Greenpeace Australia Pacific Ltd | Level 4, 39 Liverpool Street | Sydney NSW
Submission to the NSW Review of the Gene Technology (GM Crop Moratorium) Act 2003
27 August 2007
Thank you for the opportunity to register a submission concerning the state moratorium on genetically modified canola. The New South Wales moratorium was introduced in 2003 because of concerns within industry, the farming sector and regional comunities about the impact of GE crops on markets. The concerns that led to the introduction of the moratorium include liability and insurance issues, problems with segregation and cross contamination and export market sensitivities.
In the four years since the moratorium was introduced these concerns have proven highly justified. GE contamination scandals have plagued countries, such as the US, that have adopted GE crops. These have resulted in hundreds of millions of dollars of lost export revenue and and costly litigation. Segregation of non-GE canola in Canada has failed, leading to the collapse of its non-GE and organic canola industries. Farm incomes in Canada have plumetted since the introduction of GE canola and Canada has entirely lost its canola seed exports to Europe. Furthermore, consumers in Australia, and major export markets such as Europe and Japan, remain resolutely opposed to GE food. Recent studies questioning the science behind GE and the safety of GE food have only served to heighten consumer concern on the issue.
In 2005 Ian MacDonald, the NSW Agriculture Minister stated that “at this point the lack of segregation trials means that there has been no practical demonstration of the capacity to segregate GM and non-GM product across the supply chain to differing market standards.”[i] He argued that “it is important that independent, small-scale agronomy trials of GM canola occur prior to larger-scale segregation trials being conducted to address marketing issues.”[ii] This work has still not been completed.
Greenpeace believes that the reasons for a moratorium on commercial GE food crop production are stronger than ever, and that the current moratorium should be extended by a further 5 years.
1. Economic benefits of the moratorium
1.1. Benefits for consumers
Polling by Swinburne University and Biotechnology Australia last year shows that the majority of Australians are uncomfortable with eating GE food and are unlikely to eat it.[iii] Similar attitudes exist in our key export markets, such as Europe and Japan. A survey by the Pew Global Attitudes Project shows that Western Europeans and Japanese consumers are overwhelmingly opposed to scientifically altered fruits and vegetables because of health and environmental concerns.[iv] A 2006 poll, by the Japanese Ministry of Agriculture, Fishery and Forestry (MAFF), found that 78% of Japanese consumers were uncertain about the impacts of eating GE food.[v] The current moratorium has allowed the market to supply what consumers want non-GE canola with a low risk of GE contamination, and without the need for costly segregation and identity preservation (IP) systems. Segregation and IP costs, along with the costs of recalls when the inevitable contamination occurs will invariably be passed on to food companies and, ultimately, to consumers.
1.2. Benefits for user industries
The moratorium has benefited industry in several ways since it’s implementation. Benefits include:
* price premiums and preferential market access for Australian canola;
* lower production costs, since costly segregation and identity preservation processes are not required;
* an absence of costly recalls due to unwanted GE contamination such as recently happened with rice products in the US;
* a reputation among domestic and export markets for high quality non-GE products.
The issues surrounding market access, price premiums, and segregation costs will be discussed in more detail in the following sections.
1.3. Benefits for farmers
“Over the past decade, corporate and government managers have spent millions trying to convince farmers and other citizens of the benefits of genetically-modified (GM) crops. But this huge public relations effort has failed to obscure the truth: GM crops do not deliver the promised benefits; they create numerous problems, costs, and risks; and Canadian consumers and foreign customers alike do not want these crops.
It would be too generous even to call GM crops a solution in search of a problem: These crops have failed to provide significant solutions, and their use is creating problems”” agronomic, environmental, economic, social, and (potentially) human health problems.” Canadian National Farmers Union (2005)[vi]
As Table 1 demonstrates, the vast majority of the world's canola is non-GE. Claims that Australia is being ‘left behind’ by not adopting GE canola are nonsense. Canada is the only major canola producing country to have adopted GE canola and its farmers are heavily subsidised. If Australia adopted GE canola without subsidising its farmers, it would be the first major canola producer in the world to do so. Europe decided not to adopt GE canola because of widespread community opposition to GE crops and concerns about the biodiversity impacts of GE canola.[vii]
Table 1: Key characteristics of the world canola seed market
Percentage of world production[viii]
GE canola adopted?
1.3.1. Price Premiums
Figure 1: Annual average price difference between Australian and Canadian canola
As illustrated in Figure 1, in 1998, the difference between Australian and Canadian canola prices was about $70 a tonne in favour of Canada. However, by May 2006 Australian prices had exceeded Canadian prices by some $50 a tonne.[ix] It is difficult to determine how much of this price premium is due to Australian canola’s non-GE status, since the information is commercially confidential. However a WA Department of Agriculture report observes that premiums for non-GE canola exist in both Japan and Europe.[x] Premiums of $12 to $14 per tonne have been reported in Europe.[xi] However, Portmann and Tucek noted that it was unlikely that the real price differential would be seen until there was a shortage of non-GE product.[xii] This is exactly what happened in 2006 when Australian canola producers were badly hit by the drought. This saw Australian canola prices soar to $115 a tonne more than Canadian canola.[xiii]
1.3.2. Supply and production costs at all stages
The moratorium currently protects farmers from costs associated with segregation, identity preservation and contamination. Currently, non-GE farmers are expected to bear many, if not most, of the costs of introducing genetically engineered (GE) crops. The Australian Bureau of Resource Economics (ABARE) has estimated that the introduction of GE canola will cost non-GE farmers 5-15% of the farmgate value of their crop.[xiv] That figure is based on a 1% contamination acceptance threshold a threshold not currently accepted by farmers or markets. If a ‘zero tolerance’ segregation system is implemented, costs are likely to be significantly higher.
