Handler Compliance Plan - NGP

9191 Towne Centre Drive, Suite 200 San Diego, CA 92122
NON-GMO PROJECT HANDLER COMPLIANCE PLAN

Under the Non-GMO Project Program Policies, any production or handling operation seeking certification to sell,
label or otherwise represent goods with any Non-GMO Project Verified claim must develop a Non-GMO
compliance plan that is approved by NSF. Any changes you make to your Non-GMO compliance plan need to be
documented and approved by NSF prior to implementation.
Physical Location Name :Aceites Especiales TH SA deCV

Physical Address: Eje Norte Sur 451
City: Morelia. State/Province: Morelia Zip/Postal: 58200 Country: Michoacan
Contact Person at Location Eddy Ruiz Alegria/ Alejandro Lopez Anaya
Phone No. 443-471-14-21/443-337-01-34 Fax No. E-Mail Eruiz@aeth.mx/alopez@aeth.mx
Name of Primary Participant (P.P.) Eddy Ruiz Alegria Date
You will also be asked to complete and attach additional NSF documents to verify product, procedure, and input
compliance as applicable. If you find a question is not applicable to your operation, please clearly indicate this in
the space provided after the question with explanation. If needed for clarity, please provide further explanation in
Section G.
Please be advised that if an inspection is required, it must occur when the facilities and activities that demonstrate
compliance, or the ability to comply, can be observed.
A) Non-GMO Project Compliance Plan Overview

1. Please attach an accurate flow chart that documents movement of product within your facility. Be
sure to include all steps of Non-GMO Project Verified handling and processing, and the names of all
processing equipment.
The chart should indicate each of the steps in the handling of Non-GMO Project Verified products from
the receipt of ingredients through processing to release of custody of finished goods. If desired, you
may also attach a facility map to clarify processes involved.
Attached Not attached, please explain:
Se anexa diagram de flujo de los procesos de extraccion por pensa y solventes de los
granos de Oleaginosas.

2. For all products seeking Non-GMO Project Verification, please attach completed, current Profile
forms. Profile forms should include Product Formula Sheets, Single Ingredient Product List, Input Supplier
List, and color labels – as applicable.
Handler verification may be applicable for several activities including processing, repacking, and
distributing. NSF has created Non-GMO Project Profile forms to make it easier for participants to identify
the products, inputs, and ingredients seeking Non-GMO Project Verification.
Este punto para nosotros no aplica ya que todo se vende como producto crudo y
agranel. Es decir no va a un consumidor final.

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016
This is a confidential document and may be reproduced only with the permission of NSF International. Page 1 of 12

3. Please provide a description of practices and procedures.

Include the estimated frequency of anticipated production runs. Please be sure to include descriptions and
frequencies for both Non-GMO Project Verified production and non-verified (conventional) production.
Provide a general overview of the activities and processes your operation conducts. Discuss production
activities, as well as the volume and frequency of production. You may reference your flow chart as
applicable.
Describe here:

4. Please provide a description of your monitoring procedures as they pertain to ensuring that your Non-
GMO Project Compliance Plan is followed and Non-GMO integrity is maintained at every step in your
process.
Please provide a description of how, and how often, you will review your Non-GMO Project
Compliance Plan to ensure that it is being implemented effectively. This is not what is done day-to-day.
Rather this is the description of the general internal quality review, and how often it will be performed; to
ensure the Non-GMO integrity of ingredients, inputs, and products is being maintained with the systems
in place.
Describe here:

5. Do you have a procedure for documenting and addressing complaints relating to compliance with the
Non-GMO Project Standard?
Yes No, please explain:

B) Approval of Co-Packer(s)
1. Please provide a list of the operations seeking co-packer approval.
For each co-packer, be sure to include the following information:
- Co-Packer Name
- Address
- List of the Products Manufactured by Each Co-packer
Any manufactured product that is made by an operation contracted by the Participant may be evaluated
and approved under the PVP as long as it is a product of a system that has been designed to avoid
GMOs. Examples of such systems are organic certification and other identity preservation systems. All
such systems are subject to review by the Technical Administrator, especially in cases where parallel
processing occurs within the certified system.
Non-GMO Project Standard

For your convenience, please feel free to use the Non-GMO Project Brand Owner Co-Packer List. A similar
document in your own format is also acceptable.

