Study "does not comply with some of the Commission’s own standards" – and its claim that some new GM products could improve sustainability is "hypothetical"

The German Federal Agency for Nature Conservation has commissioned and published an expert opinion on the original EU Commission DG SANTE paper from 2021 on new GM techniques that set the Commission on the deregulation path.

The expert opinion represents a damning critique of the Commission's study, saying it does not comply with some of the Commission’s own standards, fails to address the unintended effects of new GM techniques, and relies on "hypothetical" claims that some new GM products could improve sustainability.

The main findings are:

* The Commission's study is not a study in the proper sense. There are significant methodological weaknesses. The study does not systematically analyse the state of research and does not make transparent the criteria for evaluating the material on which it is based, but merely summarises it. Its conclusions appear arbitrary and are not based on a systematic analysis.

* The study does not comply with some of the Commission’s own standards. The Better Regulations Guidelines stipulate that stakeholders must be carefully selected to ensure that all interested parties have their views represented. However, proponents of new GM techniques (new genomic techniques or NGTs) are overrepresented in the COM study.

* Opinion is not differentiated from evidence. Statements and opinions by stakeholders and Member States are placed on equal footing with findings from empirical studies regarding these facts.

* The study does not make sufficiently clear how it deals with deviating views/statements/positions of Member States and stakeholders.

* Special features of the new GM techniques are not dealt with, e.g. that new GM techniques can modify areas of plant genomes that are not accessible to other methods.

* Unintended effects of new GM applications are not sufficiently considered by the Commission's study – regardless of whether they result from intentional or unintentional changes.

* The Commission's study pays particular attention to the question as to what extent new GM crops can contribute to achieving the goals of the European Green Deal and related policies, including the EU’s Biodiversity Strategy, the Farm to Fork Strategy, and the UN Sustainable Development Goals. Several new GM plant products were identified that the Commission says could contribute to the Green Deal and related policies, but all this remains hypothetical.

* As a consequence of possible deregulation, various protected goods come under threat. These include GM-free goods and certain ecologically sensitive areas. Also, the polluter pays principle could be violated. Accordingly, the expert opinion formulates options for action that focus on these protected goods.

Overall, the expert opinion is a comprehensive and accessible deconstruction of the Commission's document, which GMWatch has always considered does not deserve the name of a "study" but is rather a wish-list adopted from the GMO industry and its lobbyists.