Even maintaining a 1% threshold is likely to be extremely difficult. A UK study demonstrated that a single GE canola crop contaminated subsequent grain crops in the same field at levels above 1% for up to 16 years unless the most stringent of measures were implemented.[xv] Currently, there are no on-farm conditions imposed on the commercial release of GE canola.[xvi]
Additionally, non-GE farmers will be exposed to increased financial risk, including potential liability and lost market access, when the inevitable contamination occurs.[xvii]Initial attempts to segregate non-GE canola in Canada have categorically failed and this issue is discussed in greater detail in section 3.Contamination costs must be considered an inevitable cost of doing business if Australia embraces GE food crops.
1.3.3. Productivity and profitability
“Those who assert that GM seeds increase farmers’ net income need to produce some data. And, as we stand ten years after the introduction of these seeds, and as we stand mired in the worst farm income crisis in Canadian history, it is probable that such data will be hard to produce. The claim that GM seeds make our farms more profitable is false.”Canadian National Farmers Union (2005)[xviii]
In a recent report, Nuffield scholar Andrew Broad estimated that genetically engineered (GE) Roundup Ready canola would cost $27.82 per hectare more to grow than conventional canola. He claimed that this would be compensated for if there was a yield gain of 4%, not taking into account the additional costs of segregation and identity preservation.[xix]However, there is no evidence that GE canola actually increases yields.
No independent trials have been conducted to assess any potential yield gains associated with the GE canola varieties approved for commercial production in Australia. Bayer and Monsanto have failed to enter their GE canola varieties into national seed listing trials in order that they can be independently assessed. The data from Monsanto and Bayer's own studies suggests that there may actually be a substantial yield penalty associated with GE canola. Despite Monsanto adding the Roundup Ready gene to 'elite varieties', the best Australian trials of Roundup Ready canola yielded only 1.055t/ha at least 16% below the national average of 1.26t/ha. Monsanto has since removed the details of the trials from its website.
In 2005 Ian MacDonald, the New South Wales Agriculture Minister, argued that before the moratorium is lifted “it is important that independent, small-scale agronomy trials of GM canola occur prior to larger-scale segregation trials being conducted to address marketing issues.”[xx] This work has still not been completed. In 2003, the New South Wales Government approved field trials of Monsanto and Bayer’s GE canola in order that their agronomic performance could be evaluated. However, both companies pulled out of the trials with Bayer citing ‘poor seasonal conditions’ as the reason.[xxi]
As Figure 2 shows, Canadian canola yields from 1965 to 1994 increased by an average of 0.2 bushels per acre per year. This was the result of selective breeding and improvements to farming techniques. GE canola was introduced to Canada in 1996, however from 1995 to 2004, yield only increased by an average of 0.1 bushel per year. Those who claim that GE crop technologies positively contribute to yield - either directly or indirectly - have no data to prove that assertion.[xxii]
Figure 2: Canadian canola yields, 1965-2004[xxiii]
“Farmers’ profits haven’t just disappeared; they’ve been taken. The farm crisis didn’t just happen; it was caused. The family farm isn’t dying; it’s being killed. And the perpetrations of this destruction are the agribusiness corporations who are using their market power to extract profits that would otherwise end up on our farms. Farmers can’t make a living because agribusiness giants insist on making a killing.”
Canadian National Farmers Union (NFU) 2005[xxiv]
Even if GE canola did have the potential to increase yields, as the Canadian National Farmers Union point out “any initial economic benefits will be quickly outweighed as farmers are drawn further under corporate control.”[xxv] As Figure 3 shows, net farm incomes in Canada have plummeted since the introduction of GE canola. The last five years in Canada have been the worst five years of realised net farm incomes in the history of the country.[xxvi] At the same time, we have seen corporate agribusiness “earn” record profits. In Canada, corporations have captured more than 100% of the profits associated with GE (the shortfall has been made up by Government subsidies) and farmers have become increasingly dependant on high-tech seeds and chemicals. The knowledge and power has shifted from the farmers to giant agri-business corporations such as Bayer and Monsanto. And as the power has shifted, so have the profits.[xxvii]
Figure 3: Canadian Realised Net Farm Incomes[xxviii]
Companies such as Monsanto have gone to great lengths to ensure that they capture the full benefits of the introduction of GE crops. Monsanto spends over US$10 million annually investigating, intimidating, pressuring, and suing farmers.[xxix] The company has a staff of 75 employees devoted to these pursuits and Monsanto also contracts dozens of lawyers from outside firms. It has sued for, and won, judgements as high as US$3 million and several more over $1 million.[xxx]
While the net income numbers in Figure 3 represent farmers in general (not just canola farmers), the net income trend is representative of the experience of canola farmers. According to the NFU, if anything, the trend is optimistic, because - if it were available - data on net income from canola production would produce a graph line that would fall much more precipitously than the line in Figure 3. The profitability of canola production, like that of crop production in general, has crashed over the past decade.[xxxi]
Data from Statistics Canada shows that small and medium-size Canadian farms now rely on off-farm income for approximately 90% of their total income; large farms rely on off-farm income for over half (52.1%) of their total income; and even Canada’s largest farms, depend on off-farm income of between 25.9% and 33.5% of their total income.[xxxii]
The NFU states that a combination of government subsidies, increased debt loads (now exceeding C$52 billion), and off-farm income are the main factors that allow farming to continue despite sub-Depression level net incomes.[xxxiii] Whilst Australian farmers remain unsubsidised, according to the NFU, Canadian subsidies work out to about A$150 per ha of cropland.[xxxiv] This year ABARE estimates that over 1million ha in Australia will be sown to canola this year.[xxxv] If the Australian Federal Government were to subsidise Australian canola farmers to the same extent it would cost $150 million a year. The NFU also estimates that in order for most Canadian farmers to take a “wage” from their farms, current subsidies would have to nearly double. In other words, if the Australian Government wants GE canola farmers to stay in business it needs to be prepared to subsidise them to the tune of over $300 million a year.
