Key data
| Regulation | Commission Implementing Decision (EU) 2026/518, of 10 March 2026 |
|---|---|
| CELEX Reference | CELEX:32026D0518 |
| Notified with number | C(2026) 1507 |
| Publication | 12 March 2026 |
| Entry into force | 10 March 2026 |
| Affected product | Genetically modified corn T25, code ACS-ZMØØ3-2 |
| Legal basis | Regulation (EC) No 1829/2003 of the European Parliament and of the Council |
| Affected parties | Importers of agricultural raw materials, manufacturers of processed foods and animal feed producers in Spain and the EU |
| Category | European Regulation |
Importers of agricultural raw materials, manufacturers of processed foods, and animal feed producers operating in Spain and the EU may continue to market products that contain, are composed of, or have been produced from genetically modified corn T25 (ACS-ZMØØ3-2). The European Commission has confirmed this through the Implementing Decision (EU) 2026/518, adopted on 10 March 2026 and published on 12 March 2026.
This renewal is neither automatic nor passive: it activates a set of operational obligations that affected companies must review and maintain in force. Non-compliance with labeling, traceability, or post-market surveillance requirements may result in action by the competent authorities.
What does this regulation establish?
Implementing Decision (EU) 2026/518 renews the authorization for marketing genetically modified corn T25, identified with the code ACS-ZMØØ3-2, in accordance with Regulation (EC) No 1829/2003 on genetically modified food and feed.
The authorization covers three categories of products:
- Products that contain T25 corn (ACS-ZMØØ3-2)
- Products that are composed of T25 corn (ACS-ZMØØ3-2)
- Products that have been produced from T25 corn (ACS-ZMØØ3-2)
The renewal does not modify the underlying regulatory framework, but confirms that the marketing of these products remains legal in the European market and that the conditions established in Regulation (EC) No 1829/2003 continue to be mandatory.
Economic and operational impact
For affected companies, this renewal has three direct operational consequences that must be covered:
| Obligation | What it means in practice |
|---|---|
| Labeling | Products that contain, are composed of, or have been produced from T25 corn must be identified in accordance with the requirements of Regulation (EC) No 1829/2003 |
| Traceability | Companies must maintain systems that allow tracing the use of T25 corn throughout the entire production and distribution chain |
| Post-market surveillance | The authorization holder must keep surveillance systems active and notify any incidents to the competent authorities |
The actual operational cost depends on the degree of prior implementation of these systems in each company. For those who were already complying with previous regulations, the impact is mainly documentary review and updating. For those who did not have these systems properly implemented, the renewal is a warning signal: authorities may verify compliance at any time.
Who does it affect?
This decision directly affects the following companies and professionals operating in Spain and the EU:
- Importers of agricultural raw materials that include T25 corn (ACS-ZMØØ3-2) in their operations
- Manufacturers of processed foods that use this corn as an ingredient in their products
- Animal feed producers that incorporate T25 corn in their formulations
- Authorization holders for marketing, who directly assume the obligations of post-market surveillance and incident reporting
Companies that do not use T25 corn (ACS-ZMØØ3-2) in any phase of their production chain are not affected by this specific decision.
Practical example
A Spanish manufacturer of compound feed for livestock that uses imported corn from third countries, part of which corresponds to the T25 variety (ACS-ZMØØ3-2), must verify three points following the publication of this renewal:
- Updated labeling: Check that final products containing or produced from T25 corn are correctly identified in accordance with Regulation (EC) No 1829/2003.
- Documented traceability: Ensure that you have records that allow you to identify in which batches and in what proportions T25 corn has been used, from receipt of the raw material to distribution of the final product.
- Active notification protocol: Verify that there is an internal procedure to detect and report to the competent authorities any incident related to this ingredient.
If this manufacturer did not have these systems implemented or had them outdated, the renewal of the authorization is the time to regularize the situation before a possible inspection.
What should companies do now?
- Identify if you use T25 corn (ACS-ZMØØ3-2): Review with your purchasing and quality department whether any of your raw materials or ingredients correspond to this variety. The identification code is ACS-ZMØØ3-2.
- Audit the labeling of your products: Verify that all products that contain, are composed of, or have been produced from T25 corn comply with the labeling requirements of Regulation (EC) No 1829/2003.
- Review your traceability systems: Check that you can trace the use of this ingredient throughout your production chain and that the documentation is up to date and available for a possible inspection.
- Activate or update the post-market surveillance protocol: If you are the authorization holder, ensure that surveillance systems are operational and that there is a clear procedure for reporting incidents to the competent authorities.
- Document compliance: Keep evidence of compliance with all these obligations. In case of inspection, the burden of proof rests with the company.
Frequently asked questions
What is genetically modified corn T25 and why does it affect my company?
T25 corn (code ACS-ZMØØ3-2) is a variety of genetically modified corn whose marketing in the EU has just been renewed by the European Commission through the Implementing Decision (EU) 2026/518. If your company imports, manufactures, or distributes products that contain, are composed of, or have been produced from this corn, you are directly affected.