Transgenic Soybean GMB151 × DAS-44406-6: obligations for food and feed importers and manufacturers in the EU

Key data

If your company imports soybean from third countries—especially from markets where this transgenic variety is present in crops—or manufactures food and feed with soybean as an ingredient, this decision requires you to act now. Implementing Decision (EU) 2026/2112, published on 25 September 2026, opens the legal door for the variety GMB151 × DAS-44406-6 to circulate in the European market, but it does so with strict conditions of identification, labeling, and traceability that fall directly on operators.

The basic regulatory reference is Regulation (EC) No 1829/2003 of the European Parliament and of the Council, which regulates genetically modified food and feed throughout the European Union. The decision is not optional: it enters into force on the same day of its adoption, 23 September 2026.

What does this regulation establish?

Implementing Decision 2026/2112 authorizes three types of products related to soybean GMB151 × DAS-44406-6:

• Products that contain this transgenic soybean variety.
• Products composed of it (mixtures, preparations, compound feed).
• Products produced from it (oils, meals, derived proteins).

The authorization does not eliminate obligations: on the contrary, it activates a set of requirements that operators must comply with in order to legally market these products in the EU internal market.

This decision is particularly relevant for importers of soybean from third countries where the GMB151 × DAS-44406-6 variety may be present in crops on a regular basis, either in pure form or mixed with other varieties.

Economic and operational impact

The direct impact is not a fixed regulatory cost, but an operational cost that each company must size according to its business volume and the degree of updating of its current systems. The main areas of expenditure are:

• Review and update of labeling: Any product that may contain this variety must be reviewed. If the current labeling does not contemplate the GMB151 × DAS-44406-6 variety, it will need to be redesigned and reprinted.
• Update of traceability systems: Supply chain management systems must be able to specifically identify and record this variety. This may require software updates, staff training, or changes in goods receipt processes.
• Supplier audit: Importers must verify whether their suppliers in third countries supply this variety, and in what proportion it may be present in batches.
• Risk of sanctions: Non-compliance with labeling obligations may result in administrative sanctions in the Member States. The specific amount of sanctions depends on the national legislation of each EU country.

The cost of adaptation is proportional to the size of the company and the complexity of its supply chain. A company with multiple soybean suppliers in different countries will have a significantly greater adaptation effort than an operator with a single certified supplier.

Who does it affect?

• Soybean importers from third countries where the GMB151 × DAS-44406-6 variety is present in crops.
• Food manufacturers that use soybean or soybean derivatives as an ingredient (oils, lecithins, proteins, meals).
• Feed manufacturers that incorporate soybean or soybean by-products in their formulations.
• Distributors that market food or feed products that may contain this variety.
• Supply chain operators that act as intermediaries between third-country producers and the European market.

Practical example

A Spanish compound feed manufacturer for livestock regularly imports soybean grain from Brazil, a country where the GMB151 × DAS-44406-6 variety may be present in crops alongside other already-authorized transgenic varieties.

Following the entry into force of Decision 2026/2112 on 23 September 2026, this company must:

1. Verify with its Brazilian suppliers whether the supplied batches may contain the GMB151 × DAS-44406-6 variety.
2. Update its internal traceability system to specifically record this variety in delivery notes and batch records.
3. Review the labeling of its compound feed to include the corresponding declaration if the variety is present above the thresholds established in Regulation (EC) 1829/2003.
4. Communicate to its customers (farms, integrators) the possible presence of this variety in the supplied feed.

If it does not carry out these updates and the competent authority detects products with this variety without correct labeling, the company is exposed to administrative sanctions according to Spanish regulations implementing Regulation (EC) 1829/2003.

What should companies do now?

1. Audit the supply chain: Identify which suppliers supply soybean or soybean derivatives from countries where the GMB151 × DAS-44406-6 variety may be present in crops.
2. Update traceability systems: Incorporate the GMB151 × DAS-44406-6 variety as a traceable variety in supply chain management systems and batch records.
3. Review product labeling: Check that current labeling of food and feed complies with the requirements of Regulation (EC) 1829/2003 for this specific variety. Update if necessary.
4. Train the purchasing and quality team: Ensure that personnel responsible for purchasing, quality control, and labeling are aware of the existence of this new authorized variety and its associated obligations.
5. Review supplier contracts: Include declaration and traceability clauses for the GMB151 × DAS-44406-6 variety in supply contracts with third-country suppliers.
6. Consult a specialist in food regulation: Since sanctions for non-compliance are applied at the national level, it is advisable to verify the specific sanctions regime applicable in Spain.

Official source

Consult complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602112