Introduction of GMO Full Labeling System

After more than two decades of debate since its initial proposal to the National Assembly, South Korea is poised to implement a comprehensive labeling regime for genetically modified organisms (“GMO”). On December 2, 2025, the National Assembly approved a partial amendment to the Food Sanitation Act and the Health Functional Foods Act (collectively, the “Amendment”) at a plenary session, bringing the GMO full labeling system closer to implementation. Below is a summary of the Amendment’s key details, the anticipated timeline, and its expected impact on the industry.

GMO labeling: If GMO is used as a raw material in production, "even when no GMO material remains" in the final product.

The biggest change in the Amendment is a shift from assessing whether GMO ingredients remain in the end product to assessing whether GMO ingredients are used in the production.

Current Labeling Standard: Foods that contain no detectable genetically modified DNA or protein due to extensive refinement or processing (e.g., edible oils, soy sauce, sugars, alcoholic beverages, etc.) are exempt from GMO labeling.
New Labeling Standard: Any food produced using GMO raw materials must carry GMO labeling, regardless of whether genetically modified DNA or protein residues are present in the final product.

Accordingly, items previously exempt, such as edible oils, soy sauce, and sugars, and secondary and tertiary processed foods that incorporate those ingredients will be subject to labeling. Given the broad scope of this change, the new GMO labeling requirement is expected to have a substantial impact on the food industry.

Considering this impact, the Amendment requires the Minister of Food and Drug Safety (“MFDS”) to phase in the food products subject to full GMO labeling. The MFDS is currently consulting closely with industry stakeholders to determine the staged implementation.

Relaxation of non-GMO labeling criteria

Under the Amendment, the conditions for using a “non-GMO” claim will be relaxed as follows:

Current Labeling Standard: A non-GMO label is permitted only when non-GMO ingredients constitute at least 50% of the product’s raw materials^[1] or are the single largest ingredient. Accidental or unintentional presence of GMO is not acknowledged.
New Labeling Standard: The 50% threshold and the largest-ingredient requirement are removed. Non-GMO labeling would be allowed where all relevant raw materials were procured as non-GMO, provided that any ingredients that would otherwise require GMO disclosure are present only at inadvertent contamination levels.

Korea’s current tolerance level for unintentional incorporation is 3%; the MFDS plans to reassess and amend allowable contamination rate through stakeholder consultation. Once a finalized threshold is established, products that meet that tolerance level will be eligible to use non‑GMO claims under the amended rules.

The Amendment establishes a strict, raw-material-based GMO labeling regime that requires labeling whenever GMO ingredients are used, regardless of whether GMO material remains in the finished product. Despite many concerns from academia and the food industry, the Amendment has been adopted. Therefore, it is crucial how the MFDS defines the items to be phased in under the full labeling requirement and determines the allowable threshold for unintentional incorporation.

To strengthen post‑market oversight of non‑GMO labeling, the MFDS is expected to implement verification mechanisms, including a traceability management system. Consequently, domestic food manufacturers will likely face higher costs to secure non‑GMO ingredients and to reinforce quality‑control measures in line with consumer expectations, while importers will encounter increased burdens to obtain ingredient‑level certification and documentary evidence from overseas suppliers.

As the GMO full labeling requirement is expected to have broad implications across the food industry, it is necessary to closely monitor regulatory developments and take proactive measures to mitigate potential compliance risks.

[1] Only when soybeans, corn, cotton, canola, alfalfa, and sugar beet, which are currently raw materials subject to GMO labeling, are used as non-GMO products

[Korean Version]

Share

Professionals

Professionals