The adoption of GE canola has certainly not improved grower profitability in Canada, and there is no reason to suggest that it will in Australia. Since there are no demonstrated agro-economic benefits associated with the GE canola varieties approved for commercial use in Australia, the uptake of the technology by farmers is likely to be low without heavy discounting. However the increased costs associated with segregation and contamination will be born by all canola farmers, regardless of whether they choose to adopt the technology.
Extending the moratorium will retain preferential market access for New South Wales canola and ensure the continued profitability of canola production for farmers.
1.3.4. Export market access and reputation
An ABARE research report concluded that “a range of market access restrictions related to GM products means that it is easier to trade non-GM grains in the current market environment than it is to trade GM grains.”[xxxvi]
In the early and mid-1990s, before the widespread introduction of GE canola, Canada sold much of its canola crop to the EU. The EU took 16% of total Canadian exports in 1993, 32% in 1994 and 25% in 1995. However, as a result of the introduction of GE canola Canada entirely lost its canola seed exports to Europe. Over the past decade, China has become a major buyer of Canadian canola. However, China is a low-price market, whereas the EU was a premium-price market. Today, Canadian canola prices, adjusted for inflation, are at a record low.[xxxvii] Because of the introduction of GE varieties and attendant market loss, canola prices have fallen.[xxxviii]
USDA figures indicate that high levels of carry-in stock (stock not sold immediately) are afflicting Canadian GE canola producers, indicating an inability to immediately sell their GE canola into the world’s markets. While Department of Agriculture figures for Australian carry-in stock of canola are not available, there is no evidence that Australia is having similar problems.
As can been seen from Figure 4, Australia's most important export markets for canola are Japan and Europe, accounting for 41% and 38% of exports in 2006.[xxxix] The EU has instituted strict rules regarding the import and labelling of GE products, reflecting the strong and continuing resistance to GE in Europe.[xl]Other countries that are planning to introduce GE labelling laws include Quatar and Kuwait. Consumer campaigns are currently underway in Europe, Japan, the US and Canada for tighter labelling laws regarding GE food.
Japan, in particular, is an extremely important market - receiving 50% of Australian canola seed exports between 2001 and 2004. Consumer resistance to GE is extremely strong in Japan, and the recent scandal regarding GE canola contamination around Japanese ports has further heightened fears. If GE canola is commercialised in Australia the negative consequences for Australian grain markets could be significant. The WA inquiry observed that “Australia was able to secure greater market access because it was producing non-GM canola”[xli] According to Perry Gunner from ABB Grain, Japan's interest in buying Australian canola is growing. He states that there are further opportunities to sell canola there because of Australia's GE free status.[xlii] This month it was reported that Canadian canola exports to Japan will be down this year due to competition from Australia.[xliii]
Several Japanese companies specifically market Australian GE-free canola oil and attract premium prices for their products. Several Japanese consumer co-ops have expressed concerns about GE crops. Uni Co-op reportedly switched from Canadian canola to supply from Australia in response to consumer demand for GE-free product. Similarly, Shutoken Co-op has indicated it wants GE-free canola.[xliv]Organic export companies have noted that export opportunities for organic canola oil are not being captured due to major immediate supply shortages.[xlv]
GE canola was introduced to Canada in 1996, and by 1998 Canada had entirely lost its sales of canola seed to Europe. The EU is a growing market for Australian canola, accounting for 38% of Australia's exports in 2006. The increase in demand is driven largely by the biodiesel sector, and the EU is sourcing canola from Australia precisely because of its non-GE status. According to the Canola Council of Canada, if it weren't for the GE restrictions, between 300-400,000 tonnes of Canadian canola could have been exported to the EU in 2005-2006. Furthermore, the Council has estimated that the level of demand could easily double in 2006-2007, making the opening of EU borders to Canadian canola an important priority for Canada.[xlvi] Clearly Australia has a important marketing advantage over Canada when it comes to serving EU markets. There is no evidence to support the claim that the EU is likely to lift its ban on Canadian canola seed imports. According to the Canadian Canola Council “despite the recent World Trade Organization Panel ruling on the approval and marketing of biotech products in the EU, it could be some time before genetically modified (GM) canola is welcome in the EU”.[xlvii]
A recent ABARE report has noted that the unintended presence of GE canola in Australian shipments could be a problem if the EU becomes a larger and more regular importer of Australian canola, because of the EU labelling threshold of 0.9%.[xlviii] Based on the current trend towards increased demand for biodiesel, there is an extremely high probability of this happening.
The domestic market accounts for approximately 20-30% of total canola seed production (depending on the year), making it the third largest market for Australian canola. The two largest buyers are Goodman Fielder and Unilever, both of which have a policy to avoid the use of GE derived canola oil.
