USDA organic is a federal regulation: an organic food is produced and handled without "excluded methods", which is the rule's term for genetic engineering, and also without most synthetic pesticides and fertilizers, sewage sludge or irradiation, checked by a USDA-accredited certifier against your organic system plan. Non-GMO Project Verified is a private program about one thing, avoiding GMOs: a product is evaluated by one of four technical administrators against the Non-GMO Project's Standard, ingredients from high-risk crops like corn and soy are tested, and the verification is renewed every year. So organic covers far more than GMOs, and the Butterfly is narrower but tests for them. A third label sits beside both: USDA's mandatory bioengineered food disclosure, which a maker under $2.5 million in receipts is exempt from. In the example below, an Iowa tofu maker weighs its options when a co-op asks. Below are the differences, the federal label, the example, and a free checklist.
The short version
- Organic: a USDA regulation; no genetic engineering, plus rules on pesticides, fertilizers, additives and handling.
- Non-GMO Project Verified: a private, product-by-product verification focused on GMO avoidance.
- The Project tests ingredients from high-risk crops, not finished products, and renews each product every year.
- Its fee is $115 for most products, plus the technical administrator's own fees; it takes 3 to 6 months on average.
- Organic foods are exempt from the federal bioengineered disclosure; so are businesses with under $2.5 million in annual receipts.
- A food can carry both.
- Any "non-GMO" statement of your own has to be truthful and not misleading; the Project itself says "GMO-free" isn't defensible.
- TaroStack keeps each ingredient lot's supplier and its documents with the batches that used it. More below.
The differences
| USDA organic | Non-GMO Project Verified | |
|---|---|---|
| Who runs it | USDA's National Organic Program, through accredited certifiers | The Non-GMO Project, a nonprofit, through four technical administrators |
| What it covers | Genetic engineering, synthetic substances, pesticides, fertilizers, sewage sludge, irradiation, handling | Avoiding GMOs |
| GMOs | Excluded methods are prohibited in production and handling | Evaluated against the Project's Standard |
| Testing | Process-based: the rule prohibits the method | Major ingredients from high-risk crops, such as corn and soy, tested |
| Animal products | Organic feed and livestock rules | Feed with high-risk ingredients is tested; honey needs a 4-mile radius free of GM crops |
| Scope | The operation and its products | Each product |
| Renewal | Annual inspection | Annual review by the technical administrator |
| Label | "Organic" and the USDA seal | The Butterfly |
| Federal bioengineered disclosure | Exempt | Not an exemption by itself |
The organic rule is 7 CFR 205.105. The Project's process and fees are in its verification FAQ, and its current rules in the Standard, Version 17, published October 1, 2026. How organic records work is in organic certification record keeping. This is general information, not legal advice.
The federal bioengineered label
Since January 1, 2022, a food that's bioengineered, or contains a bioengineered ingredient, carries a disclosure under 7 CFR part 66. It doesn't apply to:
| Exempt | Why |
|---|---|
| Small manufacturers | Annual receipts under $2,500,000 |
| Restaurants and similar retail food establishments | Food served there |
| Foods certified organic | Under the National Organic Program |
| Up to 5% inadvertent presence | Per ingredient, when no ingredient intentionally contains a bioengineered substance |
| Meat, milk and eggs | An animal isn't bioengineered because it ate bioengineered feed |
USDA's list of bioengineered foods includes alfalfa, canola, corn, cotton, potato, soybean and sugarbeet, among others. FDA's guidance on voluntary statements asks one thing of a "non-GMO" or "not bioengineered" claim of your own: that it's truthful and not misleading.
An example: a tofu maker and a co-op
Skunk River Tofu Co., the made-up tofu maker in Ames, Iowa, I use in these examples, makes tofu and soy milk from Iowa-grown food-grade soybeans, and its co-op asked whether the tofu is non-GMO. Soybeans are on USDA's bioengineered list, so the question is fair:
| Option | What it takes | What the label can say |
|---|---|---|
| Say nothing | Nothing | Nothing about GMOs |
| Its own statement | The grower's identity-preserved non-GMO letter for each lot of beans | "Made with non-GMO soybeans" |
| Non-GMO Project Verified | A technical administrator's evaluation, a license agreement, soybean testing, yearly renewal; $115 a product plus the administrator's fees | The Butterfly |
| USDA organic | Organic soybeans and organic certification of the tofu plant | "Organic" and the USDA seal |
With $94,690 in sales, Skunk River is under the $2.5 million line, so the federal disclosure doesn't apply either way. It chose its own statement for now, backed by the grower's letter on every lot, and keeps the Butterfly in mind if a regional chain asks for it. How the tofu's costs work is in tofu business plan.
Get the checklist
Download the non-GMO and organic checklist. Two sheets: claims by product, with each product's high-risk ingredients, your receipts and certifications, giving the federal disclosure position and the claims open to it; and ingredient documents, each lot's letter, certificate or test with its expiry, red when it's run out. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A non-GMO statement rests on every lot of beans having its letter, organic rests on every input being organic, and the Butterfly on test results. A statement is only as good as the lot that didn't come with its paperwork.
How TaroStack does it
TaroStack keeps each ingredient lot's supplier and documents with the batches that used it.
Lots at receiving. Each delivery of soybeans gets a lot with its supplier, so the grower's letter belongs to a lot, not a folder; how documents follow lots is in certificate of analysis tracking.
Documents on the batch. Fields of your own on the batch record hold the letter's reference or the test result, and batch records note which lots were consumed, automatically.
Where it went. Each co-op and shop order records the lots it got, so one recall report shows every customer a lot of beans reached.
| The job | Folder | In TaroStack |
|---|---|---|
| The letter for a lot of beans | Filed by month | With the lot, from receiving |
| Which batches used a lot | Worked out from dates | Recorded on the batch |
| Which customers got it | Invoice by invoice | One recall report |
Lots, batches, receiving and orders are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.