1.Attacks on zero-tolerance based on misinformation
2.GM FEED IN THE EU: POLICIES AND PRINCIPLES
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1.Attacks on zero-tolerance based on lie

COMMENT by GM-free Ireland: Last week's article "Zero tolerance on GM feeds must go" in the UK Farmers' Weekly (see below) is a classic example of agri-biotech industry scaremongering about the EU food safety policy on contamination of the food chain with unapproved GM animal feed:

The claim that Brazil is "dominated by GM soy varieties" is a total lie.

Despite the economic crisis, Brazil's production of Non-GMO soybeans has boomed from 0.4 million tonnes in 2000 to 8.85m tonnes that were audited and available for certified crushing and shipment to Europe as part of the 2009 harvest which took place from February through May. Moreover, the recent trend of increased GM soy planting in Brazil has almost petered out, and may reverse in the 2009-2010 season as farmers find the disadvantages of planting GM soy outweigh its benefits.

This year (2009), roughly 26 million tonnes of Non-GM soy (i.e. 45 to 50% of Brazil's total soy harvest of 57.3m tonnes) was Non-GM. Although lack of demand led most of this Non-GM soy to be sold without segregation and traceability, some 10 million tonnes were produced within IP systems, certified GM-free below a detection limit of 0.01%, and were available for purchase by European buyers. Furthermore, 6.3m tonnes of this were additionally certified via the ProTerra standard as both Non-GMO and sustainable, and were sold and shipped as such (http://www.cert-id.eu/ProTerra.php ).

The claim that non-approved GMOs are "harmless" flies in the face of scientific evidence. For example:

"Effects of GMOs and pesticides systematically understimated CRIIGEN appeal to public authorities, July 2009
http://www.criigen.org/images/stories/pressrelease-ijbs_080709.pdf

Check-list of scientific papers on the health dangers of GM food and farming
http://www.gmfreeireland.org/health/studies.php

Advice for farmers

In view of the animal feed cartel's inability or refusal to provide Irish farmers with affordable supplies of legal GM and/or certified Non-GM soy feedstuffs, GM-free Ireland is advising farming organisations and feed buyers to organise themselves to source the material they need directly from suppliers in Brazil, India and China.

To secure price and availability for delivery in Spring 2010, buyers should place bulk orders via fixed cost frame contracts, preferably before the October planting in Brazil, or by December or January at the latest.

Useful contacts:

For reliable information on the availability and certification of Non-GM soy  products:

Cert-ID Europe Ltd / Proterra
Middleton, Staffordshire, UK
tel + 44 (0) 1827 874 849
email: This email address is being protected from spambots. You need JavaScript enabled to view it.
http://www.cert-id.eu

ABRANGE
Brazilian Association of Non Genetically Modified Grain Producers
Sao Paolo, Brazil
tel + 55 11 2892 7101
email: This email address is being protected from spambots. You need JavaScript enabled to view it.
http://www.abrange.org

For questions of availability and general market information on Non-GM soy  products:

Jochen Koester
TraceConsult
Geneva, Switzerland
tel + 41 22 819 1729
email: This email address is being protected from spambots. You need JavaScript enabled to view it.
www.traceconsult.ch
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ZERO TOLERANCE ON GM FEEDS MUST GO
By Philip Clarke
Farmers Weekly, 19 August 2009
http://www.fwi.co.uk/blogs/agribusiness/2009/08/zero-tolerance-on-gm-feeds-must-go.html

At last the political pressure seems to be building to do away with the EU's ridiculous rules that outlaw any feedstuffs that contains even a trace of a non-approved GM product.

Just two weeks ago, a cargo of US soymeal was turned away by importers in Spain, following the discovery of traces of an unapproved GM maize variety. And further consignments had to be recalled in Germany.

The EU's highly convoluted approvals process means that the waiting list of GM products is increasing all the time. And is it grows, so does the risk of contamination with non-EU approved soya or maize.

This week's report from DEFRA and the Food Standards Agency sums up the problem well. It points to the fact that Brazil and Argentina currently supply 90% of the UK's soya market, and these two countries are dominated by GM varieties - over 90% in the case of Argentina....

Currently they only cultivate varieties that are approved for use in the EU. But patience is wearing thin and Argentina could soon start approving non-EU approved varieties too.