1.3.5. Effects on other industries
The moratorium protects not only canola farmers from the negative impacts of GE contamination but also prevents the contamination of other crops such as barley and wheat. Both AWB Limited and the Australian Barley Board (now ABB Grains), key grain marketers in Australia, have expressed concerns over the commercialisation of GE canola in Australia because of the possibility that unintended presence of GE canola seed in wheat and barley shipments would jeopardise some of their markets. Similarly, numerous marketers of Australian livestock products have claimed that there is a market advantage to not feeding GE material to livestock.[xlix] Canola meal is commonly used as stock feed in the dairy industry which is extremely sensitive to GE contamination. Consumer concern regarding the use of GE stock feed, both in Australia and in important export markets such as Japan and Europe, has resulted in the majority of Australian dairy suppliers having non-GE policies. These companies include:
* National Foods
* Bega Cheese
* Norco Co-operative
* Dairy Farmers
* Parmalat Australia
* Jalna Dairy Foods
* Snowy Mountains Organic Dairy
* Tatura Milk Industries
* Murray Goulburn Co-operative
* Warrnambool Cheese & Butter Factory
A full list of these companies’ policies regarding GE ingredients can be found in Appendix A.
1.3.6. Research and development and access to new varieties
In Australia, although private companies are exerting increasing control over seed research and development, there is at least some publicly funded seed development. In Canada the rise of global seed corporations has resulted in the decimation of public seed development. Corporations, such as Monsanto and Bayer, are using patents, contracts, and ever-tighter Plant Breeders’ Rights legislation to ensure that farmers pay for seed. When farmers don’t pay, corporations sue. Such lawsuits over seeds are fast proliferating, with the companies seeking and receiving farm-destroying amounts of money. Not satisfied with these legal tools, companies are working to overcome resistance to Terminator Technology (seed genetically engineered to be sterile after one generation) in order to force farmers to buy new seed each year. Companies have also successfully pressured governments to do less publicly funded plant breeding, meaning that farmers have fewer and fewer alternatives to corporate seeds.[l]
1.3.7. Sustainability on farm
The negative environmental impacts of GE crops are well documented. A summary of these can be found in our attached briefing The Environmental Impacts of GE crops. [li] GE crops threaten to undermine the economic basis of agriculture by unbalancing the biosphere, increasing weed resistance problems,endangering beneficial insects, and eroding bio-diversity.[lii] Biodiversity is a vital source of raw materials for agriculture and an essential component of environmental well-being.[liii] The moratorium has protected farmers from these threats to the sustainability of farming.
2. Two very good reasons why the moratorium should be extended
2.1. Consumer resistance
Consumer resistance is the strongest economic argument for remaining GE free. As the Australian Wheat Board has noted, “Legislation might allow GMs but that doesn't mean our customers want them.”[liv] The Western Australian inquiry noted“the unpredictable nature of world commodity markets” and acknowledged “the shortcomings of any attempt to predict future market conditions and consumer behaviour”[lv]It also concluded that“there exists no certainty in the market acceptability of GM foods, with consumer attitudes being both varied and unstable on the issue.”[lvi]Since there is no market in the world with a preference for GE canola over non-GE canola; and Australian canola is currently receiving favourable market access and premiums because of its non-GE status; it would be reckless for the New South Wales Government to lift the moratorium in the current market environment.
As the Canadian National Farmers Union puts it:
“While the benefits are questionable, risks and costs are real. Consumers are rejecting GM foods. Markets in Europe, Japan, and elsewhere are closing and domestic markets are likewise threatened. This is driving prices down. Closing markets and falling prices threaten to overwhelm any small, short-term economic benefits that GM crops or livestock may offer. Further, the proliferation of some GM crops has effectively deprived many organic farmers of the option to grow those crops.”[lvii]
There is no evidence of waning consumer opposition to GE crops in either Australia, or our major export markets such as the EU and Japan. As more studies come to light that question the scientific basis of GE and the safety of GE foods, this is likely to have a further detrimental effect on consumer attitudes to GE foods. This will obviously have an effect on the marketability of GE crops. Another major health or contamination scandal involving GE food crops, such as the Starlink scandal or the recent illegal GE rice scandal in the US could have catastrophic impacts on the marketability of GE crops.[lviii]
In June this year, new research published in the leading scientific journal Nature revealed serious flaws in the science behind genetic engineering. The research calls into question the assumption that each DNA sequence can be isolated and has its own function. Instead, genes operate in a complex network where they react, interact and overlap with each other in ways that are still far from being understood. This new research shows that genes cannot be considered isolated units - nor can they be controlled. The research raises serious questions about the safety of GE crops.[lix]
This incomplete understanding of genetics explains why so many unexpected effects have occurred in GE feeding studies. For example, the attached peer reviewed study, published this year, found evidence of liver and kidney toxicity when rats were fed an approved GE maize variety (MON863).[lx]Similar effects were observed when Monsanto fed its GT73 Roundup Ready canola variety to rats. The rats showed a 12-16% increase in liver weight, yet Food Standards Australia New Zealand (FSANZ) still rubber stamped the canola as safe for human consumption.[lxi]
In 2005 CSIRO abandoned a decade-long project to develop GE peas after tests showed they caused allergic lung damage in mice. [lxii] The allergic reaction is believed to have been caused by unexpected changes to the protein when it was expressed in the pea. FSANZ typically uses proteins expressed by bacteria in its toxicity studies, rather than proteins isolated from the plants in which they are expressed.[lxiii] This allergenic pea would therefore have been approved for human consumption had it gone through FSANZ's normal testing regime.
