New EU rules for New GMOs – why Non-GMO labelling will become even more important
The new EU Regulation (2026/1388) on plants obtained by certain New Genomic Techniques (NGTs), published in the Official Journal on 26 June 2026, enters into force on 16 July 2026 and will apply from 17 July 2028. It creates a major transparency gap in the European food and feed supply chain. The new law fundamentally changes the legal framework for New GMOs on the EU market. Category 1 NGT plants and products are spared any measures of transparency and precaution: there will be no GMO risk assessment, traceability and labelling requirements throughout the whole food chain; with the exception of seeds. Consumers as well as processors of feed and food along the value chain will face many more hurdles to identify those ingredients and food products that have credibly been produced without any GMOs – be it “old” or “new” GMOs.
Market research shows: Consumers don’t differentiate between “old” and “new” GMOs. And the negative sentiment towards NGTs in our food remains as high as ever: e.g. in Germany, 69% of all consumers say that they think it is important that products containing NGTs are being labelled (April 2026); in Austria, 85.1% call for labelling (Aug. 2025).
A YouGov poll (November 2025) found that 82% of Danes wanted the EU to maintain its strict GMO rules, at a time when EU institutions were negotiating whether products from New Genomic Techniques should be exempted from existing labelling and traceability requirements.
As a result of the new EU regulation, in the future consumers wishing to buy Non-GMO food products will only find these with a certified Non-GMO or organic label. Whilst all conventional food production in the future will run the risk of incorporating NGTs in their products either on purpose or unknowingly, and use of NGTs will be strictly excluded in labelled Non-GMO and organic food.
This has the potential to significantly increase the value of Non-GMO labelling.
The European Union has adopted a new Regulation for plants obtained by certain New Genomic Techniques, such as targeted mutagenesis, cisgenesis or the rather new technologies like Crispr/CAS or Talen. The new legislation establishes two categories of NGT plants and substantially changes the way they are regulated.
Most plants classified as Category 1 NGT plants will be fully exempted from the risk assessment, authorisation, traceability and labelling requirements that currently apply to GMOs. Although these plants officially remain GMOs under EU law, they will largely be treated in the same way as conventionally bred plants.
Seeds and other plant reproductive material of Category 1 NGT plants will have to be identified as NGT material. However, this information will generally not have to be passed on throughout the food and feed supply chain. Food and feed produced from Category 1 NGT plants will therefore not be specifically labelled - neither for consumers, nor for processors along the value chain.
Category 2 NGT plants will remain subject to authorisation, risk assessment, traceability and GMO labelling requirements, although some of these requirements may be adapted.
The use of NGT plants remains prohibited in organic production. Non-GMO production and certification systems will also formally exclude the use of New Genomic Techniques in their production and certification standards.
The Regulation entered into force on 16 July 2026 and will apply from 17 July 2028. During this transition period, implementing rules, databases and further technical provisions will have to be developed.
17 June 2026
The European Parliament approves the Regulation at second reading, completing the legislative procedure.
26 June 2026
Publication of the Regulation in the Official Journal of the European Union.
16 July 2026
The Regulation enters into force.
2026–2028: Preparing for implementation
Implementing and delegated acts, databases and further technical provisions will be developed. At the same time, the food and feed sector, Non-GMO certification systems and organic supply chains will need to prepare for the new legal framework.
17 July 2028
The new rules apply. Most Category 1 NGT plants and products will no longer be subject to the existing GMO requirements for risk assessment, traceability and labelling throughout the food and feed chain.
The new Regulation creates a major transparency gap in the European food and feed supply chain.
Information identifying Category 1 NGT plants will be available at seed level, but there will be no general legal obligation to pass this information on when agricultural products are traded, processed or used as food and feed ingredients. Food businesses will therefore no longer be able to rely on the EU’s mandatory GMO traceability and labelling system to determine whether Category 1 NGT plants have been used.
This will present particular challenges for companies producing organic and Non-GMO food and feed. Although NGTs remain formally excluded from these production systems, the information needed to credibly avoid their use may not be readily available throughout the supply chain.
Businesses wishing to maintain NGT-free supply chains may therefore need to rely more strongly on:
- clearly defined purchasing specifications and contractual requirements along the full value chain;
- supplier declarations and documentation;
- knowledge of seed use and agricultural production;
- segregation and identity-preserved supply chains;
- risk-based auditing, sampling and testing;
- reliable certification and control systems.
The Regulation may consequently shift additional responsibilities and costs to farmers, processors, manufacturers and retailers that want to respond to the clear consumer demand for food produced without GMOs.
At the same time, transparent and independently controlled organic and Non-GMO production will become even more important. Where statutory information is no longer available throughout the food chain, credible certification and labelling systems will provide essential sign posting for businesses and consumers.
The new legislation changes the regulatory framework, but it does not remove the strong market demand for transparency, freedom of choice and food produced without GMOs.
a. Non-GMO production will remain possible – and even has the potential of gaining value and increasing its product portfolio (e.g. with plant-based products).
b. Organic and Non-GMO standards will continue to formally exclude New GMOs.
c. Consumer demand for transparency and Non-GMO food remains strong.
d. Voluntary labelling and certification systems will become more important.
e. The food and feed sector has until July 2028 to prepare before the Regulation applies
Following the adoption of the new EU Regulation on New Genomic Techniques, ENGA is shifting its focus from the legislative debate to the practical implementation of the new legal framework.
Together with its members and European partners, ENGA is working to ensure that Non-GMO production and certification will remain credible, practicable and economically viable.
Implementation of the Regulation
ENGA is closely following the development of implementing and delegated acts, EU databases, guidance documents and national measures. We will continue to represent the interests of the Non-GMO food and feed sector throughout this process.
Traceability and supply-chain information
As mandatory GMO traceability will no longer apply to most Category 1 NGT plants and products, ENGA is working on practical solutions to maintain reliable information throughout the food and feed chain. This includes contractual requirements, supplier declarations, documentation systems and risk-based controls. In addition, methods and instruments to increase transparency in the NGT market, such as the annual New GMOs Report, respective databases and of course the development and implementation of detection methods, will remain a key focus of ENGA’s work.
Standards and certification
ENGA is coordinating with national Non-GMO associations and certification schemes to assess where existing production and certification standards may need to be adapted. The objective is to ensure that Non-GMO claims will remain fully reliable, verifiable and trusted by consumers.
The new Regulation changes the legal framework, but it does not change consumer demand for transparency and food produced without genetic engineering. ENGA will continue to provide information, coordinate practical solutions and defend the interests of the European Non-GMO sector as the new rules are implemented.
To find out more about the legislative process and what it means for your business, please get in touch: info@enga.org