GMO Disclosure to Buyers: Indicator 1.4.4 Compliance Requirements

Scope and Applicability of Indicator 1.4.4

Indicator 1.4.4 of the ASC Farm Standard Interpretation Manual applies specifically to aquaculture units (UoCs) that use compound feed. The requirement is straightforward: farms must disclose to all buyers of their ASC certified product when a product's feed contains greater than 0.9% Genetically Modified Organisms (GMO) or macro ingredients produced from GMO.

The 0.9% threshold derives from European Council Regulation (EC) No 1830/2003, which establishes traceability and labelling rules for GMO-containing products across the food and feed supply chain. By adopting this international standard, ASC aligns farm-level disclosure obligations with broader regulatory frameworks that buyers and retailers already recognise.

Who Must Disclose and To Whom

According to the Interpretation Manual's guidance on Indicator 1.4.4, the required disclosure is directed to the UoC's buyers of ASC certified products. This is a material distinction: the disclosure obligation does not require public labelling or a general announcement. Instead, farms must inform their direct commercial customers—processors, distributors, retailers, or other buyers—when the feed used to produce their ASC certified product meets or exceeds the 0.9% GMO threshold.

The Manual clarifies that

a public disclosure is possible but not required

What Triggers the Disclosure Obligation

The disclosure is triggered by two conditions:

• The product's feed contains greater than 0.9% GMO (by mass or proportion); or
• The product's feed contains macro ingredients produced from GMO that exceed the 0.9% threshold.

The phrase "macro ingredients" refers to principal feed components—such as soy, corn, or other staple ingredients—rather than trace elements or additives. If a compound feed mill uses soy meal produced from genetically modified soy, and that soy meal comprises more than 0.9% of the final feed formulation, the GMO status must be disclosed to the farm's buyers.

Documentation and Evidence of Compliance

The Interpretation Manual specifies what evidence farms must maintain to demonstrate compliance with Indicator 1.4.4. Under "Evidence of implementation should be maintained", the guidance requires:

• Records of disclosure to buyers

These records serve multiple purposes. They provide an audit trail for external auditors assessing farm compliance, they create a defensible record for the farm if questions arise about GMO transparency, and they document the farm's diligence in meeting contractual and regulatory obligations to buyers who may have their own GMO-sensitive supply chains or customer bases.

The form and medium of disclosure records are not prescribed by the Standard. A farm might maintain records through email correspondence with buyers, supplier agreements that include GMO disclosure language, laboratory test reports on feed ingredients, or attestations from the certified feed mill. What matters is that the records demonstrate disclosure occurred—not merely that the information was available, but that it was actively communicated.

Auditor Verification Approach

When auditors assess compliance with Indicator 1.4.4, they confirm:

• Evidence of disclosure to buyers

Auditors will typically request documentation such as buyer communications, supplier declarations, or feed certification documents that attest to the GMO status of compound feeds. They may also cross-reference feed mill certifications—Indicator 1.4.3 requires that compound feeds originate from feed mills holding valid ASC Feed Standard certification. The Feed Standard certifications often include information on GMO sourcing and handling practices, which auditors can use to corroborate farm disclosures.

Auditors are instructed to confirm the existence of records rather than to audit the technical accuracy of GMO detection itself. The farm's responsibility is to obtain reliable information from its feed supplier and pass that information to its buyers; it is not to conduct independent GMO laboratory testing unless the farm's management system or buyer contracts require it.

Relationship to Broader Feed Sourcing Requirements

Indicator 1.4.4 exists within a larger framework of feed traceability and compliance. Indicator 1.4.3 requires that all compound feeds originate from mills holding ASC Feed Standard certification and are accompanied by specific documentation identifying the production model (Mass Balance or Segregation) and feed name. Indicator 1.4.4 layers onto this requirement a specific disclosure obligation regarding GMO content.

Farms that operate under a Segregation Production Model—where non-GMO or certified feeds are physically separated from conventional feeds—may find that their feed suppliers already provide detailed GMO documentation. In such cases, the farm's disclosure to buyers may be as simple as forwarding the feed mill's certification or ingredient declaration that confirms GMO status below the 0.9% threshold (or explicitly stating no GMO content).

Conversely, farms operating under a Mass Balance Production Model, where certified and non-certified ingredients are mixed and tracked through a mathematical balance, must ensure their feed suppliers provide clear statements on the aggregate GMO content of the final compound feed supplied to the farm.

Practical Implementation Considerations

For a farm to comply with Indicator 1.4.4, it should:

1. Obtain from its feed supplier(s) clear documentation on the GMO status and GMO percentage of each compound feed product used.
2. Establish a process to determine whether any feed product contains >0.9% GMO or macro ingredients from GMO sources.
3. Communicate this information to all direct buyers of the farm's ASC certified product, either individually or collectively (e.g., through a standard supply agreement or product sheet).
4. Maintain records of these disclosures for audit review.

The disclosure can be integrated into existing buyer communications—product specification sheets, purchase orders, certificates of analysis, or supply agreements—rather than requiring a separate GMO disclosure form. The Standard does not prescribe the format or frequency of disclosure, only that buyers receive the information.

Scope Limitation: Applicability to Feed Users Only

Indicator 1.4.4 applies only to UoCs that use compound feed. Farms that rely exclusively on feed not subject to ASC Feed Standard requirements, or farms in species groups or systems where compound feed is not the primary input, fall outside the scope of this indicator. Similarly, farms that do not use any compound feed are not subject to Indicator 1.4.4 or the related feed traceability requirements in Indicator 1.4.3.

This article summarises ASC-INT-001-ASC-Farm-Standard-Interpretation-Manual-V1.0.1-September-2025.pdf. Refer to the original document for the authoritative text and full requirements.