Commission opens public consultation on new legislation for new genetic engineering techniques
The EU Commission launched a 12-weeks consultation period in the context of the Impact Assessment for new legislation for ‘New Genomic Techniques’ (new genetic engineering techniques or NGTs).
The consultation takes the form of a questionnaire, available on the “Have your say” website and open for participation from citizens, companies and associations. The deadline for submitting your application is 22 July. To participate, you need to register or use an existing account.
IFOAM Organics Europe will reply to this consultation on behalf of the European organic movement. We will share a technical analysis of the questionnaire with our members by June.
Consultation fails to provide available policy options
In a first assessment, the Impact Assessment and related public consultation reveal various shortcomings, however. Based on the EU guidelines for better Regulation1, an impact assessment should identify available policy options, based on which the benefits, costs, risk of unintended consequences and implications for different stakeholders can be assessed.
In this light, it is striking that the public consultation is failing to name concrete options on how the rules could look like and thereby does not give stakeholders like the organic sector the opportunity to provide concrete feedback to different ways forward.
This is somewhat unusual, given that policy options were presented in other (related) legislative procedures, for example the review of rules for Plant Reproductive Material. This is an unsatisfactory basis for a public consultation and keeps stakeholders in the dark on the scenarios analyzed in the impact assessment and how the economic impacts on the whole food chain (including organic production) would be assessed.
Creating a new legal framework for NGTs could leave GMOs undetectable
As IFOAM Organics Europe, we already expressed our concerns that taking NGTs out of the existing legal framework applying to GMOs for agriculture and food is worrying news. This could leave organic food systems unprotected, as GMO’s traceability in the food chain is essential to avoid contaminations, which lead to economic losses for organic and GMO-free operators (who live up to high organic quality standards and consumer expectations).
Currently, the traceability and labelling system is laid out in a Regulation and two Directives (2001/18, 1829/2003 and 1830/2003).
Connected to this is an apparent lack of concrete proposals on how to ensure co-existence with existing agricultural practices. This should be a key element of any legislation regarding NGTs and the current approach of the Commission is a worrying sign, as it suggests that this issue has not been properly investigated yet – despite IFOAM Organics Europe having raised this issue repeatedly.
Given these shortcomings, there is limited possibility to provide concrete feedback in the context of this consultation. Concrete policy options should be provided as soon as possible to respect the guidelines for Impact Assessments and allow meaningful stakeholder participation.
For more information on GMOs and new GMOs and IFOAM Organics Europe’s work on this issue, please contact firstname.lastname@example.org. IFOAM Organics Europe members can find more information on the member extranet and background materials in the arguments database on the member extranet (main messages, arguments/FAQs, visuals & videos). Contact email@example.com for access rights (issues).