Greenpeace does not believe that any potential benefits promised by the technology could ever outweigh the potential risks posed by the technology to human health, the environment and the economy. Furthermore, most of the purported benefits of GE crops such as drought and salt tolerance can be achieved by other techniques which don’t pose the same risks to human health and the environment. For example, last year John Brumby, the then Victorian Minister for Innovation, announced that Victorian scientists had developed non-GE drought tolerant canola using marker assisted selection.[lxiv]
2.2. Segregation is impossible
“GM crop agriculture is incompatible with other forms of farming””non-GM and organic, for instance””because GM crops contaminate and because segregation is impossible.”Canadian National Farmers Union (2005)
The introduction of GE canola would require the implementation of segregation and identity preservation (IP) in order to serve market demand. In 2005 Ian MacDonald, the NSW Agriculture Minister, argued that “at this point the lack of segregation trials means that there has been no practical demonstration of the capacity to segregate GM and non-GM product across the supply chain to differing market standards.” [lxv]. This is still the case. Greenpeace believes that the moratorium should be extended, since no satisfactory measures have been suggested that would protect non-GE farmers and consumers from unwanted GE contamination.
A Western Australian Parliamentary inquiry into genetic engineering formed the view that “contamination of non-GM crops by GM crops is inevitable, segregation is not practical and that identity preservation (IP) can be achieved, but at a significant cost.”[lxvi] The WA inquiry found that “extra costs will arise with an identity preservation system due to the additional work involved throughout the supply chain, including in growing, handling, storage, transport, processing, cleaning and administration. Certification and/or testing of the GM status of bulk commodities in the marketing chain and labelling will also contribute to the additional costs.”[lxvii]
Europe currently has a 0.9% threshold for GE contamination. However this is for “adventitious or technically unavoidable presence”, not a legislated tolerance threshold. A 'zero tolerance' segregation system would therefore be required to serve EU markets. The Australian Bureau of Agricultural and Resource Economics (ABARE) has noted that, “zero tolerance in an importing country for contamination with GM canola would make it very difficult, if not impossible, for a country producing a mix of GM and non-GM canola to address that market.”[lxviii]
Segregation advocates point to organic growers who successfully segregate their crops from the rest of the food supply. However such comparisons fail to appreciate how segregation systems work. Keeping the general pool of product from contaminating a small subset is a very different task to trying to keep grains separate within the commercial system, with its huge bulk-handling facilities, intermixing, port blending, sketchy paperwork, and numerous delivery points to say nothing of pollen drift and seed contamination.[lxix]
The experience in countries that have adopted GE food crops has shown that the contamination of non-GE and organic crops would be inevitable. The introduction of GE canola would result in greatly increased on-farm costs for both GE and non-GE farmers; lost market access; as well as greatly increased costs for user industries; which would ultimately be passed onto consumers.
Initial attempts to segregate non-GE canola in Canada failed and it is now nearly impossible to grow non-GE canola in most of Canada. The proliferation of GE canola, uncertainty over seed supply purity, and the risk of contamination from windblown pollen mean that non-GE farmers have little certainty that their canola will be free of GE seeds. If these farmers try to grow non-GE canola, they face huge risks that their products may be rejected by buyers, possibly when those products reach overseas ports.[lxx]
Based on the North American experience, it is virtually guaranteed that a GE/non-GE segregation system will fail. Canadian researchers tested 33 samples of certified non-GM canola seed and found that 32 samples were contaminated with GE varieties””and three of those samples had contamination had levels above 2%.[lxxi] Another study in the US found that virtually all samples of non-GE corn, soybeans, and canola seed were contaminated by GE varieties.[lxxii] Widespread contamination is not surprising. A recent UK study found that GE canola cross-pollinated with non-GE canola more than 26 km away.[lxxiii]
Peter Portman from CBH (the largest grain handler for export in Australia) has stated that segregation is only likely to take place for a couple of years for 'political reasons'. The lifting of the moratoria would remove choice for both food producers and consumers with a preference for non-GE ingredients.
3. Additional Measures
In addition to the extension of the moratorium, Greenpeace believes that strict liability legislation and tighter labelling laws are needed to protect markets and consumers from unwanted GE contamination.
3.1. Strict liability legislation
It is inequitable to allow biotech companies to privately reap profits and not require that they also assume all costs. The State Government must hold biotech companies accountable for the costs their products create for farmers, industry and the consumers. Introducing strict liability legislation so that companies are held responsible for the damage caused by their products would be an equitable way to achieve this.
Consumers should have the right to choose whether or not they want to eat GE food. Polls consistently show that the overwhelming majority of consumers want GE food to be labelled as such. Food derived from GE crops, including products from animals fed GE feed should be clearly labelled as such.
Greenpeace believes that the reasons for a moratorium on commercial GE food crop production are stronger than ever, and that the current moratorium should be extended by a further 5 years.
