VLOG Licence Fee Schedule "Ohne GenTechnik" Seal and VLOG fee schedule for licences for the “VLOG geprüft” Seal. Costs that are associated with certification pursuant to the VLOG Standard are to be paid exclusively to the certification body and not to VLOG.
If the facility does not wish to become a VLOG member and does not apply for a license for use of the "Ohne GenTechnik" or "VLOG geprüft" seal, there are no other fees to be paid to VLOG.
That is a discretionary decision on the part of VLOG. In the event of a serious breach, VLOG may revoke the usage permission for the seal and define further sanctions. This is based on the sub-licensing agreement for use of the "Ohne GenTechnik" seal or the licence agreement for the "VLOG geprüft" seal concluded between VLOG and the user of the licensee.
The "Ohne GenTechnik" seal or "VLOG geprüft" seal may be used on delivery slips or internal business documents if the business has concluded a (Sub) Licence Agreement with VLOG.
To use the German, or a translated version, of the “Ohne GenTechnik” seal, the requirements of the VLOG Standard must be met along with those pursuant to the national law of the country where the product is being placed on the market. Assessing the legality of using the “Ohne GenTechnik” seal outside of Germany is the sole responsibility of the licensee.
A suitable translation of the “Ohne GenTechnik” seal may be requested from VLOG by contacting layout(at)ohnegentechnik(dot)org. It is not permitted to develop one's own translated version. Products may only be placed on the market with a translated version of the seal following conclusion of a sub-licensing agreement between the licensee and VLOG. If such an agreement already exists, it must be supplemented with any new products that are to be labelled.
The “VLOG geprüft“ seal may also be used on feed that is placed on the market outside of Germany. Beside the German version of the seal, there is also an English version available: “VLOG verified”. No other translations are permitted.
The "Ohne GenTechnik" seal is a trademark-protected word and figurative mark, which is owned by the Federal Republic of Germany, legally represented by BMEL. On the basis of an exclusive agreement with the Federal Ministry of Nutrition and Agriculture, solely VLOG is authorised to issue usage rights for the “Ohne GenTechnik” seal. The specific usage is governed by an agreement between each licensee and VLOG. The basis for this agreement is certification of compliance with the VLOG standard or a standard recognised as equivalent.
Food with this label may not be genetically modified organisms (GMOs) itself, nor contain or be produced from GMOs. No components produced by GMOs may be used during the production either.
For food of animal original such as meat, milk or eggs and for food that contains productsfrom animal origin, the following also applies: They may only be labelled as "Ohne Gentechnik" if the animals themselves were not fed with genetically-modified feed within defined periods.
Milk, eggs and meat need not be labelled, even if the animals have eaten genetically modified plants. However, most genetically modified plants are globally used to produce animal feed. By means of the “Ohne Gentechnik” label, manufacturers can point out to the customer that they have refrained from using genetically modified plants in the food itself and in animal feed. Thus, consumers have the possibility of standing up for GMO-free agriculture by their buying behaviour.
VLOG endorses an extension of the EU labelling regulations for genetically modified food. The most important reason why Germany has a “Ohne Gentechnik” label is because the EU “Mit Gentechnik” labelling has large gaps. For example, milk, eggs and meat need not be labelled in the EU as being genetically modified, even if the animals have eaten genetically modified plants. At present, there is no majority in Brussels supporting a change of this law. Even if the mood should change in the EU Commission, it will take years before a new law will enter into force. Until an extended “Mit Gentechnik” labelling becomes obligatory, the voluntary “Ohne Gentechnik” labelling is a sensible alternative for consumers.
Consumer organisations appreciate the freedom of choice of consumers. As result of the "ohne Gentechnik" labelling the consumers can finally choose whether they want to support the cultivation of genetically modified plants or not. There is great hope for a boom of “Ohne Gentechnik” products and a decrease of the cultivation of genetically modified plants if the population, with a majority that rejects genetic engineering, purchases correspondingly.
The environmental associations welcome this labelling for the same reason. Above all, they see the threat to biodiversity and ecosystems which results from the cultivation of genetically modified plants.
The organic food industry considers the labelling opportunity to be a progress as well: Genetic engineering is never used to produce organic products. The fewer genetically modified plants are cultivated, the lesser the risk for contamination is. The expense for testing and safety measures would decrease.
The seal may be used on all products the business has received a usage license for from VLOG. Generally, the "Ohne Gentechnik" labelling is intended for all plant and animal-based food, if using genetic engineering in the production is possible or assumed by the customer. For example, because of general competition laws, using the seal on natural mineral water is not allowed because genetic engineering is generally not used for it. However, it could be placed on a label for mineral water with specific fruit ingredients (e.g. papaya) since genetically-modified papaya is available on the market. However, it is more common, for example, for chocolate which may contain soy lecithin or for food in which soy derivatives are part of the recipe. The same goes for your frozen pizza and cereal. However, food from animal origin is particularly important: from dairy products, eggs and poultry sausage to roast port and steak. When producing these foods, usually genetically modified plants are used. Thus success can be best achieved and communicated here.
In the processing sector (here: oil mills/refineries) the impurities/contamination can occur. 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 lead to a contamination of “Ohne Gentechnik” sunflower oil. Due to the risk of contamination, VLOG does not consider advertising such food (e.g. sunflower oil) as “Ohne Gentechnik” as “self-evident advertising”.
No. The "Ohne Gentechnik" label always has to refer to the entire product.
In general, any business that meets the statutory prerequisites can label its products with the words "Ohne Gentechnik". For this purpose, the businesses shall present prima facie evidence that their products meet the statutory prerequisites under Sect. 3a and Sect. 3b of the EGGenTDurchfG. The requirements vary by industry and product. The current "Ohne Gentechnik" Production and Certification Standard includes all requirements that must be fulfilled for the respective sector/stage.
