…And What These Changes Mean for You
GMOs — the latest four-letter word to rock the food and beverage industry has evolved from a niche health topic to inspiring nationwide labeling legislation. Health-conscious consumers and public health advocates claim genetically modified organisms are harmful for humans and the environment. On the other side of the great GMO debate, recent reports find GMOs to be generally safe for humans and the environment, and some position GMOs as a solution for feeding a fast-growing global population.
Companies and legislators initially cringed at the thought of mandatory labeling of GMO ingredients. But that all changed in July when the QR code arose as an unlikely savior for manufacturers — and maybe consumers too.
GMO Labeling Legislation Timeline
- May 2014 – Vermont becomes the first state to pass mandatory GMO labeling law, set to go into effect July 1, 2016.
- Manufacturers scrambled to determine not only how to comply with labeling legislation, but also how to manage the logistics around creating and distributing those new labels only for the Vermont market.
- Vermont’s bill threatens to become “a de facto federal standard” for the industry.
- Legislators mobilized to devise a solution that would prevent a patchwork of state laws.
- July 2015 – House passes federal GMO labeling standard, but Senate cannot get the bill passed by year’s end.
- January 2016 – Campbell Soup Co. becomes first company to voluntarily label GMO ingredients in its products, and more companies later followed.
- March 2016 – Senate attempts but fails to pass a federal GMO labeling bill.
- June 2016 – Just before the Vermont bill’s deadline, the Senate Agriculture Committee introduces a bipartisan bill, which is now the official national GMO labeling law.
- July 2016 – Senate and House pass the bill, President Obama signed the bill into law.
What the Law Mandates for Manufacturers
While GMO labeling proponents gained a victory through the new national mandatory labeling standard, many were disappointed with some of the bill’s provisions. Labeling is mandatory for food and beverage manufacturers, but they have several options for compliance: an on-package statement, a symbol to be approved by the USDA or a QR code. Consumers can scan the product’s QR code with their smartphones to access GMO ingredient and other information.
For our customers, key points to keep in mind for compliance will be design adjustments for product labels, particularly the placement of the QR code, symbol or on-package statement, and the costs involved in reprinting labels with the new design. Also, for QR codes, our clients will need to plan where they’ll house the online content consumers will access by scanning the product label’s code. That means web development and hosting, which could require additional costs and labor.
But don’t start making significant changes too soon — the specifics at this point are yet to be determined, and the USDA has about two years to release guidelines for manufacturers. Those guidelines will likely contain clearer details for QR code and statement wording, size and placement, in addition to the exact types of information manufacturers will have to provide consumers, such as ingredient sourcing or processing information.
However, while manufacturers may have an upfront cost, the new GMO labeling bill also offers manufacturers an opportunity to boost brand education. Consumers will likely have to visit a particular website to learn about GMOs, and that online platform is infinitely scalable compared to the limited real estate on an actual product label. Manufacturers can use this to their advantage to be more transparent about their products and operations in a content hub consumers will already be visiting, such as providing information on allergens, animal welfare and fair labor practices.
QR Codes: Dirty Word or Industry Solution in GMO Labeling Debate?
The bill’s critics claim that using a QR code enables companies to hide information that should be easily legible directly on packaging. Opponents of the new bill also argue that forcing people to access this information via QR codes discriminates against those without regular access to this technology, particularly the poor, rural residents, older populations and minorities.
Manufacturers considering QR codes could also face pushback from retailers. Whole Foods Market offers prime shelf space for producers of better-for-you foods, but the retailer itself will require all companies to label GMO ingredients by 2018. Many products Whole Foods stocks are already non-GMO or certified organic (which also means non-GMO by default). But if other retailers decide to take a similar approach, manufacturers may have to reconsider their labels or retail strategies in the near future.
One option already gaining steam is SmartLabel, which the Grocery Manufacturers Association debuted late last year. SmartLabel is currently available on thousands of products from dozens of food, beverage and CPG producers, but GMA expects more than 34,000 products to adopt its QR code by 2017.
Legislators and other supporters of QR codes see the once-dying technology as a fresh opportunity for increased transparency across food and beverage — even though many of the brands themselves have long considered the technology almost obsolete. Yet through a single mandate, the government could revive a technology that has been glossed over as a marketing gimmick by companies and consumers alike.
It may seem curious that the industry would land on a technology on its way out of relevance in the wake of apps. But ultimately, the scalability of a webbased platform accessible via scanning a QR code is what made this older technology attractive to legislators and the industry again.
From here, only time will tell how consumers will respond to manufacturers’ use of QR codes for GMO labeling and other transparency initiatives. But now that the food, beverage and CPG industries have found a new relevant functionality for QR codes that resonates with curious and health-conscious shoppers, that all could change.
It’s up to the USDA now to finalize GMO labeling requirements for food and beverage companies in the next two years. Needless to say, the industry will be hungrier for QR codes perhaps now more than ever. And since we specialize in package design, we’ll be there to help our customers navigate through the new requirements.

Emily Carlson, Senior Account Leader
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