2. For each Co-Packer seeking approval, please attach documentation, which demonstrates that
products seeking Non-GMO Project Verification are produced from a system that has been designed
to avoid GMOs.
Examples of such systems are organic certification and other identity preservation systems.
Any manufactured product that is made by an operation contracted by the Participant may be evaluated
and approved under the PVP as long as it is a product of a system that has been designed to avoid
GMOs.

3. For each Co-Packer seeking approval, is there a contractual relationship between the Brand
Owner (Participant) and the co-packer?
The Non-GMO Project acknowledges pre-existing contractual agreements between certain

Participants (e.g., brand owners) and their contracted processors. Thus, enables Participants who
manufacture their products in contracted facilities (also known as co-packers or coprocessors) to more
quickly enter the Program.


4. Unless the product is being co-packed in a facility that is dedicated to certified organic
production and no parallel processing of High-Risk Ingredients is occurring in the facility, the Co-
Packer’s exemption from inspection expires after three years. After that point, the Brand Owner
must EITHER:
a. Adopt a defined plan (timeline and agreement in place) for bringing contracted operations into full
participation in the –Product Verification Program and full standard compliance; OR
b. Submit to a facility survey and onsite inspection for contracted operations. Such inspection shall be
completed by an inspector approved by the Non-GMO Project.
Non-GMO Project Standard.

C) Traceability
1. Please describe the individual elements of your record keeping system established to track
ingredients and products by identity and volume from purchase and receiving through distribution or sale.
Each lot of Non-GMO Project Verified product or input must be traceable back to specific lots of the
inputs used in its production.
Describe the types of documents used in your audit trail system. Be sure to include a description of the
individual elements that make up your record keeping system used to track your product from purchase
to sale. Be sure to include the specific names and descriptions of each paper document and/or
computer-based document.
Describe here:

2. Are the records pertaining to your operation maintained on-site and organized in a manner that
can be fully audited and available on-site for inspection during regular business hours?
The producer/manufacturer must be prepared to provide the Technical Administrator of the Program
with traceability information.
The appropriate personnel must be available during the inspection, as applicable, to grant access to
the required documents (e.g. accounting, management, etc.). NSF recognizes that great diversity
exists among Non-GMO participants and that a wide variety of record keeping systems may
demonstrate compliance with the protocol. In addition to verifying records on-site, sample copies of
relevant records may be collected at the inspection to allow NSF to verify compliance with the Non-
GMO Project Standard.


3. Please indicate the types of activities for which you maintain consistent documentation allowing
the auditing of Non-GMO Project Verified goods while they are in your custody.
Check all that apply.
Systematic procedures shall be in place for tracking lot numbers and/or marking and labeling of
packaging, containers, and storage facilities to assure traceability of inputs, work-in-progress, and final
products at all points in the production process.
There should be a system in place for ensuring a clear and coherent audit trail, such as linking lot
numbers from one document to the next. You must be able to account for quantities of all finished Non-
GMO products sold and in inventory, and quantities of Non-GMO ingredients received and used in
manufacturing.
Production & processing Physical or running inventory Lot coding

Ingredient receipt Ingredient purchase Product sales
Shipping & distribution Verification of Non-GMO inputs Input testing
Other:

4. If you use contracted storage facilities for ingredients and/or WIP (work-in-progress), do you maintain
affidavits or documentation confirming the storage facility protects the Non-GMO integrity of
goods in storage?
Storage facilities that receive product in enclosed packages, and do not repackage, re-label, or process
the product further, are not required to be verified. However, the verified participant must ensure that
the integrity of the inputs, ingredients, and finished products are maintained during storage at non-
verified facilities. Measures must be in place that would prevent the Non-GMO integrity of the products
from being compromised.
Yes, Non-GMO Warehouse Affidavit or other documentation is maintained

Not applicable, no contracted non-verified storage No, please explain:


5. Do you maintain all Non-GMO Project records for a minimum of three years?
If your operation is less than three years old, you must have a plan in place to comply with this
requirement.