The "Ohne GenTechnik" seal may be used exclusively by the business that has concluded a Sub-licence Agreement with VLOG for use of the "Ohne GenTechnik" seal.
Each product, that shall be advertised for with the "Ohne GenTechnik" seal requires a licence. The sub-licensee, i.e. the business that needs to apply for the licence for use of the seal, is clearly defined by VLOG: “A sub-licensee for the VLOG ‘Ohne GenTechnik’ seal has to be the distributor of a food product who, within the scope of its activities, applies the VLOG seal to its products. Generally, it is the manufacturer of the food product. In individual cases, it could also be the company that fills, slices or portions and then packages the food product.”
Here you will find detailed information on how to apply for the seal.
The “VLOG geprüft“ seal is a trademark-protected word/image logo whose owner is the Verband Lebensmittel ohne Gentechnik e.V. (VLOG). It serves the purpose of labelling feed that is suitable for producing food labelled as "Ohne Gentechnik". The feed is certified pursuant to the VLOG Standard or a standard recognised as equivalent by VLOG.
The "VLOG geprüft" label allows producers, merchants or suppliers to advertise that their feed has been inspected pursuant to the VLOG "Ohne Gentechnik" Production and Certification Standard or a standard recognised as equivalent.
The "VLOG geprüft" seal may be used exclusively by the business that has concluded a Licence Agreement with VLOG for use of the "VLOG geprüft" seal.
Each company that wishes to advertise feed with the "VLOG geprüft" seal or wants to use it on bills of lading or other documents requires a licence. If bagged feed shall be labelled with the "VLOG geprüft" seal, normally the producer acts as licensee but also a company that trades or does private labelling can be the licensee for products produced for it. In this case the license just includes products, which are traded by the licensee.
Certified organic feed is considered as equivalent to "VLOG geprüft/varified" feed and is there fore suitable for the production of “VLOG"/"ohne Gentechnik” food. If the feed is to be labelled with the “VLOG geprüft/varified” seal, no additional VLOG certification is necessary on top of the organic certification. However, the feed business has to apply to VLOG for a licence for the use of the “VLOG geprüft/varified” seal.
Genetically modified plants are prohibited in organic farming. Nevertheless, not all organic products may be labelled as "Ohne Gentechnik". Two issues are to be taken into account: thresholds for food ingredients and self-evident advertising.
Thresholds for food ingredients: According to the law, the same threshold for contamination with genetically modified components applies for ingredients in the organic sector and for conventional food: 0.9% per ingredient if contamination was adventitious or technically unavoidable. However, for “Ohne Gentechnik” products, the legislator expects a purity up to the detection limit of, in most cases, 0.1%. That means that organic producers must provide additional VLOG GMO-free certificates fortheir plant-based food ingredients.
Self-evident advertising: Since the requirements for organic and “Ohne Gentechnik” food ingredients are different, correctly implemented “Ohne Gentechnik” labeling for organic food of plant origin or plant ingredients must also not be self-evident. It could be different for products of animal origin such as milk, eggs and meat to which no ingredients of animal origin were added. The requirements for feed for the production of “Ohne Gentechnik” food do not go beyond the requirements in the organic sector. But here as well, in VLOG’s opinion, it may be sensible and legal to label an organic food item with the “Ohne GenTechnik” seal. For this purpose, however, the security concepts for guaranteeing it is GMO-free, which go beyond the requirements of the production of organic foods, should be implemented. Furthermore, there are longer conversion periods for some animal species (e.g. cattle for beef, aquaculture). Additionally, it may be argued that many consumers are not awarethat organic food are produced without genetic engineering. In this respect, the “Ohne GenTechnik” seal has an informative content and, from the view of the consumers, does not convey any self-evident fact.
For more in-depth legal advice, we suggest that you contact a law firm. In the “Links” column you will find contact information for law firms that have dealt in detail with “Ohne Gentechnik” labelling.
Whether or not organic certification may be considered as equivalent to VLOG certification depends on the additional ingredients that are used. During the production of spiced ham, ingredients are used for which the requirements of the EGGenTDurchfG go beyond those of Regulation (EC) No. 834/2007 on organic production and labelling of organic products (e.g. dextrose, spices). Organic certification is not sufficient in this case. In this document we explain in which cases further requirements have to be fulfilled for the recognition of the product as equivalent.
In general, any consumer or business can become a VLOG member. The purpose of the association is to inform consumers on the subject of food without genetic engineering within the meaning of consumer protection. The members have to support this.
Our members are farmers processors, marketers, food producers and trade businesses as well as advisors, associations and individuals.
The more members VLOG has, the more important its position does get in politics, economics and the media. With your membership, we can engage ourselves even better for GMO-free food production. As a member, you will regularly receive an electronic newsletter with news from the association and articles about current GMO topics. You may participate in the General Assembly (GA), the highest decision-making body of the association, and help determine the future of VLOG. Every second year, the GA elects its executive board. You may also participate in various work groups. We are happy to give you expert advice on “Ohne Gentechnik” production and support you in handling questions from consumers and the media.
Membership fees are staggered based on branches and annual revenue and start at 30€ per year for individuals. The fee schedule gives detailed information.
Membership and use of the seal are not linked. A licensee for the "Ohne GenTechnik" or "VLOG geprüft" seal does not have to be a VLOG member. On the contrary, not every member may use the seal. Nevertheless, most licensees are also VLOG members.The uniform seal promises maximum recognition by the consumer and, as a member, you profit from VLOG’s strong and expert representation of your interests. The uniform seal promises the greatest consumer recognition, and as a member, you have a dedicated and knowledgeable advocacy group in VLOG.