GMOs and the new NGT Regulation: what does it mean for your business?
On 16 July 2026, the new European regulation on New Genomic Techniques (NGT) entered into force, one of the biggest reforms of the GMO framework in thirty years. What does the distinction between NGT-1 and NGT-2 actually mean for the labelling of your raw materials? We outline the key changes below.
Pascal Brysse
What are GMOs and why is EU legislation changing?
Genetically modified organisms (GMOs) have been strictly regulated in the European Union since the 1990s, under Regulation (EC) No 1829/2003 (food and feed) and Regulation (EC) No 1830/2003 (traceability and labelling). Every GMO product must undergo a thorough risk assessment and, above the 0.9% threshold, must be labelled as "genetically modified". However, new breeding techniques, known as New Genomic Techniques (NGT) such as CRISPR-Cas, allow precision changes that are often indistinguishable from conventional breeding or natural mutations. This technological development was the direct trigger for a thorough revision of the European GMO framework.
The new NGT Regulation: two categories
On 16 July 2026, Regulation (EU) 2026/1388 on plants obtained by new genomic techniques entered into force, following approval by the European Parliament on 17 June 2026 and by the Council on 21 April 2026. The regulation introduces a two-track approach:
- Category 1 (NGT-1): plants equivalent to conventionally bred varieties. These are exempt from the extensive risk assessment and mandatory GMO labelling, but remain traceable through a public register.
- Category 2 (NGT-2): more complex modifications. These remain fully subject to the existing GMO framework, including mandatory risk assessment and labelling.
This is considered the most far-reaching reform of European GMO legislation since the European Commission's first proposal in 1988.
What does this mean for labelling and traceability?
For NGT-1 plants, the mandatory "genetically modified" label disappears, which represents a significant change to specification management and labelling processes for food businesses processing these raw materials. For NGT-2 products, as well as for all existing GMOs under Regulation 1829/2003, the classic labelling obligation (0.9% threshold) remains unchanged. Businesses purchasing raw materials from third parties will need to check with their suppliers which category an ingredient falls under, as this directly determines whether a labelling obligation applies.
Timeline: when does the new legislation actually take effect?
Following the regulation's entry into force on 16 July 2026, a two-year implementation period follows, during which the European Commission must develop the necessary implementing and delegated acts (including the criteria for classification into category 1 or 2, and how the public register will operate). The new framework will be fully applicable at the earliest by mid-2028. Until then, the existing GMO framework (Regulations 1829/2003 and 1830/2003) remains fully in force for all products.
What does this mean for your food business?
Even though full implementation is not imminent, the consequences are already relevant today: suppliers and growers are applying NGT techniques, and the classification of raw materials into category 1 or 2 will have a direct impact on your labelling and communication obligations. AMNorman can help you to:
- screen your raw materials portfolio for potential NGT- or GMO-related ingredients;
- prepare your specification management and labelling processes for the changing regulation;
- incorporate this new dimension into your risk analysis and supplier assessment.
Would you like to know what this new regulation means in practice for your raw materials and labels? Discover our approach to labelling and specification management, read more about risk analysis, or get in touch with us.
