GE Food Labeling Rule

Recent Developments:

Posted: September 23, 2015

Guidance on CP 121 – Labeling Foods Produced with Genetic Engineering

Today the Attorney General’s Office issued guidance on Consumer Protection Rule CP 121 – Labeling Foods Produced with Genetic Engineering. The guidance provides details on how the Attorney General’s Office interprets and will enforce the labeling law, which goes into effect on July 1, 2016. Formatted as an annotated version of the Rule, the guidance responds to numerous questions posed by individuals, organizations and companies about how the labeling requirements will operate. The Office anticipates providing answers to frequently asked questions in the coming months, and will update the guidance from time-to-time as necessary.

Questions about the guidance or the labeling law should be addressed to: (note: this is a new address).

Posted: July 8, 2015

Procedure for Applying to be an Independent Verification Organization

Pursuant to 9 V.S.A. § 3044(6), the Attorney General’s Office has established a procedure for authorizing independent organizations to verify that food has not been knowingly or intentionally produced from or commingled with food or seed produced with genetic engineering. Entities seeking to qualify as such an independent verification organization should send an application to with “Application for Independent Organization” in the subject line.

Applications should include: a cover letter outlining the entity’s scope of work, contact information for the organization, and additional materials sufficient to demonstrate that the entity meets the requirements of the Rubric for Assessing Independent Verification Organizations.

The Attorney General’s Office will review and assess applications as they are received and will follow-up with requests for additional information, as necessary. Applicants will be informed whether they are approved as an independent verification organization, and approved organizations will be posted on this website.

Posted: April 22, 2015

The Attorney General’s Office has formally adopted Consumer Protection Rule CP 121 after approval by the Legislative Committee on Administrative Rules. The adopted rule was filed with the Secretary of State’s Office on April 17, 2015. The rule will take effect on July 1, 2016, along with Act 120, the law requiring the labeling of food produced with genetic engineering.

Posted: March 27, 2015

The Legislative Committee on Administrative Rules will review the Final Proposed Rule CP 121 – Labeling of Food Produced with Genetic Engineering on Thursday, April 2, 2015, starting at 8am at the State House. The Committee’s review is one of the final steps prior to formal adoption of the Rule. The Committee’s full agenda is available here, and the full final proposed rule filing is available here.

Posted: March 23, 2015

On Friday, March 20th, the Attorney General submitted the Final Proposed Rule CP 121 to the Secretary of State’s Office and to the Legislative Committee on Administrative Rules. The Committee, which meets every Thursday between 8am – 9am at the State House, will place the rule on its agenda in the coming weeks and will review it in a meeting open to the public.

Posted: January 23, 2015

Responding to requests for additional opportunity to comment on the proposed rule on the labeling of foods produced with genetic engineering, the Attorney General has scheduled a second public hearing on the rule. This hearing will take place on Wednesday, February 4, 2015, from 5 – 6pm in Room 10 at the State House in Montpelier. Additionally, the Attorney General has extended the deadline for submitting written comments on the rule by two weeks to Thursday, February 12, 2015.

Posted: January 7, 2015

On December 8, 2014, the Interagency Committee on Administrative Rules approved the Attorney General’s Proposed Consumer Protection Rule 121 for the Labeling of Foods Produced with Genetic Engineering. The Attorney General has submitted the proposed rule to the Secretary of State’s Office, thus commencing the formal rulemaking process under Vermont’s Administrative Procedures Act.

The Attorney General will be holding a public hearing at the Statehouse in Montpelier on Tuesday, January 20, 2015, to accept public comments on the proposed rule. Members of the public are also invited to submit formal written comments to the Attorney General until January 28, 2015.

Further information is available on the Secretary of State’s website:

GE Food Labeling Rule

In May 2014, the Vermont Legislature passed Act 120, the law that requires labeling food produced with genetic engineering (GE). Foods produced with genetic engineering are also known as genetically modified organisms (GMOs). Act 120 may be viewed in its entirety here.

In passing Act 120, the Legislature tasked the Attorney General with developing rules to implement the law. These rules provide clarity on the scope and reach of the law, including specific requirements for labeling food.

Members of the public are invited to review the draft rule — Proposed Consumer Protection Rule 121 — and provide input by sending a message to

Learn More About Act 120 Rulemaking

  • To learn more about Act 120 and the draft rule, you may view answers to Frequently Asked Questions about Act 120. This document will be updated and expanded as rulemaking progresses.
  • In October 2014, the Attorney General held public meetings in Burlington, Montpelier, and Brattleboro to introduce the draft rule. The presentation shown at these meetings is available here.
  • In June 2014, the Attorney General released a GE Food Labeling Rule Questionnaire, developed to gather public input early in the rulemaking process and to field questions about the law. View a summary of the questionnaire results here.
  • Provide Input and Ask Questions

    While the Attorney General will solicit official public comments on the proposed rule in 2015, the Office welcomes ongoing feedback and questions from producers, retailers, and consumers at

    Communications submitted to this email address are subject to disclosure under Vermont’s Public Records Act, 1 V.S.A. section 315, et. seq. This email address will act as a repository for public input and not necessarily as a channel of two-way communication. The Attorney General’s Office anticipates publishing periodic answers to Frequently Asked Questions in response to the inquiries and input received through this channel. To the extent your message requires a specific response, a member of the GE Food Rulemaking Team will be in touch with you as soon as practicable, given the volume of input we receive.

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    Published: Oct 28, 2014