Appendix A: Dairy company policies on GE ingredients
"We do not use any GE ingredients in the manufacture of Attiki yoghurt or cheese. All of our milk purchases are made through the Dairy Farmers Co-Op, which has assured us that feed used contains no GE products. All other ingredients used in the manufacturing process have been certified GE free". November 2002
"It is our policy not to use any ingredient containing GMO's in our manufacturing process. The process is managed through our Ingredient Supplier Assessment Program which requires the supplier to declare products to be supplied are from non GM sources. To manage the possible impact of GMO's in the milk supply chain it is our policy not to accept milk from transgenic or cloned cows from our suppliers and to limit the possible use of GM feed to the lowest practicable level. This is facilitated by a declaration from the milk suppliers that includes a commitment to ensure that the cow's nutritional diet will not contain more than 1% GM sourced or possibly contaminated feed." Elvis Amair, Technical Services Manager, July 2003."
"Dairy Farmers policy is to exclude all genetically modified ingredients. This includes both those ingredients that contain modified protein or novel DNA and those ingredients that are derived from genetically modified plants, but do not contain modified protein or novel DNA. Some Dairy Farmers products are manufactured using milk sourced entirely from cattle in South Australia and Victoria where, to the best of our knowledge, no cottonseed is used for supplementary feeding. In these regions, when supplementary feeding is required, Canola Meal is used instead. At this stage, this product is GM free (Dairy Vale, Coon, Shape Cheese, Take Care). For these brands, we can be confident that the milk supply is not from cattle fed on genetically modified crops. Dairy Farmers is not able to guarantee that material from genetically modified crops is not currently in use as a feed in Queensland and New South Wales. Dairy Farmers will work with its suppliers and with the suppliers of stockfeed to identify any sources of supplementary feed that may contain material from genetically modified crops and to phase out the use of supplementary feeds containing material from genetically modified crops." July 2003"
Jalna Dairy Foods
"We declare that all our products are made using only non-GE ingredients; non GE derived ingredients; and non-GE feed." Jeff Carlin, Promotions & Business Development Manager 17th June 2003"
"..use no GE ingredients or GE-derived ingredients in the manufacture process." Heidi Behrens, July 2003. "GM livestock feed will not be permitted in Tasmania outside of research and physical containment facilities." Tasmanian Government Gene Technology Policy 2001. "Lactos' commitment to the use of GE-free stockfeed has been communicated to all of our milk suppliers." Michel Duleu-Burre, Managing Director July 2003.
Murray Goulburn Co-operative
"Our "MG Milkcare" program specifically excludes the use of GM feed materials for the production of milk to Murray Goulburn. Our farmers are required to provide a declaration showing that feeds used does not contain GM products. Our policy is also very clear against the use of GM modified animals or cloning of animals for milk production. We do not use GM ingredients or GM additives in the manufacture of our dairy products."
"National Foods Ltd has a contractual requirement with supplier farmers that raw milk supplied to the company comes from cows which themselves are not genetically modified and have not been fed rations from crops using recombinant DNA technology." Ian Greenshields - Group General Manager 09/04/02"
Norco does eliminate ingredients derived from GE crops which constitute an important aspect of the food... Norco Rural Stores has a policy (where) stockfeed products either purchased-in or manufactured in-house are derived from grains which do not contain genetically modified technology. All bought stockfeed be sourced from non GE crops and not to contain GM products.
"In relation to genetically engineered or genetically modified (GE/GM) materials, Parmalat has a clear policy to avoid their use whenever possible. Accordingly, we require from all our suppliers, warranties in regard to the GE/GM status of ingredients and additives. For our dairy products, fruit juices and carbonated drinks, none of the ingredients or additives used are GE/GM. For our soy products, the soy beans used to make the soy protein isolate are from non-GE/GM soy beans under a strict "Identity Preservation" system... In the case of milk, our preference is that our farmers avoid GE/GM feed for their cows and seek warranties from their suppliers of compounded feeds when in doubt." Dr Roger MacBean, Technical Manager Australia Asia, February 2003
Snowy Mountains Organic Dairy
"It is our policy that products containing, or suspected of containing, derived or produced using GE methods are not used. The feed that is given to the organic dairy herds is produced on [the] farms and is grown organically, without the use of GE ingredients. No ingredient used in the processing facility [milk] can be traced back to a GE ingredient." Rod McCormack, Sales & Marketing Manager, June 2003."
Tatura Milk Industries
"Tatura Milk Industries is committed to ensuring that all ingredients through the food chain are GE free. The Tatura Quality Milk Program (TQMP) requires our farmers to exclude the use of GE feed materials for the production of milk to Tatura Milk Industries. Tatura Milk Industries actively seeks the purchase of ingredients for manufacturing purposes, which are not derived from genetically engineered crops." Andrea Farago, Quality Assurance Manager, July 2003."
Warrnambool Cheese & Butter Factory
"Our policy is (a)none of our products contain GE ingredients (b)no GE derived ingredients used (c) procedures in place, as part of the on-farm QA program, to exclude GE feedstuffs being used by supplier farmers." Steve Billington 23/7/03
Greenpeace (2006) Spotlight on GE the environmental impacts of GE crops.
Séralini, G-E, Cellier, D. & Spiroux de Vendomois, J. (2007) New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxicity. Archives of Environmental Contamination and Toxicology DOI: 10.1007/s00244-006-0149-5.
[i]Hansard (2005) Gene Technology (GM Crop Moratorium) Amendment (Postponement of Expiry) Bill, 9 November 2005,http://www.parliament.nsw.gov.au/prod/PARLMENT/hansArt.nsf/V3Key/LC20051109040, viewed 24/6/07.
