The European Commission has recently launched its consultation process on “legislation for plants produced by certain New Genomic Techniques (NGTs)”, open for stakeholder responses until 22 July 2022. It is clear by the way in which the questionnaire and the options for answers are framed and by the small amount of space provided for stakeholders to contribute their point of view, that this Impact Assessment process is being undertaken in a truly biased way, with a clearly desired end result – a de-regulation of New GMOs – already in the Commission’s mind.
The questionnaire makes a number of false claims, including that:
• … the current legislation is described to be problematic for all stakeholders
• … there allegedly are no specific risks to NGTs; that their risk profile is claimed to be similar to conventional breeding and classical mutagenesis;
• … plants produced by targeted mutagenesis or cisgenesis are seen as “magic pill” for sustainability and that they are assumed to have great potential to contribute to Green Deal objectives;
• … new GM plants are considered as hardly detectable, and a differentiation from similar products produced by conventional breeding or classical mutagenesis would hardly ever be feasible because – as the Commission alleges - it will be difficult to prove which technique has been used.
The questionnaire does not provide a range of possible regulatory options for stakeholders to choose from (including the status quo – full regulation). This gives a clear indication that the European Commission is pushing for a wide-scale de-regulation of NGTs. The questionnaire is intended to give the impression of a real consultation. However, the Commission is clearly biased and leaves little room for stakeholder input not guided by its considerably biased questions. For example, 14 out of 18 questions in the questionnaire only have “tick box” options, leaving only 4 questions where stakeholders can give a (limited) written response.
The framing of the questionnaire primarily reflects the interests of the biotech and seed industries, and of trade partners with strong GMO industries. In the questionnaire, the Commission actively questions any GMO labelling, instead proposing labelling new GMOs as allegedly “sustainable”. In doing so, the Commission would severely impact the core of the Non-GMO and organic agriculture and food sectors who are dependent on transparently and properly labelled GMOs to exclude them from their value chains. Consequently, the Commission would act against an overwhelming majority of EU citizens who either do not want to eat GMOs or at least request them to be labelled.
ENGA is calling upon European Non-GMO producers and marketers to pro-actively participate in the consultation and firmly reject the threats on their business model it could lead to. ENGA will be providing in-depth guidance on the questionnaire.
For more information on the European Commission’s Impact Assessment process, please see our InfoPackage.