The Farm to Fork Strategy aims to make farming healthier and more environmentally friendly – but it might also prove to be a back-door entry point for gene-edited products

The European Commission’s Farm to Fork Strategy (F2F) is a key component of the European Green Deal, a "new growth strategy" that "gives back more than it takes away".

F2F aims to make agricultural practices more sustainable. It promises to "strengthen... efforts to tackle climate change, protect the environment and preserve biodiversity" and to "increase the level of ambition to reduce significantly the use and risk of chemical pesticides, as well as the use of fertilisers and antibiotics".

So far, so good – but the Commission has prompted concern in some quarters by stating in a leaked draft version of the F2F Strategy that it plans to "assess the status of new genomic techniques under EU law and, if appropriate, follow up by submitting a proposal". The document presents GMO as a solution for climate change:

"Climate change brings new threats to plant health. The sustainability challenge in the field calls for measures to strengthen the protection of plants from emerging pests and diseases and for innovation. The Commission will adopt EU rules to reinforce vigilance on imports of plants and surveillance of the Union territory. New innovative techniques, including biotechnology, may play a role in increasing sustainability provided they are safe for consumers and the environment while bringing benefits to society as a whole. The Commission is carrying out a study to assess the potential of new genomic techniques to improve sustainability along the food supply chain."

The draft was produced in February, so we don't know if this controversial wording is still present.

The Commission has separately announced on its website its intention to perform a study on "a study in light of the Court of Justice’s judgment in Case C-528/16 regarding the status of novel genomic techniques under Union law".

"New genomic techniques" are, of course, new GM techniques. It is baffling that the Commission planned to assess their status under EU law because the European Court of Justice – the highest legal authority in the EU – ruled in 2018 that these new techniques fall under the EU's GMO regulations. That means that products of the new techniques must go through safety checks and carry a GMO label. Did the Commission really think it understood the law better than the Court? Or was it just desperate to find a way to rescue "new GM" from the scrutiny of safety assessments and labelling?

As for the Commission's potential "proposal", this is almost certainly an attempt to change the GMO regulations to allow gene-edited (and possibly all GM) products easier access to market.

If this was the Commission's intention, it would fit with what many see as the pro-GMO bias of certain people and divisions within the organisation. Its health division DG SANTE launched its "stakeholder consultation" on gene editing by overwhelmingly inviting organisations representing big industrial food and farming interests, rather than civil society organisations or organic and peasant farmer groups. Nina Holland of Corporate Europe Observatory commented, "Such a biased set-up raises concerns that the study is being designed to deliver a pre-determined conclusion."

The broader question is how gene editing can be assumed to have a place in a sustainability strategy, since there is no evidence to justify such an assumption. The assumption would have to be based on hypothetical benefits to sustainability, which may not be realised. On the other hand, gene-edited products could well make our food and farming systems less sustainable. For example, gene-edited herbicide-tolerant crops will bring with them an increase in herbicide use. But there's no sign that the Commission will incorporate into its study the risks to health and environment posed by gene-edited crops and foods.

The Commission has just concluded its public consultation on F2F. Below are short excerpts from the summaries of comments submitted by Beyond GM, Dr Michael Antoniou, Testbiotech, and Pesticide Action Network Germany. In each case, more detailed and referenced reports were submitted, which can be downloaded at the weblinks provided.
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Beyond GM

"Genome editing (GE) is currently being proposed as a way of improving sustainability in both plant and animal agriculture.

"While GE in agriculture is often bundled in with broader aspirations towards ‘technological innovation’, it stands wholly apart from other agricultural technologies in that it fundamentally alters living material at a genetic level, with unknown and largely unknowable consequences for health.

"These 'new' techniques are very much mired in old, and damaging, industrial ‘business as usual’ paradigms. For example, many are being used to produce herbicide tolerant and insect repelling plants, both of which have been shown to increase the use of environmentally damaging chemicals in the fields which ultimately encourage resistance amongst weeds and insects."

Dr Michael Antoniou

"As a scientist with 40 years of experience in using genetic modification techniques, including most recently gene-editing techniques, I am convinced that there is no place in the Farm to Fork Strategy for a proposal that would lead to gene-edited products being evaluated in a less stringent way than other genetically modified organisms (GMOs). ...

"Following CRISPR/Cas-mediated gene editing, a range of unintended mutations can occur at off-target and intended on-target editing sites. This can result in the alteration of multiple gene functions leading to altered plant biochemistry, which can lead to the production of novel toxins and allergens.

"It is also important to bear in mind that the unintended mutations at the intended editing sites occur after the gene-editing tool (CRISPR/Cas, TALEN, ZFN) has completed its task. Thus no matter how precise the editing event is made with regard to location, unintended mutations at the intended editing site of the type highlighted here will still take place.  

"These inevitable unintended outcomes from gene editing show that stringent process-based risk assessment must be applied to gene-edited organisms in the food supply, and farmer and consumer choice must be ensured through clear labelling, in line with European Union law as elucidated by the European Court of Justice ruling.

"It is necessary here to caution that contrary to frequent assertions of safety, there is a large body of peer-reviewed animal feeding studies attesting to harmful and potentially harmful effects on health from first generation GM foods and crops."

Testbiotech

The Farm to Fork strategy must ensure that both 1st and 2nd generation genetic engineering (GE) techniques need to stay regulated under EU law, ensuring risk assessment, labelling and post-market monitoring. This is important in order to achieve the F2F strategy's objectives of increasing transparency and consumer information, and reducing the environmental footprint of EU agriculture and food systems.

2nd generation GE: "Novel genomic techniques"

"In November 2019, the Council of the EU requested the Commission to submit, by 30 April 2021, 'a study in light of the Court of Justice’s judgment [...] regarding the status of novel genomic techniques under Union law'.

"New genomic techniques are frequently hailed by stakeholders from industry and science for their supposed benefits. They are also said to be less risky than conventional breeding because of their precision. It is argued that only those applications which insert novel genes (SDN3) should be regulated. SDN-1 and SDN-2 should be deregulated according to industry’s wishes.

"However, as our new report 'Overview of genome editing applications using SDN-1 and SDN-2 in regard to EU regulatory issues' shows, the need for regulation of SDN-1 and SDN-2 applications does not result solely from the ECJ judgment, but rather is also scientifically imperative.

"Higher precision in changing the genome does not necessarily result in greater safety or higher success rates."

Pesticide Action Network Germany

"PAN Germany welcomes that the roadmap of EU Commission´s 'Farm to Fork' strategy highlights the need for 'measures to significantly reduce the use and risk of chemical pesticides'. In this context, we would like to point out that especially those measures that include legislative changes need to align with the European Green Deal (EGD) objective towards a pesticide-free EU, and that current EU pesticide law has to be fully implemented. However, without clearly defined pesticide use reduction targets the strategy fails the seriousness of its purpose. Currently, the EU citizens' initiative Save Bees and Farmers demands on the EU COM to set an 80% pesticide reduction target by 2030 aiming a phase-out of chemical pesticide use by 2035. To meet these requirements the 'Farm to Fork' strategy must set an overall reduction target for pesticide use within a reasonable period. In regard, we agree with PAN Europe’s recommendation for a 50% reduction target until 2025."