In December 2025, the National Assembly approved partial amendments to the Food Sanitation Act and the Health Functional Foods Act introducing a mandatory Full GMO Labeling System. Under the new regime, even when genetically modified ingredients are not detectable in the end product, the labeling of GMO ingredients are required if GMO ingredients were used in the manufacturing process.
 
As a follow-up, on February 27, 2026, the Ministry of Food and Drug Safety (MFDS) issued an administrative notice proposing a partial amendment to the Labeling Standards for Genetically Modified Foods, etc. (the "Proposed Amendment Notice"). Under the Proposed Amendment Notice, soy sauce, sugars, and edible oils and fats produced or processed using genetically modified agricultural raw materials would be subject to the Full GMO Labeling System and GMO labeling would be required regardless of whether GMO DNA or protein remains detectable in the final product.
 
However, considering the stable establishment of the Full GMO Labeling System and to allow industry preparation, the implementation will be staggered. For example, the requirement for soy sauce is scheduled to take effect on December 31, 2026, while the requirement for sugars and edible oils and fats, with a one-year grace period, is scheduled to take effect on December 31, 2027.
 
The Proposed Amendment Notice also substantially strengthens the practical evidentiary burden on companies for post-market compliance. As soy sauce, sugars, and edible oils and fats undergo extensive refinement that removes detectable GMO components, the MFDS plans to base post-market oversight primarily on raw materials. Therefore, food businesses should secure and retain documentation proving strict segregation and management of final product lots, such as certificates showing products were manufactured and controlled under segregated conditions, and authoritative evidence regarding raw materials (e.g., certificate of distribution, government certificate, or test/inspection report), to fundamentally mitigate the risk of regulatory non-compliance.
 
Although the Proposed Amendment Notice initially targets only three product groups, there is a significant likelihood that the GMO labeling requirement will be expanded to secondary and tertiary processed foods that use such raw ingredients. Therefore, food manufacturers and importers should proactively review their raw material supply chains and comprehensively overhaul their documentary and verification processes.
 

[Korean Version]