National bioengineered food disclosure standard: QR codes for GMO food labels

The new National Bioengineered Food Disclosure Standard (NBFDS) requires that any food with bioengineered ingredients state so directly on the packaging, and provides acceptable disclosure methods to do so. Compliance doesn’t need to be costly or difficult thanks to the fact that QR codes are an acceptable disclosure mechanism. The same QR codes also offer additional benefits to brands and customers, like traceability data and customer engagement. In this article you will learn:

• What counts as bioengineered foods?
• What is the National Bioengineered Food Disclosure Standard
• Why QR codes are ideal for complying with the law and why they are called out in the new standard
• How to set up QR codes for use on packaging, quickly and reliably

Bioengineered (BE) foods, commonly referred to as those containing GMOs (Genetically Modified Organisms), are foods that contain one or more ingredients that have been genetically modified through in vitro rDNA or other methods not found in nature.

These ingredients — generally crops — are often designed to be more resistant to pests, weather conditions, or more abundant in vitamins. Most people know very little about the GMO process, to what extent our food products contain GMOs, and how these processes may or may not affect our health. That has put bioengineered foods at the center of controversy in the last few decades.

Unfortunately, misinformation dominates the conversation around whether bioengineered food is harmful. Ironically, studies point out that people opposed to or with negative opinions of products that include genetically modified organisms often don’t actually know what they are. The best thing that companies producing food with bioengineered ingredients can do is give consumers access to more information about their products. In any case, now that the bioengineered food disclosure standard is a law, some degree of this information sharing is a legal requirement anyway.

In July 2016, Congress directed the United States Department of Agriculture (USDA) to establish a mandatory standard to disclose foods that are bioengineered, partially to address the lack of information and familiarity with bioengineered foods. Due to a request from the U.S. Congress, the National Bioengineered Food Disclosure Standard (NBFDS, or “the Standard”) was released in 2018.

The Standard requires that food retailers, manufacturers, and importers disclose whether foods for retail sale are or may be bioengineered. However, statements about the impact that bioengineered foods may have on health are not a part of the requirement. The NBFDS clearly states:

“Nothing in the disclosure requirements set out in this final rule conveys information about the health, safety, or environmental attributes of BE food as compared to non-BE counterparts.”

As of January 1st, 2022, you’ll start to see more “bioengineered” tags on food labels in America. But again, this only requires a simple disclosure of the presence of bioengineered ingredients. Getting more in-depth information about what’s in your food still falls entirely on the decisions that brands make about how and which information to disclose.

According to the NBFD standard, “bioengineered food disclosure must be large enough and displayed prominently so that it is likely to be read and understood by the consumer under normal shopping conditions.” The standard includes five options for how food manufacturers can disclose this information:

1. Written directly on the package, e.g. “bioengineered food.”
2. A USDA approved symbol
3. A digital link, such as a QR code, with clear instructions, e.g. “Scan here for more food information.” or “Visit the website for more food information.”
4. A text message option prompting the consumer to request product information with a statement like, “Text [command word] to [number] for bioengineered food information.”
5. A telephone number or URL that consumers can call or visit for more food information.

The most interesting option offered in the bioengineered food disclosure standard is for an electronic or digital link as the mechanism to share the disclosure. While the standard doesn’t dictate exactly which technology must be used, it does call out two tools: QR codes, which are visible to the naked eye on packaging, and digital watermarks, which are invisible. Both options, even the invisible watermark, allow someone to scan the label with a smartphone to receive more information on the food’s ingredients. Both options must be accompanied by clear instructions on how to scan the food package for more information, as well as a telephone number for those who do not have a smartphone. In fact, studies show that a clear call to action or instruction accompanying a QR code significantly increases scan rates. Either way, scan rates have been increasing across the board with QR codes being used now more than ever.

Even though the NBFDS mandatory compliance date of January 1st, 2022 means it’s already a requirement, and the standard was first passed and proposed several years ago, retailers and manufacturers are still figuring out the best way to disclose GMO or bioengineered ingredient information to consumers. The stigma surrounding bioengineered foods remains strong because of ignorance. This raises the concern that having a simple label won’t give enough information to educate consumers. If the consumer doesn’t know what “bioengineered” really means, then a label without more detailed information certainly won’t do much toward making them feel confident in a purchase they already have reservations about.

Headlines caught the attention of British consumers in 2013 with a story about food inspectors finding horse meat and, in some cases, pork in meat products that were labeled as “beef”. In some instances, the content of non-beef products was 100%. Major brands, like IKEA and Tesco, were caught by surprise. At its core, the scandal was about people being appalled that they’d been deceived. In some of the worst cases, people who’s religious beliefs prohibit them from eating specific items, like pork, found that the deceit was very personal. Withholding information about what is in food products, whether intentionally or not, will always have the potential to be catastrophic for companies. The best approach is always full disclosure.

