In its “Vision for Agriculture and Food1” for a competitive, resilient, future-oriented, and fair EU food production system, the Commission clearly acknowledges that NGTs are key to contribute to the EU’s food security and that an enabling regulatory framework is needed to ensure a level-playing field with third countries. The undersigned agri-food value chain partners support this ambition and welcome the Commission’s commitment to working in close cooperation with the Council and the European Parliament to find a forward-looking compromise on the proposal for a Regulation on plants produced by certain NGTs. A science-based and proportionate legal framework for NGT plants and derived products is essential to strengthen the competitiveness and resilience of the European agricultural and of the food and feed supply systems, considering the sustainability and climate change challenges.
In view of the upcoming trialogue negotiations, we reiterate our strong concerns for the discussions about the possible introduction of unjustified, mandatory labelling requirements for conventional-like NGT plants and products and their negative impact on the development and uptake of NGT plants and products, on trade as well as on the EU’s competitiveness.
The core spirit of the Commission’s NGT-proposal aims at differentiating NGT plants and products that are equivalent to conventional plant varieties (Category 1) from transgenic products subject to the regulatory framework for GMOs. The Commission proposal ensures transparency and freedom of choice for farmers which allows the establishment of supply chains that wish to produce according to certain standards to respond to market demands.
The balanced approach of the European Commission should not be undermined by requiring traceability and mandatory “New Genomic Techniques” labelling for the Category 1 NGT plants and products at all stages of the supply chain, including for the end-consumer. Such requirements are discriminatory and very challenging to implement due to several factors:
Technical constraints, enforcement challenges associated with the traceability and labelling of new genomic techniques (NGTs)
• NGT Plants classified as Category 1 could, by definition, originate from conventional
breeding, meaning they are indistinguishable from conventional and natural
variants using current analytical methods. These technical limitations present
significant challenges in developing workable traceability systems for Category 1
NGT plants and products.
• Especially for imported feed and food, business operators will not be able to verify
the presence of Category 1 NGT plants and products with analytical methods.
Harming the competitiveness of the food and feed supply chain and trade of
Category 1 NGT plants by creating unjustified additional costs associated with the
traceability and labelling of new genomic techniques (NGTs)
• Mandatory labelling would necessitate the physical segregation of the NGT products
and commodities at each stage of the supply chain, multiplying storage and
transport facilities, processing paths, and increasing costs. Given the bulk nature of
the grains market such segregation would be impossible for most commodities and
would negatively impact NGT plants and products’ development and trade as well as
cost-efficiency and competitiveness of the food and feed supply chain. It would3
ultimately impede the development and uptake of NGT plants and products by entire
value chains, while lead to raising prices to consumers at a time when food inflation
is recognised as a sensitive issue in the EU
• A recent study from Wageningen University3 highlights that such requirements could
reduce the economic benefits of conventional-like NGTs by up to 80% and make
their adoption economically non-viable. Mandatory traceability and labelling for
Category 1 NGT products requires recordkeeping at all stages of the value chain and
comes with a cost in financial and human resources for seed breeders, farmers,
primary food producers and for all operators along the chain. This also results in
administrative burdens for the entire supply chain, both in the EU and in third
countries, which cannot be justified by any science-based safety grounds.
Discrimination and misleading consumers
• Tracing and labelling similar products differently (Category 1 NGT plants and
products vs. conventional) is clearly discriminatory and could be wrongly
perceived as a safety difference between conventional and Category 1 NGT plants
and products. This could create confusion among consumers who generally lack the
knowledge and understanding of the different breeding techniques being used
already now for decades; also, Category 1 NGTs have been reviewed by EFSA4 and
are deemed both safe and equivalent to conventionally bred plants.
• Such misperception is likely to result in consumers scepticism, making it difficult to
market NGT plants and products. This could disincentivise academic institutions,
and companies, from start-ups and SMEs to bigger enterprises, to innovate in
plant varieties adapted to the EU needs that could – amongst many other things –
contribute to a more competitive and sustainable EU agriculture and food and feed
system.
Transparency of information
• The database listing the decisions declaring category 1 NGT plant status as foreseen
in the Commission proposal ensures sufficient transparency and choice for
researchers as well as public and private seed breeders who wish to use or avoid
NGT1 plants.
• Farmers, who will be the primary users of seed varieties obtained by category 1 NGT
plants, make their selections based on the national variety lists or the EU Common
Catalogue of Varieties including the information about the use of category 1 NGT
plants and as mandated by the PRM (Plant Reproductive Material) legislation. This
ensures that the supply value chains can create differentiation responding to
specific demands of certain consumers.
Global regulatory landscape
• More than 25 countries around the world have already implemented new policies for
NGT plants. None of them require any traceability and labelling of conventional-
like NGT plants and products. The number of regulatory decisions to exclude
specific NGT plants from GMO regulations is increasing towards 300 around the
world. Commodity suppliers and business operators from third countries would
struggle to meet the scientifically unjustified EU-specific labelling requirements
and would redirect their production towards markets with more enabling and fit-
for purpose regulatory requirements.
We, the undersigned agri-food value chain partners, urge the EU institutions to rapidly adopt a much-needed, fit-for-purpose, future-proof, proportionate and workable EU regulation for NGT plants and products. This will enable the European Union to develop plant breeding innovation adapted to EU’s climate and environmental challenges, strengthening its competitiveness, while ensuring a level-playing field with third countries and preserving EU and global trade of NGTs.
We remain fully committed to further contribute to the discussion to explain our position.
To read the full position please follow this link