D) Input/Ingredient Compliance Verification

1. For all ingredients / inputs to be used in products seeking Non-GMO Project Verification, please
attach a current Input Supplier List. Be sure to list all major, minor, and micro ingredients, any
packaging that is immersed or combined with liquid as part of preparation for human consumption (e.g. tea
bags), as well as any processing aids used in products seeking Non-GMO Project Verification.
The intent of the program is for the Participant to design production processes and input specifications
that exclude GMOs from the Participant’s products. This not only requires that one use inputs that are
compliant with the Non-GMO Project Standard, but also that one employ practices that control
unintentional contamination with GM material.


2. For each high-risk input used as a major ingredient in products seeking Non-GMO Project verification,
please identify how Non-GMO input compliance is demonstrated. Check all that apply.
Participants shall undertake preventative measures to assure the Non-GMO Project Standard
compliance of High-Risk Inputs.
Non-GMO Project Verification via Certificate of Compliance or Non GMO Project Web-listing
Incoming Inputs Accompanied by Non-GMO Test Reports and Compliant Sampling Plan
Incoming Inputs are Tested for Non-GMO Status upon Receipt.
Other:

3. For each of the following types of high-risk input, please identify how Non-GMO input compliance
is demonstrated. Check all that apply.
a. High-Risk input downgraded to Low-Risk status, such as a crop grown in a country GMOs are
prohibited, Non-GMO Project Standard compliant seed was verified as having been used, and
documented identity preservation procedures are in place for the manufacturing and transport of the
product.
On a case-by-case basis, certain High-Risk inputs may be downgraded to Low-Risk

status based on source, documentation, protocols for contamination prevention/avoidance,
and/or laboratories results (in accordance with the Non-GMO Project Standard) demonstrating
consistently low risk of GMO contamination.
b. High-Risk input used as ONLY minor or micro ingredient in products seeking Non-GMO Project
Verification.
In cases where GMO analytical certificates or traceability linked to analytical certificates of

precursors is not available Non-GMO Project compliant status of Minor or Micro Ingredients
may be verified based on affidavits from suppliers, as long as these ingredients are the
product of a system that has been designed to avoid GMOs.
Non-GMO Project Verification via Certificate of Compliance or Non GMO Project Web-listing
Incoming Inputs Accompanied by Non-GMO Test Reports
Incoming Inputs are Tested for Non-GMO Status upon Receipt
Specification Sheets, which Verify Absence of High-Risk Ingredients
Non-GMO Project Compliance Affidavit
Other:


4. For each low-risk input used in the production of products seeking Non-GMO Verification, have you
verified the following?
Preventative measures for Low-Risk Inputs consist of: Examining the specification sheet for compound
ingredients to verify absence of high-risk ingredients.
Specification Sheets, which confirm absence of High-Risk Ingredients

No, please explain:

E) Product Protection, Cleanout, and Segregation

1. Do you handle high-risk ingredients/inputs in your facility? Select ALL that apply.
Please see Appendix B of the Non-GMO Project Standard for a list of High-Risk Crops, Processed/
Processing Inputs, Production Inputs, and other Organisms with GMO Risk. These inputs carry risk of
being genetically engineered.
Non-GMO Project Standard – Appendix B
Yes, high-risk inputs are used as ingredient(s) in products seeking Non-GMO Project Verification.
Yes, high-risk inputs are used as ingredient(s) in non-verified (conventional) products.
No, high-risk inputs are not handled at this facility.
If yes, please list high risk inputs used in non-verified products:

