Category: Non-GMO Grains

For food manufacturers, ingredient processors, and other large-volume buyers, choosing the right non-GMO grain supplier involves more than finding an available crop at an acceptable price. Procurement and quality teams should evaluate how grain is grown, segregated, tested, documented, stored, and transported before approving a supplier.

That level of diligence is particularly important for corn. Genetically engineered varieties account for the large majority of U.S. corn acreage, which makes segregation and documented sourcing controls important for buyers making non-GMO commitments. At Clark Specialty Grains, we structure our grain programs around the specifications and documentation requirements established with each customer.

Key Sourcing Takeaways

• Choose a qualified non-GMO grain supplier: Look for documented sourcing controls, appropriate testing, lot-level traceability, and clear procedures for preventing commingling.
• Understand testing protocols: Ask which testing methods are used, where samples are taken, which traits are tested, and what action thresholds apply to your program.
• Verify physical segregation: Review storage, processing, loading, and equipment cleanout practices instead of relying on verbal assurances.
• Require useful documentation: Determine which Certificates of Analysis, PCR test results, traceability records, certifications, and shipping documents your quality team needs before ordering.
• Evaluate identity preservation: Identity-preserved programs can provide additional traceability and varietal control when those characteristics matter to your product.

Questions to Ask a Non-GMO Grain Supplier

A supplier evaluation should start with specific questions about sourcing and verification rather than price alone. The appropriate testing program can vary according to the crop, intended use, certification program, customer requirements, and type of claim a manufacturer plans to make.

Ask prospective suppliers questions such as:

• What non-GMO sourcing requirements do you establish with growers?
• What testing methods are used for the grain we are buying?
• Does an accredited third-party laboratory perform the testing?
• At what points in the supply chain is testing conducted?
• Is documentation tied to individual lots?
• How do you prevent commingling with genetically engineered or other grain?
• What happens when a test result does not meet the customer’s specification?
• Can you provide sample documentation before we approve the supplier?

Our non-GMO grain supply programs are built around verified sourcing controls, segregated handling, PCR-based laboratory testing, lot-level traceability, and documentation tailored to customer requirements.

Understand What the 0.9% Threshold Actually Means

One important correction to common discussions about non-GMO sourcing involves the 0.9% figure. The Non-GMO Project uses a 0.9% action threshold for products intended for human consumption. It should not be described as a universal U.S. legal limit for every food ingredient or every non-GMO claim.

An action threshold is also not the same thing as permission to intentionally use genetically engineered material up to that percentage. It is designed to address inadvertent or technically unavoidable presence within the requirements of the applicable verification standard. Buyers should therefore determine which certification, customer standard, contract specification, or labeling requirement governs their own product.

PCR-based testing is commonly used in non-GMO verification because it detects genetic material associated with genetically engineered traits. Depending on the method and sample, quantitative PCR can estimate the proportion of targeted genetic material in a sample. It is more accurate to describe PCR results as quantitative measurements or estimates under a defined analytical method rather than claiming that they reveal an exact percentage under every circumstance.

Compare PCR Testing With Rapid Strip Testing

PCR and lateral-flow strip testing serve different purposes. Rapid strips generally detect particular proteins associated with genetically engineered traits and can be useful for screening crops in the field or at receiving points. PCR testing detects DNA rather than expressed proteins and can provide more detailed information when quantitative analysis is required. Neither method should automatically be described as universally superior without considering the crop, processing level, intended claim, and verification standard.

Manufacturers should ask suppliers for enough information to understand the following:

• Whether testing is qualitative or quantitative
• Which genetic traits or events are included
• How samples are collected
• Which laboratory performs the analysis
• Whether the method is appropriate for the grain and processing stage
• How results are associated with shipment lot numbers

Heavily processed ingredients create an additional challenge because processing can degrade or remove DNA. In those situations, documentation from earlier stages of the supply chain may become especially important.

Review Segregation and Equipment Cleanout Procedures

A compliant test result is only useful if the grain remains properly controlled afterward. Grain can pass through harvesting equipment, trucks, bins, conveyors, processing systems, storage areas, and loading equipment before reaching a manufacturer’s facility.

When non-GMO and other grain share infrastructure, documented cleanout and segregation procedures become important. Buyers should determine how the supplier controls each transfer point rather than assuming that “non-GMO” means every piece of equipment is permanently dedicated.

Questions worth asking include:

• Are storage bins dedicated or shared?
• If equipment is shared, what cleaning procedures are followed between lots?
• How is cleanout completion documented?
• Are trucks or railcars inspected before loading?
• How are lot identities maintained during processing and transfer?
• What safeguards prevent the wrong grain from entering a non-GMO lot?

For programs requiring tighter varietal control, our identity-preserved grain programs maintain segregation and lot-level traceability from seed selection through delivery.

Require Documentation That Matches Your Quality Program

What a Non-GMO Grain Supplier Should Document

There is no single document package that every non-GMO purchaser must receive. The correct documentation depends on contractual requirements, certification programs, downstream customer expectations, and the manufacturer’s own quality system.

