2.Point by point rebuttal of claims of animal feed crisis due to GM approvals issue
The second item here is incredibly important. It's a point by point rebuttal of claims of a crisis in Europe over animal feed due to the slow rate of GM approvals. The rebuttal shows that any problems over price rises etc. to do with animal feed are unconnected to the GM approval issue. The biotech industry and its supporters are clearly once again creating a crisis narrative that is intended to undermine regulatory standards.
The extremity of the hype over this issue is typified by the Financial Times article below (item 1) reporting claims that 'Europe's livestock industry could be decimated without greater use of genetically modified crops', and that a matching of the US regulatory system is required: 'It takes two to four years to approve a GM crop in Europe, 15 months in the US. We cannot compete.'
In the FT article it's also claimed that the European pig production exemplifies how Europe's livestock industry faces devastation: 'Pig rearers are already struggling... Feed costs have risen by 50 per cent but prices have fallen 8 per cent.' It's then claimed that without help 'up to a fifth of [pig] producers could give up by the end of the year'.
Among the many points made in the rebuttal document (item 2) are:
+ The European pig industry is struggling with animal feed prices because of recent price hikes in the cost of wheat and barley, and shortages of feed wheat, ie to do with crops that are entirely non-GM!
+ Farmers are struggling with rising animal feed prices in a whole series of countries *outside the EU*, including countries where they grow GM crops!
+ And comparisons with the US regulatory system inevitably look bad in terms of time scale because the US has an almost non-existent system! Comparisons with other GM growing countries like Brazil, Argentina and China, which act less cavalierly, throw up quite different conclusions.
Incidentally, the claims of a pending crisis due to issues around GMOs first emerged out of a report from the EU Comission's avidly pro-GM Directorate General (DG) for Agriculture. That report considered a worst case scenario, and even the report's authors admitted that the magnitude of the figures generated under such a scenario were unreliable and should be treated with caution: 'It should be noted that the worst case scenario yields an impact that goes well beyond the technical limits of the model used for the analysis in the provision of precise and reliable estimations.' In other words, all the subsequent hype has been based on dodgy figures!
But when the DG Ag report came out, the most pro-GM of the Commissioners and the biotech industry lobby group Europabio immediately seized on its claims. Europabio promptly press released its demands for a weakened regulatory system on GMOs. This was done in conjunction with elements in the grains industry that would like as regulatory-lite a system as possible to suit their own business interests.
Pro-GM US ag lobby groups have been busily joining in the chorus and lobbying their European counterparts. Europabio's claims and demands have since been repeatedly parrotted by pro-GM European farmers' leaders and politicians, and press released to all and sundry.
The hope is clearly that this will create extra leverage on regulatory issues in relation to the ongoing WTO negotiations between the US and the EU over GMO approvals, ie the aim's to exert pressure not just externally but from within the EU.
1.Failure on GM crops could ruin livestock industry, EU farmers warn
By Andrew Bounds Financial Times, February 20 2008 http://www.ft.com/cms/s/25d78330-de92-11dc-9de3-0000779fd2ac.html
Europe's livestock industry could be decimated without greater use of genetically modified crops, farmers warned yesterday after European Union agriculture ministers failed yet again to agree whether to allow imports of five biotech crops intended for animal feed.
The European Commission, the bloc's executive, is entitled to rubber-stamp the applications to import four types of maize and one type of potato into the EU.
However, Copa-Cogeca, which represents the EU's farmers, said that with feed prices rising and suppliers in the Americas increasingly planting GM seeds, the industry faced ruin without a speedier approval process. Approvals must first go to national governments, which rarely agree.
'It takes two to four years to approve a GM crop in Europe, 15 months in the US. We cannot compete,' said Simon Michel-Berger, Copa-Cogeca's spokesman.
Pig rearers are already struggling, he said. Feed costs have risen by 50 per cent but prices have fallen 8 per cent. Without help - including export refunds and subsidised storage - up to a fifth of producers could give up by the end of the year.
David Hill, of the EU biotech farmers' network, said poultry production was increasingly moving to Thailand and Brazil. He said there were 18 crops awaiting approval for cultivation and 49 for import, and farmers were frustrated by the delay.
The EU has approved only about a dozen crops amid consumer fears of so-called 'Frankenfoods'. Just one, an insect-resistant maize, can be planted in the EU. France, Austria and Hungary have banned even that.
The Commission has pledged to speed up the process after losing a World Trade Organisation case against the US. Washington has granted a period of grace but could press for sanctions if the situation is not resolved soon.