According to the DEFRA study, under a worst case scenario, where there were no soya imports from either Argentina or Brazil, there would be a 300% major increase in feed costs, a "significant" reduction in pig and poultry production and a marked increase (10-20%) in meat prices.

While these are, by admission, extreme figures, they highlight the problem. Even without contamination, sourcing GM-free soya can cost anything between $5/t and $80/t more than a GM alternative.

Fortunately, there seems to be some momentum building in Brussels to change these rules. EU agriculture commissioner Mariann Fischer Boel recently said she was "deeply concerned" about the threat to the EU livestock sector of not being able to source competitive feed. It was almost impossible to avoid some form of GM contamination, as the crops are now so widely grown, she added.

And, while proposals to deal with the issue have been held up in the EU's food safety directorate for many months, the expectation is that they will now see the light of day when Brussels goes back to work in September. It is rumoured they may even go to the EU agriculture council on 7 September.

As with anything to do with GM crops, they are likely to split opinion between member states.

But, from a purely practical point of view, steps must be taken urgently to allow at least a degree of "adventitious presence" of non-approved GMs, without the cost and waste of banning such harmless consignments from the EU food chain.

Source: Farmers Weekly Interactive [UK]
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2.GM FEED IN THE EU: POLICIES AND PRINCIPLES

COMMENT by GM-free Ireland: The article falsely implies that the so-called "asynchronous approval" of GM crops between the USA and the EU is simply a matter of timing. This is not so.

USFDA classifies new GM food, feed and crops as GRAS (Generally Recognized as Safe), and thus "deregulates" their placing on the market on the say-so of the applicant companies by rubberstamping their approval with virtually no oversight, no labelling, no traceability - and thus no possibility of epidemiological studies, and no liability!

The EU has a more responsible approach: new GM products require a positive risk assessment opinion from EFSA, followed by approval by the Council of Ministers or the Commission, and must be labelled to inform consumers (although a giant loophole still allows meat, poultry, fish and dairy produce from livestock fed on GM animal feed to be placed on the market without a GM label). The EU's leading retailers and food brands refuse to sell GM-labelled food, and voluntary GM-free labels for such animal produce are now used in Austria, France, Italy, Germany, Switzerland and other countries.

The implication that most new US GM products will eventually be approved in the EU - and that the problem is only a matter of asynchronous timing - is utterly deceitful.

Moreover, the claim that EFSA "has the final say in what can and cannot be imported into the EU" is absolutely false. EFSA only provides an opinion, but the Council of Ministers or the European Commission decides. For details see our interview with former EFSA Chair Prof Patrick Wall at http://www.gmfreeireland.org/efsa/index.php

That said, EFSA's risk assessment protocol for the safety of GM feed and food is widely regarded as a farce, because it relies on secret data provided by the applicant companies, prevents transparent peer review, fails to consider the eco-social impacts, and regularly downplays or ignores the opinions and warnings raised by independent scientists and member states. The Council of Ministers recognises this and has told EFSA to stop giving positive opinions on new GM products until such time as it is prepared to exercise due diligence.

Needless to say, the article also fails to mention the growing body of peer-reviewed scientific litterature on the health dangers of GM feed and food. For example:

Effects of GMOs and pesticides systematically understimated

CRIIGEN appeal to public authorities
Committee of Independent Research and Information on Genetic Engineering, July    2009:
http://www.criigen.org/images/stories/pressrelease-ijbs_080709.pdf

Check-list of scientific papers on the health dangers of GM food and farming:
http://www.gmfreeireland.org/health/studies.php
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GM FEED IN THE EU: POLICIES AND PRINCIPLES
The Cattle Site, 23 August 2009
http://www.thecattlesite.com/articles/2100/gm-feed-in-the-eu-policies-and-principles

As the price of non-GM feed soars, the European meat industry - bound by strict regulations - struggles to compete both in global and domestic markets, writes Adam Anson, TheCattleSite.

The Evolving Situation of Global GM Markets

Fuelled by high demand and cheap production costs, many varieties of genetically modified (GM) crops are thriving in demand. Engineered to be hardier in the presence of poor conditions, stronger in the fight against disease and more resilient against the threat of insects, for many, GM crop varieties are an obvious choice.