A supplier’s documentation package may include:

• A Certificate of Analysis
• PCR or other laboratory test results
• Lot identification and traceability records
• Supplier or grower non-GMO declarations
• Organic certificates when applicable
• Identity preservation documentation
• Bills of lading and shipping records
• Customer-specific compliance documentation

The important point is that records should correspond to the material being purchased and be detailed enough for a buyer’s quality team to verify compliance with its own requirements.

Unsupported non-GMO claims can create real problems, but that does not mean every shipment is legally required to have a lot-specific PCR Certificate of Analysis. U.S. law does not impose one universal documentation package for all voluntary non-GMO claims. In a 2015 investigation involving Xochitl corn chips, however, the FTC concluded that the company lacked a reasonable basis for its “No GMO” claims when it had not specifically requested non-GMO corn or obtained adequate evidence from suppliers. Consumer Reports testing cited by the FTC found an average of more than 75% GMO corn content in six tested packages. The FTC ultimately did not recommend enforcement action after the company removed the claim and implemented additional sourcing and testing measures. See the FTC’s closing letter on the Xochitl non-GMO labeling investigation for the complete agency record.

Understand USDA Organic Versus Non-GMO Verification

USDA Organic and third-party non-GMO verification are related but distinct standards. USDA organic regulations prohibit the intentional use of excluded methods, including genetic engineering, in certified organic production and handling. Organic operations also take measures designed to avoid unintended contact with prohibited materials.

However, USDA Organic is fundamentally a process-based certification. USDA policy makes clear that the inadvertent presence of detectable genetically engineered material does not by itself mean an organic product violates the regulations. Organic certification therefore should not be described as a guarantee of absolute zero GMO presence.

Likewise, Non-GMO Project Verified products are not automatically organic. A non-GMO crop may be produced using conventional agricultural practices that would not satisfy USDA Organic requirements. For manufacturers that need certified organic grain in addition to non-GMO controls, we offer food-grade grain programs that can be structured around the appropriate certification, testing, and documentation requirements.

Evaluate Food-Grade Quality Alongside Non-GMO Status

Non-GMO status is only one component of ingredient suitability. A manufacturer also needs grain that meets the physical, food-safety, processing, and performance specifications established for its product.

Food-grade corn specifications may consider factors such as moisture, test weight, kernel condition, varietal purity, color, foreign material, mycotoxin results, processing characteristics, and required certifications. Yellow, white, blue, pink, and other specialty corn varieties can perform differently depending on milling, cooking, extrusion, nixtamalization, or other manufacturing processes. Procurement teams should therefore evaluate the entire product specification rather than treating non-GMO status as a substitute for food-grade quality standards. Our approach includes multi-stage cleaning, segregation, testing, and pre-shipment documentation for programs that require food-grade specialty grain.

Consider Supply Capacity and Logistics

A technically strong non-GMO program still has to supply the volume a manufacturer needs on schedule. Procurement teams should evaluate inventory strategy, grower relationships, storage capacity, contracted production options, packaging formats, transportation access, and contingency planning.

Questions to discuss include:

• Can the supplier support spot and contracted purchases?
• How early should specialty varieties be contracted?
• Which packaging formats are available?
• Can the supplier coordinate full truckload and rail shipments?
• What happens when crop conditions reduce availability?
• Can specifications be maintained consistently across multiple deliveries?

Our bulk grain supply capabilities include 50-pound bags, 2,000-pound totes, bulk hopper trailers, and railcar shipments, depending on the grain, volume, and customer program, with rail logistics coordinated through access to Union Pacific and BNSF networks. For specialty crops with limited acreage, early planning is especially useful. Contracted programs can help align grower production with a manufacturer’s anticipated purchasing requirements, although contract terms, pricing structures, and availability should always be evaluated for the individual program.

Know the Limitations of Non-GMO Testing

No single laboratory result can replace good supply-chain controls. Testing verifies the sample examined under the analytical method used. It does not independently prove what happened at every point from planting through delivery.

Sampling is particularly important because a laboratory analyzes only a portion of a larger lot. Buyers should understand how representative samples are collected and how the supplier responds when results fall outside an agreed specification. Highly refined or processed ingredients may contain little intact DNA, which can make certain PCR analyses difficult or inconclusive. The FTC’s Xochitl letter, for example, specifically noted that its cited laboratory used a comparative approach designed to account for DNA degradation in processed corn chips.

For these reasons, strong programs combine appropriate testing with sourcing controls, segregation, traceability, and documentation instead of treating one PCR result as proof of the entire supply chain.

Build a Non-GMO Grain Program Around Your Specifications

Clark Specialty Grains works with food manufacturers, ingredient processors, distributors, and other commercial buyers that need documented specialty grain programs. Our offerings include non-GMO, USDA-certified organic, identity-preserved, food-grade, and specialty corn programs, with yellow, white, blue, pink, and other grain options available depending on crop-year supply.

Our facility supports third-party certification and quality programs, including SQF, Kosher, and Gluten Free certifications, along with PCR verification through accredited third-party laboratories, and we offer bulk shipping in bags, totes, hopper trailers, and railcar quantities.

If you are reviewing an existing supplier or developing a new sourcing program, we can discuss the grain variety, volume, testing scope, certifications, documentation, packaging, and transportation requirements that matter to your operation. Contact our grain sourcing team to discuss availability, request documentation, or begin building a program.

Frequently Asked Questions About Sourcing Non-GMO Grains