2. If you have high-risk input/ingredients in your facility, do you have dedicated lines for producing Non-
GMO Project Verified products?
If the operation is not dedicated to Non-GMO Project verified production, systematic procedures shall
be in place to keep Program verified inputs, work-in-progress, and finished products separate from
materials that are not compliant with the Non-GMO Project Standard.
Yes, lines are dedicated. n/a All products in facility will be Non-GMO Project verified
No, lines are not dedicated. n/a No high-risk ingredients in facility
If no, please explain the measures in place to prevent contamination from high-risk or GM inputs between
non-verified (conventional) and Non-GMO Project production runs:


3. If lines are not dedicated, what sanitation and cleaning measures are in place to prevent
contamination of Non-GMO Project compliant inputs, products, and food contact surfaces by high-risk
and/or GM-containing substances during handling activities? Check all that apply.
When using non-verified or GM containing inputs in the facility, care must be taken to prevent contact
with Non-GMO compliant inputs and products. Preventive measures should be verified at every step in
your process from receiving, through processing to storage and final distribution.
n/a – Lines are dedicated Product remains in non-permeable packaging

Rinse prior to Non-GMO Project runs Clean/Sanitize prior to Non-GMO Project runs
Purge prior to Non-GMO Product runs Documented employee training
Other:

4. Which of the following details does your sanitation log include? Check all that apply.
A sanitation log is one method for demonstrating that sanitation procedures are consistently applied.
Please identify the components of your sanitation log or describe the procedures used for ensuring
sanitation is adequate and consistent.
n/a – Lines are dedicated Schedule Materials used

Procedures used Signature line Equipment cleaned/purged
Sanitation Log is not used, other documented procedures in place as described here:

5. What management practices and/or physical measures are in place to prevent commingling of Non-
GMO Project Verified and non-verified (conventional) or GM inputs / products during handling?
Check all that apply.
Additional segregation measures for Non-GMO Project Standard compliant materials may be
necessary, especially when any high-risk inputs are handled. Segregation is also necessary between
distinct lots of goods that are Non-GMO Project verified, versus inputs or products that are not
explicitly verified or included in the program as such.
In operations handling Non-GMO and non-verified or GM containing inputs, there may be several
opportunities for accidental commingling to occur. Preventive measures should be verified at every
step in your process from receiving, through processing, to storage and final distribution.
Handle Only Non-GMO Compliant Inputs Impermeable Packaging

Verification of Non-GMO Status at Receiving Tagged Lockouts
Dedicated Processing Equipment Color Coding
Clean/Sanitize Prior To Non-GMO Runs Lot Coding
Dedicated Storage for Non-GMO Compliant Inputs Documented Employee Training
Clearly Identified Non-GMO Designations
Other:


6. What measures are in place to prevent cross contamination of Non-GMO ingredients, products and
packaging by GM products during transport? Check all that apply.
Receiving, production, processing, manufacturing, transfer, and storage facilities, as well as shipping
and transportation conveyances, shall be inspected and cleaned/purged as needed to remove sources
of GMO contamination, and all relevant cleaning, purging, and inspections shall be documented.
When Non-GMO goods are stored in permeable packaging, bulk tanks, bins, hoppers, or other open
containers while in transport, care must be taken to protect the integrity of the Non-GMO goods.
Segregated transport Physical barriers

Impermeable packaging Clear product identity
Inspecting transport units prior to loading Documented complete cleanout
Inspecting transport units prior to receipt Documented employee training
Use of Clean Truck Affidavits
n/a – All incoming inputs are tested for non-GM status upon receipt.
Other:

7. If you use any high risk input(s) at a major amount (5% or more when water & salt are excluded) in any
formula, are there similar inputs handled on site? (e.g. high risk major “Bob’s Soy Protein Powder 1X” is in
use as a high risk major input for verified product & facility also handles and “Jane’s Soy Protein Powder”
though Jane’s is not for use in verified product)
Yes, this situation applies to my facility & supply
No, this situation does not apply to my facility & supply
F) Product Testing Protocol and Procedures

1. Please indicate whether or not you use a genetic testing program in your facility.
A statistically valid sampling and testing plan shall be designed on the basis of risk assessment of the
production/handling system and shall reflect the level of monitoring appropriate for the risks inherent
in the production/handling system, as well as industry standards.