[iii]Australian Centre for Emerging Technologies and Societies (2006) Swinburne National Technology and Society Monitor 2006, Swinburne University of Technology http://www.swinburne.edu.au/lss/acets/monitor/2006MonitorFull.pdf; Biotechnology Australia (2006) Trends in Australian Community Attitudes Regarding GM Foods in 2006, ACNielson Report http://www.biotechnology.gov.au/index.cfm?event=object.showContent&objectID=E6F3DEA2-960B-38D5-E1BADCE724181C1B
[v]The report can be viewed at: http://www.maff.go.jp/www/press/cont2/20050826press_4b.pdf, viewed 20/6/07.
[vi]NFU (2005a) GM Crops: Not Needed on the Island, - Recommendations of the National Farmers Union to the Prince Edward Island Legislature’s Standing Committee on Agriculture, Forestry, and the Environment, www.nfu.ca/briefs/2005/PEI%20GMO%20BRIEF%20TWENTY%20SEVEN%20FINAL.pdf, viewed 20/6/07.
[vii]Greenpeace (2003) Summary of scientific evidence on the environmental impacts of GE Canola,www.greenpeace.org.au/truefood/downloads/recent_studies_on_ge_canola_nov03.pdf, viewed 20/6/07.
[viii]Annual average, three years to 2005-06, Source: Foster, M. & French, S. (2007) Market acceptance of GM canola, ABARE research report 07.5, March 2007, available at: www.abareconomics.com/publications_html/crops/crops_07/GM_Canola.pdf, viewed 13/8/07.
[ix]Source: DAFWA, 2006 quoted in media release by Kim Chance (2006) ‘State Government questions Federal stance on State GM moratoria’, available at:http://www.ministers.wa.gov.au/chance/index.cfm?fuseaction=media.main#, viewed 21/6/07.
[x]WA Department of Agriculture (2002) International Market Trends for Genetically Modified Crops, Government of Western Australia.
[xii]Portman, P. and Tucek, M. (2001). ‘Marketing GM crops: market issues facing Australia if it moves into GM crops.’ Outlook 2001, Proceedings of the National Outlook Conference, Canberra, Vol. 2. Agriculture and Regional Australia, ABARE, pp. 189-195.
[xiii]Cargill (2006) Winnipeg canola price and canola cash price, The Land, 2/11/06.
[xiv]Foster, M. (2001) Genetically modified grains: Market implications for Australian Grain Growers, an Australian Bureau of Agricultural and Resource Economics (ABARE) Research Report 01.10, Canberra [ABARE], p. 37.
[xv]Squire, G.R., Begg, G.S. & Askew, M (2003) The potential for oilseed rape feral (volunteer) weeds to cause impurities in later oilseed rape crops, Final report of the DEFRA project: Consequences for Agriculture of the Introduction of Genetically Modified Crops, RG0114. Available at: www.defra.gov.uk/environment/gm/research/pdf/epg_rg0114.pdf, viewed 24/6/05.
[xvi]Office of the Gene Technology Regulator (2002) Licence DIR 021/2002 - Commercial release of InVigor® hybrid canola (Brassica napus) for use in the Australian cropping system, available at http://non-gm-farmers.com/news_details.asp?ID=618, viewed 24/7/06.
[xvii]Department of Agriculture, Fisheries and Forestry (2003) Liability Issues Associated with GM Crops in Australia.
[xix]Broad, A. (2006) Best practice canola production: Exploring biotechnology, agronomic advances and new grower techniques, www.nuffield.com.au/report_f/2005/Andrew%20Broad%202005%20report.pdf
[xx]Hansard (2005) Gene Technology (GM Crop Moratorium) Amendment (Postponement of Expiry) Bill, 9 November 2005,http://www.parliament.nsw.gov.au/prod/PARLMENT/hansArt.nsf/V3Key/LC20051109040, viewed 24/6/07.
[xxi]ABC (2004) Bayer pulls out of GM canola trials, http://www.abc.net.au/news/stories/2004/06/03/1124071.htm, viewed 16/7/07.
[xxiii]Source: Agriculture and Agri-Food Canada data, cited in NFU (2005b) GM Crops: Not Needed on the Island,http://www.nfu.ca/briefs/2005/PEI%20GMO%20BRIEF%20TWENTY%20SEVEN%20FINAL.pdf, viewed 16/7/07 attached.
[xxvi]NFU (2007) Submission by the National Farmers Union on The Farm Income Crisis Business Risk Management, and The “Next Generation” Agricultural Policy Framework, April 26th, 2007 www.nfu.ca/briefs/2007/NFU_Brief_to_Commons_Ag_Committee_on_the_Farm_Income_Crisi%5B1%5D..pdf, viewed 13/8/07.
[xxix]Centre for Food Safety (2005) Monsanto vs. US Farmers, www.centerforfoodsafety.org/pubs/CFSMOnsantovsFarmerReport1.13.05.pdf, viewed 13/8/07.
[xxxv]ABARE (2007) Australian Commodities: June Quarter, www.abareconomics.com/publications_html/ac/ac_07/ac_june07.pdf, viewed 13/8/07.
[xxxvi]Foster, M. et al (2003) p. 17
[xxxix]Foster, M. et al (2003) p. 17
[xl]The Pew Research Center (2003) Broad Opposition to Genetically Modified Foods: Modest Transatlantic Gap, 20/6/03,http://people-press.org/commentary/display.php3?AnalysisID=66; Stearman, K. (2005) United States tries to derail discussion on labelling of GM food, 11/5/05, www.lobbywatch.org/archive2.asp?arcid=5228; GM Free Cymru (2005) Second Bt contamination incident in Japan, 7/6/05, www.lobbywatch.org/archive2.asp?arcid=5341; Reuters (2005) CHRONOLOGY-Recent events in Bt-10 corn controversy, 1/6/05, www.reuters.com/newsArticle.jhtml?type=topNews&storyID=8669951; all viewed 15/6/05.