The Commission is likely to approve soon the four insect-resistant maize types, including three developed by Monsanto, the US biotech company. But it faces an internal battle over the potato Amfora, made by BASF, the chemicals group. Byproducts of the potato can be used in animal feed but it also creates resistance to some important antibiotics, environmentalists say.
2.Point by point rebuttal of claims of animal feed crisis due to GM approvals issue
'GMO approval procedure and zero tolerance regime and the economic consequences thereof'
MEDIA BRIEFING, 17th December 2007
European Parliament Hearing, December 18th, 2007 (Agriculture Committee)
Ahead of a hearing in the European Parliament tomorrow, Friends of the Earth Europe has warned that reports that the EU's GMO policy is harming its livestock industry are scaremongering attempts to lower EU standards on GMOs.
Helen Holder, GMO co-ordinator for Friends of the Earth Europe, said:
'The biotechnology and feed industries and the European Commission's Agriculture department are trying to spread panic that the EU's GMOs policy is threatening Europe livestock sector. Their main aim is to scare EU member states into weakening GMO standards. But the real reason that animal feed prices are rising is because land is being used to grow agrofuels. The EU should stand firm and protect its safety rules from industry attacks.'
The European Commission's DG Agriculture, the Biotech Industry and the Animal Feed Industry are claiming that the EU's GMO policy is harming the EU livestock industry. Friends of the Earth Europe contests this accusation and argues that:
* the US does not have a safety-based approvals system for GMOs, so comparing the speed of the EU's more comprehensive system with the US is irrelevant. Brazil one of Europe's main feed traders - also has biosafety legislation in place stricter than the US, whilst Argentina's trend to approve GMOs in line with the polices of its main trading partners is not expected to change
* China already has biosafety rules in place that are tougher than the US, and is making moves to strengthen them further. The Chinese market is attentive to public concerns on GMOs with a major retailer announcing that it will source GM free soy. China is therefore unlikely to increase the worldwide demand for GMOs, especially as they are in fact already the biggest importer of soybeans. The EU is projected to remain the biggest importer of soy meal for animal feeds globally
* animal feeds have become more expensive due to worldwide shortages caused by poor harvests and because farmers are using land to grow agrofuels instead of food or feed. DG Agriculture and industry are using this crisis to further their own goals to weaken the GMO approvals process in the EU
* the European Union as one of the world's biggest trading blocks carries weight in the international arena. It should use this to support the European non GMO feed industry, and to promote and defend health and safety standards for people, animals and the environment around the world.
The European Commission's DG Agriculture, the Biotech Industry and the Animal Feed Industry lobbyists are claiming that that EU's GMO policy is harming the EU livestock industry, and that:
* Rising prices are due to the EU's health and safety laws on GMOs ('asynchronous' approvals in which GMOs are authorized more slowly in the EU than in the US, and the 'zero tolerance' standard in which any imports to the EU contaminated by GMOs not authorized in the EU are blocked)
* These laws and standards could result in a major lack of feed imports into Europe
* Major emerging markets, such as China, will import GMOs and therefore the EU will no longer have leverage to demand non GM maize and soy from main exporters
* European farmers could be forced into the wholesale slaughter of their livestock due to a shortage of animal feed.
They are calling for GMO approvals to be speeded up in line with the US, and for the 'zero tolerance' standard to be reviewed so that any contamination from a GMO not yet authorized in the EU but having passed a safety assessment equivalent to that required in the EU be allowed in imports to the EUii. Below, Friends of the Earth Europe presents why this proposal is unjustified.
1. 'Asynchronous' approval of new GM crops between US and the EU has virtually NO impact on EU feed imports
DG Agriculture and Industry are claiming that the longer time taken to authorize GMOs onto the European market blocks imports to the EU, thus cutting off essential animal feed.
GMO approval systems in different regions and countries
The EU has a relatively robust regulatory procedure for authorizing GMOs onto the market. This provides the opportunity for a scientific dialogue in an area of risk assessment where there are still major gaps in scientific understanding. In comparison, there is no approvals system for genetically modified foods or crops in the US. When a company wants to commercialise a GMO in the US, it has no obligation to consult the Food and Drug Agency, and there are no specific laws for GMOs. A safety assessment is only required if the company presents evidence that this is needed. Unsurprisingly, no company has chosen to do this up until now. GMO commercialization in the US is therefore due to the total absence of health and safety procedure. The US process for authorising GMOs does not meet international requirements under the United Nations' Codex Alimentarius, which are considered as the standard by the World Trade Organisation's trade dispute body. Furthermore, the US is not a signatory to the UN's Biosafety Protocol.