Food labels have typically been designed for simplicity — they will usually provide just enough information but not so much as to create confusion. That may sound theoretical, but we’ve seen time and again that being caught doing too little has immediate consequences and long-term costs for brands.

QR codes are ideal because they allow a simple way for consumers to engage with a product without the need for much space on package designs. They can also provide exceptionally useful scan interaction data; indeed, the data this kind of package interaction generates can directly improve the bottom line of food and fast-moving goods companies.

QR codes are an opportunity for food manufacturers to comply with basic requirements while also opening up access to the benefits of increasingly used connected packaging technology. Creating an information portal using a QR code on the packaging is forward-thinking for food manufacturers because of this. When a consumer scans a QR code on food with bioengineered ingredients, they will likely move on past the bioengineered food disclosure compliance details to access other information that a brand offers them: content like a product origin story, compelling media content, or promotional campaigns to engage loyalty. All of these are made possible.

QR codes integrated with packaging give products a digital identity. This digital identity becomes a gateway to reveal aspects about the product that wouldn’t be immediately evident. This creates a unique opportunity to share and collect information about food products on a unit-by-unit basis — an almost unbelievable level of granularity. A product with a digital identity can even have anti-counterfeiting properties as a feature of its digital identity tag. The QR code data can be managed in the QR code management system, and when a product is scanned, the scanning data becomes visible to the company.

Having a solid customer engagement strategy is paramount, especially when it comes to bioengineered foods. This is where product scan data, collected throughout a product’s journey and as it makes its way from the factory to market, starts to shine. Supply chain traceability data can be combined with customer engagement tools to convert product packaging into a new marketing channel. From this point, you can run segmented, location-based, or product variation-based campaigns. Scantrust software gives brand owners all the tools they need to do this along with other, welcome benefits. Imagine printing QR codes on an entire production batch even though you aren’t yet sure which location they will be shipped to and sold in. Usually, this would mean production might be delayed or complicated. With dynamic QR codes, customer engagement campaigns based on links embedded in the codes can be managed even after products are in market, providing very helpful flexibility in supply chain tracking, marketing, and sales engagement efforts.

Scantrust QR codes provide the means to easily see where a product has been and where it ends up based on scan interaction data. While this data is valuable to the food product manufacturers, consumers react well to insights on where products originate and the routes taken to end for products to end up on the local supermarket shelf. This is the kind of transparency that builds trust for products and brands.

Especially for products that may require a more detailed explanation, like bioengineered foods, QR codes are a direct way to deliver information. As alluded to previously in this article, studies show that consumers are interested and want to see a disclosure of what goes into their food, even when they may not understand everything they’re reading on the label.

According to a 2021 survey, over 90% of people in the U.S. claim they believe QR codes are a “reliable source of information,” while 83% of people in the UK see them as a “safe way to access information.” There is an abundance of opportunities for consumers to use QR codes in a variety of settings that have established familiarity and have cemented people’s comfort with scanning them.

QR codes are also playing an increasingly wider role in enabling supply chain traceability all over the world. Tracking supply chain data has been an integral part of the U.S. Department of Agriculture’s approach in defining standards for bioengineered products. In fact, the NBFDS indicates that supply chain records can serve as acceptable means of proving compliance with the standard; while disclosed product origin can serve as part of the disclosure requirement for locations where bioengineered food is not grown.

QR codes show savvy consumers not only what’s in their food, but where it came from, where it was processed, and how it was distributed. This is information that food manufacturers need to track and that consumers want. QR codes make it simple for that information to become a consumer-facing resource.

Scantrust has been helping companies generate and print QR codes on labels for years. By using Scantrust QR codes and consumer engagement solutions, you’ll get the QR codes you need for bioengineered food labels. You’ll also benefit from the following features:

• Enterprise QR code generation and support for getting the codes onto product packaging
• A drag-and-drop mobile web landing page editor. This provides a space for all the required disclosure information – no developer needed
• Real-time data from QR code scans

The National Bioengineered Food Disclosure Standard was designed to be a positive change for the food industry in the U.S. While there is criticism of it and we can’t say it is a perfect standard, it’s easy to argue that the NBFDS is about giving access to information and educating consumers about what’s in their food. Labeling for disclosure creates consumer trust and brands that go beyond the standard by providing consumers with clear, robust, and educational information are bound to take a bigger share.

Bioengineered food manufacturers have several options on how to comply with the standard. QR codes are the best of those options – they are simple, effective, and a rich means of thinking beyond regulation and moving toward opportunity creation.
Food labeling can be challenging, but Scantrust has plenty of case studies and experience showing that it can be managed successfully and contribute to business improvements. If you want more information about how your business can leverage QR codes, our team is available to help and you can contact us to tell us about your challenges at any time —  request a Scantrust demo.