PLEZi Nutrition Non-GMO Case Study

Last week, former First Lady Michelle Obama announced the first line of products from PLEZi Nutrition, the company she co-founded to provide children with healthier snack and beverage options. The four fruity debut beverages – Tropical Punch, Orange Smash, Sour Apple, and Blueberry Blast – are low-calorie, have no added sugar, and include essential nutrients like potassium, magnesium, and zinc. Some parents factor in GMOs as well as nutrition when grocery shopping for their family so I thought it would be a fun exercise to review the ingredients in the four beverages for compliance against the Non-GMO Project (NGP) Product Verification Program Standard v16.1. The website provides a handy list of the ingredients present across all four products.

Below I have highlighted the ingredients that might be challenging based on their ‘risk’ and estimated dry weight percentage*:

Apple Juice Concentrate: Apples have been on the “High-Risk” crop list (see Appendix B of the Standard) ever since genetically engineered, non-browning apples hit the marketplace a few years ago. The good news is that GMO apples are a very small segment of the marketplace (packaged, sliced apples). Compliance is easily achieved with a supplier affidavit confirming the apples used to make the juice are non-GMO per the NGP Standard definition.

Soluble Vegetable Fiber: This could be from a low-risk crop source such as chicory or psyllium but if it is derived from a high-risk crop then the Technical Administrator would require additional documentation that shows the crops are produced in a system designed to avoid GMOs (Identity Preserved or Organic certified, or Non-GMO Project Verified), or cultivated in a country that does not grow GMO varieties of that crop. High-risk, major amount (5% or more) inputs are approved based on ongoing sampling and GMO testing for contamination if they are not NGP-verified or eligible for Country-of-Origin compliance. I doubt that the fiber ingredient contributes more than 5% to the dry-weight formulation though.

Citric Acid and Ascorbic acid: Citric and ascorbic acid are industrially made via microbial fermentation of carbohydrate-based media and are considered high-risk inputs. At a micro amount (less than 0.5% of the formulation as dry weight), the NGP requires affidavits or other documentation to confirm that the production microorganisms are not genetically engineered and that no disclosure is required under the National Bioengineered Food Disclosure Standard.  If citric or ascorbic acid contributes more than 0.5% of the formulation, the fermentation media must also be deemed compliant and if it is derived from a high-risk crop such as corn or sugar beets, the supplier must provide documentation as described above for the soluble vegetable fiber.

Potassium Citrate, Sodium Citrate, and Magnesium Lactate: These inputs are made by adding their respective mineral salts to citric/lactic acid. The minerals are considered non-risk because they are not derived from biological inputs but as noted above, there is risk involved in the citric and lactic acid production from the microorganisms and the fermentation media. My best guess is that these inputs don’t contribute more than 0.5% to the beverages though and would only require compliance at the micro, high-risk level as described above.

Vegetable and Fruit Juice colors: While the vegetables and fruits that provide color for the Tropical Punch and Blueberry Blast beverages are probably low risk–like beets, purple carrots, or blueberries–there might be preservatives or other additives present that could fall into the high-risk category such as citric acid.

Malic acid: Malic acid is probably produced from non-biological sources (double hydration of maleic anhydride), but this is one of those ingredients that is guilty until proven innocent, so it is important to obtain clear statements from the manufacturer about raw materials and production processes.

Pectin: Pectin could be high-risk if sourced from apples or if there are high-risk additives/preservatives, but low-risk citrus fruits are also common sources.

Beta-carotene: Beta-carotene can be produced via microbial fermentation, but it could also be extracted directly from plants or chemically synthesized. There is also risk associated with the carriers and stabilizers (gelatin, sucrose, starch, vegetable oil, etc.) that the beta-carotene extract is blended with.

Natural flavors: Natural flavors can be challenging because suppliers do not want to share proprietary information. Fortunately, detailed ingredient information forms used by Non-GMO Project Technical Administrators allow manufacturers to identify high-risk inputs present in the flavor components without divulging intellectual property. Flavors also often have non-proprietary carriers like maltodextrin, glycerin, alcohol, or vegetable oils, which could be from high-risk sources.

These remaining ingredients are low-risk (assuming no high-risk additives, preservatives, or processing aids): Watermelon Juice Concentrate, Orange Juice Concentrate, Blueberry Juice Concentrate, Stevia Leaf Extract, and Monk Fruit Extract. Zinc Oxide contributes no GMO risk since it is a mineral. I want to add that ingredients derived from synthetic biology** are prohibited in Non-GMO Project Verified products. If your supplier gives you any indication that an ingredient is derived from or produced via synthetic biology, it would not be compliant with the Standard even at a micro amount level.

Conclusion: This case study should give the reader an idea of how ingredients get reviewed for Non-GMO Project Verified compliance and illustrate how multi-layered and complex the process is! Ingredient compliance is just one piece of the verification puzzle, however. The program also reviews product labels, supply chains, production facilities, and quality control systems for compliance. There is a pathway over each compliance hurdle though and I feel confident that the above PLEZi beverages could achieve verification.

I applaud Michelle Obama and her team at PLEZi for providing children much healthier beverage options than the sugary drinks that currently dominate the market and for giving back 10% of the profits to fund programs that promote and improve children’s health. I look forward to PLEZi’s future product offerings!

*The Non-GMO Project Standard determines compliance requirements based on the dry weight percentage range and the designated risk associated with an ingredient. The NGP uses three different “dry weight” percent ranges: Micro (less than 0.5%), Minor (0.5-4.99%), and Major (5% or greater). Dry weight means that any water, salt, or qualifying processing aids, present in a formulation must be disregarded to calculate an input’s actual contribution to the formulation. The risk statuses are: Verified (already Non-GMO Project Verified, therefore automatically compliant), Non-Risk (derived from non-biological sources like minerals or petroleum), Low-Risk (inputs that do not have any GMO varieties), Monitored Risk (GMO varieties are under development), and High-Risk (crops or other inputs that have GMO varieties). The assigned risk combined with the dry weight percentage range determines what information is required to demonstrate compliance. The product labels indicate that the beverages contain 22% juice, so they likely contain 70-75% water.

**“The development of novel, artificial nucleic acid sequences, biological pathways, organisms, or devices or the redesign of existing natural biological systems.” Appendix A Non-GMO Project Standard page 40.