Contrary to the US, Brazil has stricter GMO laws based on the UN's Biosafety Protocol. The approvals system is currently blocked due to legal challenges concerning the correct implementation of GMO laws and it is therefore unlikely that new GMOs will hit the market soon. GM maize approval, for example, has already been blocked due to court proceedings.
Concerning Argentina, the Commission's DG Agriculture, has itself acknowledgediii that Argentina has historically been unwilling to authorize GM crops prior to EU approval and that the likely impact of the GM crop on exports is a consideration in the approvals process.
The EU procedures for authorizing GMOs will not block imports to the EU:
* The difference in timings is essentially between the EU and US. As the latter has nowhere near an equivalent health and safety assessment to the EU, the proposal to lower the zero tolerance standard as mentioned above cannot stand
* Key exporters such as Brazil and Argentina are attentive to EU market demands, and Brazil in particular has GMO laws in place closer to the EU system than the US.
The Case of Herculex GM maize
The case of Herculex Maize (DAS 59 122) has been widely reported as posing a severe problem for animal feed importers in the EU. Maize exported from the US, destined for the EU, was found to be contaminated with Herculex, a GM maize commercialised in the US but not in the EU. However, by April 2007, just a few months prior to the EU approving this maize, none of the countries from which the EU imports most of its maize - Argentina, Brazil, Serbia and the Ukraine has authorised or were growing Herculex. So when contamination was found in imports from the US and refused at port, the EU still had its other major suppliers.
2. Emerging markets: China does not pose a risk
China has been cited as a threat to the EU supply of non GM animal feed based on the idea that China has no health and safety requirements and so will import cheap GM feed. If this was the case, this could allegedly make feed producers move to GM varieties that are not authorized in the EU, thus cutting off feed for the EU market. But actually, China has a more precautionary approach to GMOs than the US, and is getting stricter:
* The Chinese Agricultural GM Crop Bio-safety Committee has been reorganized to include members specialized in environmental and biosafety issues.
* Certificates for GM commodities can only be granted for a maximum of five years, and are usually granted for three years or less iv.
* Any GMO imported into China must have proof that it is approved for commercial production in the exporting country.
* Once a company has requested approval to commercialise a GMO the Ministry of Agriculture has up to 270 days to reach a decision, therefore much longer than in the US.
* China has legislation requiring the return or destruction of food imports that contain unapproved GM materials, incorrectly labelled GM materials or materials labelled as non-GM which are discovered to contain GM material v.
* Beijing is considering legislation that would put in place monitoring of GM foods and require importing companies to bear the cost of recalling foods found to contain illegal GM materials vi.
* Furthermore, Chinese consumers are increasingly concerned about GM foods, and Kraft foods, the world's second largest food supplier, has announced that all foods produced on the Chinese mainland will not contain GM materialvii. China is also hesitant about approving GM crops because of the attractions of the non-GM market.
* Whilst the import of Monsanto's roundup ready soy has been approved, it has not been approved for commercial growing by Chinese farmers. This is partly because of recognition of the valuable premiums paid for non-GM soy in EU and Japanese markets. This sensitivity to EU markets is demonstrated by reports that the Chinese government has delayed approval of GM rice because of concern about the impact on exportsviii. Finally, China imports a different soy product (soybeans) than the EU (soybean meal) and therefore does not risk taking over from the EU as a major global importer:
* According to the OECD-FAO's most recent agricultural outlook report, by 2016 China will be the world's largest single importer of soybean products (although it does not predict in which year China will attain this position) ix. But China already imports more than double the quantity of soybeans than the EU imports. It is actually the market for soybean meal that the EU dominates, as this is used for animal feed, and the EU is predicted to remain the world’s largest single market for soybean meal x.
3. EU livestock crisis exists but not because of EU GMO laws: poor harvests and agrofuels
Rising feed costs are being blamed for serious problems facing producers in the EU, allegedly because of EU GMOs laws and the higher cost of non GM animal feed compared to GM feed.
* However, rising feed costs are also a problem in Canada xi, Australia xii, the US and China xiii.
* Rising feed prices in the pig industry are actually due to the recent price hikes in the cost of wheat and barley xiv, and shortages of feed wheatxv. [all of which are non-GM]
* In its most recent analysis, the UN's Food and Agriculture Organisation (FAO) stated that current high cereal prices are related to recent poor harvests in several food exporting regions xvi.