2. If an internal genetic testing program is in place, please indicate the components of the testing
program used to verify the Non-GMO status of incoming high-risk inputs.
Ongoing testing is required for all GMO risk ingredients. The program is a process-based verification
designed to employ testing as a best practice at the most efficient point in the production chain.
Typically, this is where ingredients are least processed and consolidated in the largest amounts, for
example, during initial processing. From there, traceability and segregation ensure that the tested
ingredient maintains its purity.
Non-GMO Project FAQs

Statistically Valid Sampling and Testing Plan* ISO17025 Accredited Lab*

Samples with Sufficiently Intact DNA* Lateral Flow Strip Tests
Test Results with 90% Confidence Interval*
Qualitative Real-Time PCR Tests with a 0.01% detection limit
Quantitative Real-Time PCR Tests
Quantitative Digital PCR Tests
*Required for all GMO testing
Other:

3. Please describe the quality management system in place to investigate the cause of the contamination
and the corrective measure, if the genetic test results exceed the GMO Action Threshold identified in
section V. A. of the Non-GMO Project Standard?
Action Threshold:
- Seed/propagation materials from crops with GMO risk (as per Appendix B) – 0.25%
- Human food, ingredients, supplements, personal care products, and other products that are
either ingested or used directly on skin – 0.9%*
- Animal feed and supplements – 5%**
- Packaging, cleaning products, textiles and other products that are not ingested or used directly on
skin 1.5%
* For seed of species not listed in Appendix B, and for all species not listed in Appendix B or C,
there is no allowable presence.
** This Action Threshold is based on the annual average of all lots tested.
A key requirement of such quality management systems is to establish an Action Threshold, which, if
exceeded, triggers the Participant to investigate the cause of the contamination, and to correct that
cause when identified. Inputs contaminated above the action thresholds may not be intentionally
used.

G) Applicant Explanations Section

Use the space below to explain your responses as needed for clarity.



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9191 Towne Centre Drive, Suite 200 San Diego, CA 92122

NON-GMO PROJECT HANDLER COMPLIANCE PLAN

Physical Location Name :Aceites Especiales TH SA deCV

A) Non-GMO Project Compliance Plan Overview

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

3. Please provide a description of practices and procedures.

Yes No, please explain:

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

Attached Not attached, please explain:

The Non-GMO Project acknowledges pre-existing contractual agreements between certain

Yes No, please explain:

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

Attached Not attached, please explain:

Yes No, please explain:

Production & processing Physical or running inventory Lot coding

Yes, Non-GMO Warehouse Affidavit or other documentation is maintained

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

Yes No, please explain:

D) Input/Ingredient Compliance Verification

Attached Not attached, please explain:

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

On a case-by-case basis, certain High-Risk inputs may be downgraded to Low-Risk

In cases where GMO analytical certificates or traceability linked to analytical certificates of

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

Specification Sheets, which confirm absence of High-Risk Ingredients

E) Product Protection, Cleanout, and Segregation

If yes, please list high risk inputs used in non-verified products:

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

n/a – Lines are dedicated Product remains in non-permeable packaging

n/a – Lines are dedicated Schedule Materials used

Handle Only Non-GMO Compliant Inputs Impermeable Packaging

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

Segregated transport Physical barriers

F) Product Testing Protocol and Procedures

Yes No, please explain:

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

Statistically Valid Sampling and Testing Plan* ISO17025 Accredited Lab*

G) Applicant Explanations Section

AESOP 13346; ISSUE 5; STATUS-PUBLISHED; EFFECTIVE 18 MAY 2016

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