Many critics have objected to GM food on several grounds, including perceived safety issues, ecological concerns, and economic concerns, yet the growth of this new market has expanded exponentially since it was first conceived in 1994. GM feeds were developed soon thereafter and for many countries became a more economical replacement for non-GM feed.

However, the EU has applied stringent regulations on GM feed, forcing EU livestock producers to continue buying the evermore expensive non-GM feed. Passing the buck from farmer to consumer is not always possible as domestic meat products already face stiff competition from foreign countries which accept the use of GM feed.

Many farmers argue that by the time their products reach the supermarket shelves they are already too expensive. In the money-conscious aftermath of the recent recession, demand for the higher-priced European product is further weakened.

Trends and Scenarios

In response to further concerns raised in the UK government's Food Matters report, published in July 2008, the UK Department for Environment, Food and Rural Affairs, in conjunction with the the UK Food Standards Agency recently produced a follow-up report examining the potential scenarios and impacts of European GM policies.

The report reflects concerns that the rate of EU approvals for GM products, coupled with the absence of any tolerance for low levels of unauthorised GM material, could prejudice UK food and feed imports. Also, the report produced an analysis of the extent to which changes in the market are putting a strain on the regulatory system for GM products (including animal feed) and the implications for UK consumers.

Of particular concern, the report identified the threat of a situation known as 'asynchronous approval'. This occurs when significant GM producers (USA, Brazil, Argentina) authorise and cultivate new types of GM crop before they are cleared for EU import.

"Where a non-EU authorised GM crop is grown, there is potential for an adventitious presence of this crop to arise which may disrupt imports of that commodity from the country concerned, both non-GM (conventional) and EU-approved GM varieties," says the report. But, counter to the threat of asynchronous approval runs the belief that Brazil and Argentina will not adopt new strains before they are approved by the EU.

However, the report also notes China's rapidly growing demand for GM feed. With an established Chinese market, EU demand will no longer dictate what kind of feed these countries produce. Concerns arise because the UK is currently dependent on soya feed from Brazil and Argentina. 90 per cent of UK feed comes from companies in these regions, totalling three million tonnes over 2007/2008. However, the current trend of these feed producers is towards the GM market. Already, 94 per cent of Argentinean soya is GM and in Brazil that figure is 65 per cent and quickly rising. There is also a risk that as a new GM soya variety is used in the US it might lead to trace levels being detected in supplies from other countries.

The premium for non-GM feed can vary greatly, between US$5 a tonne and US$80 a tonne. Currently, the cost of maintaining these non-GM feed supplies is absorbed by the meat industry, but back in November 2008, it was considered that the premium for non-GM feed for UK agriculture could rise from £24 million to £45 million per year.

Such a rise may have a disastrous impact on UK livestock farmers. As there is no legal requirement for labelling meat produced with GM-feed accordingly, consumers can find it difficult to differentiate between GM and non-GM products. The possible economical benefits of non-GM production is thereby often lost.

The Next Step

The Defra/FSA report makes it clear that that despite of the current problems they remain in favour of a strict and robust set of EU regulations. However, the pace at which GM feeds are evaluated by the European Food Safety Authority (EFSA) - which has the final say in what can and cannot be imported into the EU - could be hampered by unsatisfactory and over-stretched resources, suggests the report. A greater investment in this area would quicken inspections of new GM products and eliminate the threat of asynchronous approval.

The report also questions the idea of a 'technical solution', which would allow a low presence of unauthorised GM feeds to pass through regulation in the event of contamination. This suggestion flies in the face of EU's current zero tolerance approach to GM food. The report argues that it would fail to protect the consumer from non-GM food and may lead to a consumer backlash. Such a scenario would raise media attention and public awareness of other GM products currently available in the EU.

European citizens are highly sensitive to GM development in all sectors. Environmental claims lie on either side of the argument, as do humanitarian ones. Many are concerned that by accepting GM feed in EU markets they are effectively kow-towing to the demands of biotechnology companies, which dominate the GM market with limited competition. Such sectors lead to monopolisation - as the saying goes: absolute power corrupts absolutely. Critics fear that any gifts that farmers may garner from GM feed may be taken back once the market is globally established.

The EU Commission was recently assigned to look into the matter of GM feed in Europe in further detail. Evaluation began in April 2009 and will be finished 12 months later.