* Prior to the US governments mandates targets on ethanol production, the price of maize was tied to the price of food, but it is now strongly linked to the price of crude oilxvii, and as oil prices rise, so have maize prices. However, in comparison to wheat, prices for maize in the EU have not risen to the same extent xviii.
* In the case of soybeans, the FAO concludes that the recent high prices are due to increased demand worldwide for animal feed and the rising demand for the production of biodiesel xix.
* The policies most responsible for the current problems facing the feed industry are the US government's promotion of ethanol and the EU's agrofuels targets, which has led to significant promotion of biodiesel production.
4. What should the EU do?
The EU - as one of the world's biggest trading blocks - carries weight in the international arena. It should use this to support the European animal feed industry to produce non GM animal products. And it should promote and defend health and safety standards for people, animals and the environmental around the world. Friends of the Earth Europe is calling on the European Commission, Member States and Members of the European Parliament to:
* Help the EU livestock industry to source GM free animal feed
* Support the one million citizens that have signed a petition calling for products from animals fed with GM animal feed to be labelled. xx
* Support countries such Argentina and Brazil to establish assessment procedures comparable to international guidelines and the EU's own standards.
* Develop strict traceability and liability systems whereby the biotech company - the polluter pays and not the livestock importer, farmer or consumer
* Stand up to clear bullying tactics from the biotech industry and the US administration
* Drop the EU target that all fuels for transport contain at least 10 percent agrofuels by 2020
For more information, please contact:
i Mitchell P (2007) Europe's anti-GM stance to presage animal feed shortage?, Nature Biotechnology Vol 25 pp 1065-66
ii 'Economic Impact of Unapproved GMOs on EU feed imports and livestock production', DG Agriculture, June 2007; 'It's already one minute past midnight: The EU Farm Council must act on conclusions of the DG AGRI Report 'Economic Impact of Unapproved GMOs on EU feed imports and livestock production' Press release by COCERAL and FEFAC, 22/11/2007; Reference and Key Message Document Commission Report 'Economic Impact of Unapproved GMOs on EU feed imports and livestock production', EuropaBio, COCERAL, FEFAC, FEDIOL http://www.europabio.org/articles/Final%20Low%20Level%20Presence%20Reference%20and%20Key%20messages.pdf
iii 'Economic Impact of Unapproved GMOs on EU feed imports and livestock production', DG Agriculture, June 2007
iv Biosafety Clearing House of China website http://english.biosafety.gov.cn/
v Regulation on the Inspection and Quarantine of Import and Export of Genetically Modified Commodities: promulgated by Decree No. 62 of the Director-General on May 24, 2004 Available at the website of the National Biosafety Clearing House of China: http://english.biosafety.gov.cn/ vi Beijing plans to make food makers, sellers accountable for safety China Daily 26/07/2007 http://www.chinadaily.com.cn/2008/2007-07/26/content_5443898.htm
vii Jie L (2007) No Compromise China Daily 24/09/2007 http://www.chinadaily.com.cn/bw/2007-09/24/content_6128106.htm
viii Farmers' fear, food genetically modified, China Daily 03/01/2007 English translation at http://english.biosafety.gov.cn/news1/200703/t20070302_101257.htm
ix OECD/FAO (2007) OECD-FAO Agricultural Outlook 2007-2016
x Food and Agricultural Policy Research Institute, Iowa State University FAPRI Agricultural Outlook 2007 http://www.fapri.iastate.edu/Outlook2007/
xi The Amhurst Daily News, 03/12/2007 Requiem for N.S’s hog industry
xii Imports overwhelm pig industry Infarmation News Report 03/12.2007 www.infarmation.com.au
xiii China Daily 2/12/2007 China insures 45% of sows to ease pork shortage
xiv Bounds A (2007) EU could drop cereal import tariffs. Financial Times online 27 Novemeber 2007
xv UN FAO Food Outlook, November 2007
xvi UN FAO Food Outlook, November 2007
xvii Virginia Tech and Virginia State University Agricultural Extension Service. Weekly Roberts Agricultural Commodity Report 27/12/2007 http://www.ext.vt.edu/news/periodicals/roberts/2007wp/Nov27_2007.html
xviii UK DEFRA Food and Farming Brief September 2007. Annex 1
xix UN FAO Food Outlook, November 2007