The proposal of the EU Commission should be rejected unless it undergoes major revision and amendments. If the proposal is fundamentally revised and amended, the following points should be implemented:

1. Category 1 of the proposal should be deleted;
2. Category 2 should be amended and applied to all domesticated NGT plants that cannot persist, spread or propagate in the environment;
3. The current GMO regulation should still apply to NGT plants that belong to non-domesticated species or to domesticated species that can persist, spread or propagate in the environment;
4. Make sure that all intended and unintended genetic changes and their potential effects caused by the processes of NGTs, which are unlikely to result from other ‘at random’ processes, are subjected to molecular risk assessment;
5. Make sure that no unintended insertions of transgenes and their fragments can escape the approval process;
6. Amend the NGT regulation to assess, control and mitigate potential interactions between NGT organisms that share the same environments;
7. Data on the genetic changes introduced into the plants are the main basis for any risk assessment, and the data must be made available to the public and independent experts.