[xli]Western Australia Standing Committee on Environment and Public Affairs (2001), paragraph 10
[xlii]ABC North & West SA (2005) Interview: Perry Gunner, ABB Grain, SA Country Hour, 23/6/05, 12:19 pm.
[xliii]Canola Insight (2007) Canadian canola exports in 07/08 to decrease over prior year’s estimate,http://canolainsight.com/canolahome/story_cangeneral.html?table=news&ID=7359, viewed 14/8/07.
[xliv]McCoy, S. & Parlevliet, G. (2000) Export market potential for Clean & Organic Agricultural Products, RIRDC
[xlvi]Agriculture and Agri-food Canada (2006) Canola: Situation and Outlook, Bi-weekly bulletin: Volume 19, Number 17 http://www.agr.gc.ca/mad-dam/index_e.php?s1=pubs&s2=bi&s3=php&page=bulletin_19_17_2006-11-30&PHPSESSID=3ddca65c0676e448057f2538abe6e4a1, viewed 13/8/07.
[xlviii]ABARE (2007) Market Acceptance of GM Canola, www.abareconomics.com/publications_html/crops/crops_07/GM_Canola.pdf, viewed 17/8/07.
[li]Greenpeace (2006) Spotlight on GE the environmental impacts of GE crops see attachment.
[lii]Greenpeace (2003) Summary of scientific evidence on the environmental impacts of GE Canola,www.greenpeace.org.au/truefood/downloads/recent_studies_on_ge_canola_nov03.pdf, viewed 20/6/07.
[liii]NFU (2000) NFU Policy on GM Foods, www.nfu.ca/policy/GM_FOOD_POLICY.misc.pdf, viewed 13/8/07.
[liv]Dowler, K. (2003) Our customers don't want GMs: AWB, ABB, Stock Journal, 9/9/03.
[lv]Western Australia Standing Committee on Environment and Public Affairs (2001), section 8.103
[lvi]Ibid., section 8.186
[lviii]Greenpeace (2007) Rice Industry in Crisis, Major rice markets close doors to genetically engineered rice after contamination of the global food supply chain,www.greenpeace.org/raw/content/international/press/reports/rice-industry-in-crisis.pdf, viewed 16/7/07.
[lx]Séralini, G-E, Cellier, D. & Spiroux de Vendomois, J. (2007) New analysis of a rat feeding study with a genetically modified maize reveals signs of hepatorenal toxicity. Archives of Environmental Contamination and Toxicology DOI: 10.1007/s00244-006-0149-5. (Hepatorenal = of or pertaining to the liver and kidneys).
[lxi]Greenpeace (2004) Greenpeace critique of Monsanto’s Roundup Ready Oilseed Rape, GT73,http://saveourseeds.org/downloads/gp_GT731_comments.pdf, viewed 16/7/07.
[lxii]Young, E. (2005) GM pea causes allergic damage in mice, New Scientist, http://www.newscientist.com/article.ns?id=dn8347, viewed 16/7/07.
[lxiii]Various FSANZ safety assessments can be viewed at: http://www.foodstandards.gov.au/newsroom/technicalreportserie1338.cfm, viewed 16/7/07.
[lxiv]Victorian Government (2006) Media Release: Victorian scientist develop drought tolerant canola,www.legislation.vic.gov.au/domino/Web_Notes/newmedia.nsf/bc348d5912436a9cca256cfc0082d800/c405c362f8a2148aca2571c60001df36!OpenDocument, viewed 14/8/07.
[lxv]Hansard (2005) Gene Technology (GM Crop Moratorium) Amendment (Postponement of Expiry) Bill, 9 November 2005,http://www.parliament.nsw.gov.au/prod/PARLMENT/hansArt.nsf/V3Key/LC20051109040, viewed 24/6/07.
[lxvi]Western Australia Standing Committee on Environment and Public Affairs (2001) Inquiry into the Gene Technology Bills: Executive Summary, para. 18.
[lxvii]Western Australia Standing Committee on Environment and Public Affairs (2001) section 9.52.
[lxviii]Foster, M. et al (2003) Market Access Issues for GM Products: Implications for Australia, ABARE Research Report 03.13, p. 9. Available at: http://abareonlineshop.com/product.asp?prodid=12559, viewed 24/6/05.
[lxxi] Friesen, L., Nelson, A. & Van Acker, R. (2003) Evidence of Contamination of Pedigreed Canola (Brassica napus) Seedlots in Western Canada with Genetically Engineered Herbicide Resistance Traits,” Agronomy Journal 95, 2003, pp. 1342-1347, cited in NFU (2005b).
[lxxii]Mellon, M & Rissler, J. (2004) Gone to Seed: Transgenic Contaminants in the Traditional Seed Supply, Union of Concerned Scientists, cited in NFU (2005b).
[lxxiii]Ramsay, G., Thompson, C. & Squire, G. (2004) Quantifying landscape-scale gene flow in oilseed rape, Scottish Crop Research Institute and the UK Department for Environment, Food, and Rural Affairs (DEFRA), October 2004, p. 4. www.defra.gov.uk/environment/gm/research/pdf/epg_rg0216.pdf, viewed 16/7/07.