General Quality Statement

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Genetic Modification and Orafti® chicory-derived fructans:

Statement with relevance to EU and US regulations

Scope
This statement refers to Orafti® inulin and oligofructose products that are derived from chicory as
indicated in their specification sheets. The chicory plant is the only agricultural raw material for their
inulin/oligofructose. LL types are pH-adjusted using a food-grade buffer.

It further refers to the provisions of the EU regulations that are relevant to GMO for food and feed
as defined in Art. 2 of Regulation (EC) No 1829/2003 on genetically modified food and feed and Art. 3
of Regulation (EC) No 1830/2003 concerning the traceability and labelling of genetically modified
organisms, and food and feed products produced from genetically modified organisms.

This statement thereby covers the definitions of "Genetic engineering" as "The genetic modification of
organisms by recombinant DNA techniques" of the United States 7 CFR § 340.1, "recombinant DNA
technology" as included in the definition of "Excluded methods" of 7 CFR § 205.2, namely "gene
deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when achieved by
recombinant DNA technology" as well as the definition of "bioengineered food" of 7 CFR § 66.1, namely
"(i) A food that contains genetic material that has been modified through in vitro recombinant deoxyribo-
nucleic acid (rDNA) techniques and for which the modification could not otherwise be obtained through
conventional breeding or found in nature".

Agronomic conditions
European Law obliges Member States to establish catalogues of varieties of agricultural plant
species accepted for certification and marketing in their territory (Directive 2002/53/EC). Plant
species must be evaluated prior to their respective listing. The evaluation of a variety also
addresses, whether it is a genetically modified variety within the scope of Directive 2001/18/EC.
When such genetically modification within the scope of said Directive is determined, the plant
variety itself as well as food and feed ingredients derived thereof are subject of authorisation,
labelling and traceability as laid down in Regulations (EC) No 1829/2003 and (EC) No 1830/2003
concerning food and feed derived from genetically modified organisms.

These general provisions are applicable to chicory varieties, too. The established mandatory
official catalogue for chicory varieties does not contain such GMO-based varieties. Enforcement is
controlled by the Ministries of Agriculture.
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Chicory growers delivering to BENEO-Orafti are obliged by contract to use only those seeds which
BENEO-Orafti supplies to them. These seeds are given them for free. The seed is exclusively
bought from the worldwide only chicory breeders - a French and a Belgium breeder who are bound
to European Law. These breeders have in addition a contract with BENEO-Orafti that prohibits the
provision with seeds falling under Directive 2001/18/EC on the deliberate release into the environment
of genetically modified organisms.
→ We can thus fully guarantee that no GM chicory plants considered to be within the scope of
Directive 2001/18/EC or obtained using recombinant DNA techniques are available at neither
production site of BENEO-Orafti that could be processed to fructans. Consequently, food and
feed products derived thereof are not affected by the applicable food and feed Regulation
(EC) No 1829/2003 and No 1830/2003. The chicory plants and the food and feeds derived
thereof are thus also not genetic engineered nor bioengineered within the meanings of 7
CFR § 340.1 resp. 7 CFR § 66.1.

Agronomic chicory processing

Chicory plants for Orafti® fructans are grown in Chile or Belgium; fructans are the carbohydrate
storage polymer in the root of the chicory plant; the leafy part of the plants is removed at harvest in
the field. Roots are transported to the local plants, washed, sliced and extracted. The obtained
"raw juice" is subjected to a liming/carbonation procedure to precipitate small soil and root particles
as well as non-fructan soluble root constituents. The precipitate is removed via filtration; the liquid
contains fructans (inulin) as well as still non-precipitated solutes; this semi-purified "raw inulin"
consists of about 85 % fructans on dry substance, is stable after drying and the starting (raw)
material for food-processing.

Under the conditions employed in agronomic processing, nucleic acids of any kind are largely
degraded.

Food processing
The food process to result in Orafti® oligofructose and Orafti® inulin is a complex refining scheme
starting with raw inulin that includes - depending on the end product - crystallisation or chromato-
graphy, controlled enzymatic hydrolysis, ultra-heat treatments, repeated ion exchange, activated
carbon and sterile filtration. The process takes place in closed systems; cross contamination with
other crops during food processing can be excluded. Such crops are also not processed in the
Orafti plants.
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As a result, Orafti® products are highly refined ingredients that consists almost completely of
carbohydrates apart from traces of ash and food-grade pH adjusters in Orafti®LL variants. Proteins,
fats and consequently also other plant cell components are limited to residues (see Product
Sheets).

Processing aids are mainly inorganic or surfactants that are not derived from GM sources.
Enzymes used for oligosaccharide production with the exemption of the production of Orafti®HSI
are not derived from GMOs within the scope of Directive 2009/41/EC on the contained use of
genetically modified micro-organisms or recombinant DNA techniques.1 The buffering substance in
Orafti®LL variants is not produced by genetically organisms.

In conclusion, BENEO-Orafti confirms that it processes only chicory roots that are not obtained by
genetic engineering nor by recombinant DNA techniques as described in US Code of Federal
Regulation 7 CFR § 340.1 and 7 CFR § 205.2, respectively.

Further, we confirm that our chicory-derived ingredients from both production sites and that we
supply to our customers do not consist in whole or part of GMOs as defined in Regulation (EC) No
1829/2003 and No 1830/2003 and as established at the time of their listing in the variety
catalogue. Provisions regarding GM authorisation, GM labelling nor GM traceability laid down in
said Regulations are thus not applicable. Orafti® products are thus not bioengineered foods in the
meaning of 7 CFR 66.1. As also cross-contamination is not realistic, DNA tests are not carried out.

BENEO will continue to only allow the growth of authorised chicory varieties by contracted farmers.
Should the GM/GE status of varieties and consequential food and feed derived thereof change, we
will inform our customers accordingly.

Stéphane Gustin Denis Vande Putte

BENEO Specification Manager† BENEO-Orafti Head of Quality

† This statement takes into account the European Court judgement of July 2018; it is valid on the date of issue until
31.12.2022.

1 The use of an enzyme produced by GMOs has no effect on labelling of Orafti®HSI.