Possibility for the public to comment
7 October 2021 / While officially calling for adequate regulation and high safety standards, the EU Commission in reality seems to be following a different strategy: A document on future GMO regulation, published end of September, indicates a clear intention for far reaching deregulation of plants derived from new genetic engineering (New GE). Risks associated with the processes of New GE are either not given sufficient weight or are completely disregarded.
The Commission is in danger of proposing new EU regulation which is not sufficiently based on science, but driven by the interests of stakeholders with an interest in the application and marketing of these technologies and products.
It goes without saying that the Commission should develop its position in a non-biased and evidence-based way. Therefore, the Commission should correct its assumptions and begin an appropriate process for a fact-finding mission. In this context, the following issues in particular should be taken into account:
Using tools such as CRISPR/Cas gene scissors can generate specific patterns of genetic alterations (i.e. genotypes) that can lead to new traits (i.e. phenotypes) and outcomes, which can go far beyond what is achieved with conventional breeding. This is also true even without the insertion of additional DNA. Depending on the technical processes used, the unintended effects can be vastly different compared to conventional breeding.
Using tools such as CRISPR/Cas can also generate mutations that are already known from conventional breeding. In this context, it is simply not plausible that the companies are mainly interested in imitating genotypes that can be derived from conventional breeding. The situation is different in regard to patent applications: CRISPR/Cas in particular is frequently used to imitate genetic alterations derived conventional breeding. Companies then often use this as a ‘backdoor’ to extend the scope of the patents on conventional breeding.
The technical potential of New GE needs critical appraisal, especially in regard to the goals mentioned by the EU Commission, such as those for climate change, sustainability and biodiversity. Genetically engineered plants may disrupt or disturb interactions within the environment, and thus cause new problems. Furthermore, the use of New GE means that it is unlikely that crops tolerant to various environmental stressors can be developed just at the very moment they are needed.
Transparency, safeguarding consumer choice and development of organic agriculture should all be seen as major advantages of current EU regulations. Furthermore, the uncontrolled spread of GE plants that has been observed in many countries where these crops are cultivated, has mostly been prevented in the EU. These advantages should not be abandoned in the face emerging powerful New GE techniques, on the contrary, these should be subjected to continuous and comprehensive oversight as a matter of increasing urgency. The precautionary approach should, in addition, be strengthened.
Without sufficient regulation of New GE there is a likelihood of:
› serious damage to biological diversity;
› risks being introduced into food production that may accumulate unnoticed;
› no access or availability of data needed for risk assessment by independent experts;
› no measures being available to stop the uncontrolled spread of the organisms in the environment;
› no data being available to track and trace the New GE organisms and products derived thereof;
› no protection for agriculture and food production relying on GE free sources.
Christoph Then, firstname.lastname@example.org, Tel +49 151 54638040