Assessing the impacts of a far-reaching deregulation of new GMOs on consumers’ choice, farmers’ autonomy and nature protection

On 5 July 2023, the European Commission is due to publish its legislative proposal for the new generation of GMOs (new GMOs, or so-called "new genomic techniques" or NGT). The proposal is expected to exclude new GMOs, such as products from CRISPR-Cas9, from the current EU legal framework for GMOs, which will exempt them from labelling requirements as well as safety checks and traceability processes.

While the European Commission has strongly promoted the supposed benefits of new GMOs to help transition towards more sustainable food systems, actual impacts of their far-reaching deregulation have not been properly evaluated by EU officials.

Friends of the Earth Europe made an analysis of the upcoming legislative proposal’s various impacts on the food supply chain, consumers and biodiversity.

Mute Schimpf, food campaigner at Friends of the Earth Europe said:

“The European Commission is choosing to put untested and hidden new GMOs into our fields and onto our plates. There are no legitimate reasons to trample the precautionary principle and sacrifice the right of consumers and farmers to know that they eat or sow. The Commission is falling for the deceptive lobbying campaign led by big agribusiness, instead of protecting its citizens’ best interests."

The European Commission assumes that regulatory barriers hinder corporations’ ability to  market new GM seeds, food and feed in Europe.

Fact check: In countries which have widely deregulated new GMOs, like Canada or the USA, two new GM seeds were grown for some years before seemingly being withdrawn from the market. Because of deregulation, no evidence can prove that failure, due to the lack of transparency surrounding those products. In third countries where regulatory barriers are lower than in the EU, new GM research and laboratory work has not materialised in the development of seeds ready to be grown or marketed either.  

Friends of the Earth Europe's conclusion: Lawmaking should be based on evidence and not on what economic stakeholders with vested interests have promised,[1] especially on products which are far from being market-ready.

The European Commission keeps quiet on the deregulation’s adverse impact on the entire food sector and consumers‘ right to know and opt for GMO-free choices.

Fact check: The issue of labelling new GMOs and how to label them, if at all, is of great significance for farmers, food processors, food retailers and consumers. Studies show that, as long as consumers have the information whether their food contains GMOs or not, they prefer to choose conventional, organic or GMO-free options.[2] The existing transparency and labelling rules for GMOs have resulted in a situation of far-reaching market rejection of GM food in the European Union. Whilst more than 60 GMOs are authorised to be imported to the EU as food and feed, supermarkets have phased them out since the early 2000s and any attempts to promote GM food have failed in the last 20 years.

Friends of the Earth Europe's conclusion: Without a demand for GMO products, many farmers will not buy new GM seeds, thus limiting the European market and global agribusiness corporations’ sales of those products. Excluding new GMOs from labelling is therefore meant to open new markets for already big agribusiness corporations, as it:
* removes traceability within the production chain;
* removes transparency for farmers, food producers, retailers;
* makes it impossible for consumers to know what they buy and take a well-informed decision;
* makes it impossible for national authorities to control food safety in regards to new GMOs.

The European Commission presents the majority of new GM plants as safe as conventional plants.

Fact check: New GMOs create specific new risks. The genome editing tool of CRISPR-Cas9 relies on complex repair mechanisms of the DNA. This repair process cannot be predicted. Its outcome can impact the interactions of molecules and cells[3][4] that may change vital traits such as the fitness of the plants and could impact how organisms act in ecosystems. If you don’t look for problems, you rarely find them until it is too late. Yet, of the €356 millions the European Union spent on new GMO research in the five years prior to the 2021 Commission study, just 1.6% were spent on detection methods, risk assessment and monitoring, the Commission found.[5]

Friends of the Earth Europe's conclusion: Releasing untested new GMOs into nature conflicts with the EU’s biodiversity strategy, which aims to better integrate nature considerations into public and business decision-making at all levels. GMO farming is part of a highly industrialised agricultural system that is one of the main drivers for biodiversity loss.[6] When drafting its proposal, the European Commission consulted with certain microbiologists but their expertise on nature impacts is narrow. Ecologist scientists should also be consulted  to properly assess how new GMOs  impact ecosystems and species.

The European Commission claims that new GMOs are needed for the European Green Deal and will contribute to adapt plants to extreme weather.

Fact check: Drought tolerant new GM plants are only a corporate promise so far. GMO science relies on predictability: editing a plant to respond one specific way in one specific context, based on one specific gene make-up. But building resilience to climate change means preparing for the opposite: rapidly changing climates, different soil conditions, and maximising diversity to ensure crop survival in the face of disease and disruption.

Friends of the Earth Europe's conclusion: Looking to gene technology for magical innovations that may or may not be developed in the future wastes time that we don’t have and just raises more questions and risks than it resolves. Agroecological farming techniques – which produce the majority of the world's food[7] – prioritise production adapted to local conditions and farming in balance with nature, and are the most efficient solutions to the climate crisis in the farming sector.[8]

The European Commission claims that new GMOs can’t be detected in seeds and food.

Fact check: Back in 2017, the European Commission already blocked the development of testing methods. As long as new GMOs are regulated as GMOs, companies that wish to market them are responsible for offering a testing method.[9] The plan of the Commission to allow marketing without any detection methods delivered by the biotech sector increases the economic pressure for conventional farmers and even more so for the organic sector. Those who do not want to use new GMOs will be left with the burden of taking the appropriate measures and tests to avoid contamination of their products. The Commission focuses on minimising costs for the biotech sector and ignores the economic impacts for all the other operators of the food supply chain.

Friends of the Earth Europe's conclusion: As for already existing GMOs, the new generation also comes with detection challenges which should not be disregarded. Such challenges can only be resolved with support of EU and national research programmes.

Notes

[1] https://amfep.org/_library/_files/Letter_to_Member_States_at_Scopaffs_-_April_2019.pdf

[2] Bundesinstitut für Risikobewertung (BfR): Durchführung von Fokusgruppen zur Wahrnehmung des Genome Editings (CRISPR/Cas9), 2017, Abschlussbericht. https://mobil.bfr.bund.de/cm/350/durchfuehrung-von-fokusgruppen-zur-wahrnehmung-des-genome-editings-crispr-cas9.pdf

[3] https://www.the-scientist.com/news-opinion/crispr-can-create-unwanted-duplications-during-knock-ins-67126

[4] Brinkman, D.K., Chen, T., de Haas, M., Holland, H.A, Akhtar, W., van Steensel, B. (2018) Kinetics and fidelity of the repair of Cas9-induced double-strand DNA breaks. Mol Cell 70:801-813, doi: 10.1016/j.molcel.2018.04.016

[5] https://food.ec.europa.eu/system/files/2021-04/gmo_mod-bio_ngt_eu-study.pdf

[6] https://www.ipbes.net/global-assessment

[7] FAO, 2014. The state of food and agriculture – innovation in family farming. Rome, http://www.fao.org/3/a-i4040e.pdf

[8] Leippert F, Darmaun M, Bernoux M and Mpheshea M. 2020. The potential of agroecology to build climate-resilient livelihoods and food systems. Rome. FAO and Biovision.

[9] “It was remarked that the ENGL could play a role in the discussion on detectability of new organisms generated with new techniques. SANTE explained that the ENGL is a very important network, but that the Commission decided to have a more open debate on this issue looking into the future from a broader perspective”. Minutes from ENGL meeting April 2017: http://gmo-crl.jrc.ec.europa.eu/ENGL/docs/ENGL-Plenary-27th.pdf


Source: Friends of the Earth Europe