Updated October 2026: This article has been revised to clarify that GMO detection in cotton does not by itself establish the source, cause, intent, or percentage of GMO cotton present. Organic and textile certification decisions depend on investigation, documentation, traceability, sampling protocols, and compliance with applicable standards.
As the Extension Organic Specialist with Texas A&M AgriLife Extension Service, I work closely with organic cotton farmers to navigate the complexities of maintaining organic certification. Recently, issues surrounding the sourcing and certification of organic cotton seed have come to the forefront, particularly with the influx of imported planting seed from other countries. This situation is complicated by Global Organic Textile Standard (GOTS) requirements, differences in testing and interpretation, and the growing use of imported planting seed.

Key Issues with GOTS and Organic Cotton Seed
Contamination Risks
GOTS certifies cotton fiber from the gin facility to the mill but does not extend this certification back to planting cotton seed. This poses a significant risk for farmers, as even with rigorous adherence to organic practices, their crops can become contaminated through cross-pollination, especially in regions like the cotton belt where GMO crops are prevalent. A positive GMO screening result can jeopardize acceptance of cotton into a particular textile supply chain and can trigger additional investigation. However, under USDA organic policy, inadvertent GMO presence does not by itself establish that the producer used an excluded method or violated organic certification requirements. Upstream seed testing is not an untested concept. Organic Cotton Accelerator protocols already recognize planting-seed testing before distribution as an important GMO control point.1 Expanding that principle could give U.S. organic producers stronger documentation that the crop began with verified non-GMO planting material.
Lack of Standardized GMO Thresholds
Currently, GOTS does not establish a GMO contamination threshold for cotton seed, which complicates the situation for organic cotton farmers. While U.S. cotton seed companies may use internal quality-control standards to limit unintended GMO presence, GOTS does not establish a numeric GMO threshold for cotton. This creates uncertainty when a positive screening result is detected later in the textile supply chain. DNA-based GMO testing is most straightforward when biological material containing recoverable DNA is available, particularly planting seed and seed cotton. Mature cotton lint presents greater analytical limitations. Current testing protocols can screen cotton materials for GM-associated DNA, but a positive qualitative result does not by itself establish the percentage, source, or cause of GMO presence. This is particularly important in cotton-growing regions where organic and GMO cotton are produced in close proximity. Pollen movement, harvesting equipment, module handling, transportation, storage, and ginning all represent possible points where unintended GMO material may enter the supply chain. For that reason, the organic cotton industry needs standardized sampling procedures, laboratory methods, reporting practices, and interpretation guidelines that distinguish intentional use of excluded methods from inadvertent presence.
To address these challenges
A multi-faceted approach involving key industry stakeholders is essential. Here’s how we can move forward:
Establish Clear Planting-Seed Testing and Acceptance Standards
The organic cotton industry would benefit from a clearly defined planting-seed testing protocol that specifies sampling procedures, laboratory methods, reporting limits, and how results are interpreted. If numeric acceptance criteria are used, they should be scientifically justified, transparent, and applied consistently.
Improve Traceability Throughout the Supply Chain
Farmers, seed companies, ginners, certifiers, laboratories, textile manufacturers, researchers, and Extension specialists should work together to identify critical control points where unintended GMO material may enter the system. Clear documentation at each stage—from planting seed through harvest, transport, storage, ginning, and textile processing—would make investigations more meaningful and help determine where a problem may have occurred.
Develop Fair and Scientifically Defensible Interpretation Policies
Certification and textile programs should distinguish between intentional use of excluded methods and inadvertent GMO presence. Decisions should consider sampling methods, laboratory limitations, traceability records, seed documentation, and possible contamination pathways rather than relying on a single positive screening result alone. Upfront planting-seed testing could provide farmers and gins with stronger documentation and greater confidence throughout the supply chain.

Addressing Import Issues
The reliance on non-GMO cotton planting seed imported from other countries can help address seed availability, but it also introduces additional supply-chain and quality-control considerations. Imported planting seed should be subject to testing and documentation requirements comparable to those expected of domestically produced non-GMO seed. Standardized sampling, laboratory methods, and reporting would improve transparency, reduce uncertainty for growers and buyers, and help create a more consistent standard regardless of seed origin.
Conclusion
The organic cotton industry needs a system that protects organic integrity without holding farmers responsible for contamination pathways they cannot fully control. Standardized planting-seed testing, better traceability, consistent laboratory interpretation, and fair investigation procedures would strengthen confidence from the farm through the textile supply chain.
- Organic Cotton Accelerator. 2024. Standard Operating Procedure for GMO Sampling and Testing. Organic Cotton Accelerator. ↩︎












