“Neither scientifically justified nor suitable to adequately address potential risks of NGT plants”

New study highlighting fundamental flaws in the European Commission proposal to deregulate NGT plants

June 17, 2025

A new study conducted by experts at the German Federal Institute for Nature Protection (BfN) highlights a number of basic deficiencies in the European Commission’s proposal on New Genomic Techniques (NGTs) in plants. The Commission proposal is said to be “neither scientifically justified nor suitable to adequately address potential risks of NGT plants”. According to the scientists, the proposal would even allow plants with complex genetic modifications to be released into the environment without prior risk assessment.

In the preprint, the experts analyse the Commission’s proposal to define plants below a certain number of mutations as ‘safe’. The Commission (in short) considers NGT plants with no more than 20 genetic changes to be equivalent to conventionally-bred plants. However, the German experts stress that this approach ignores fundamental genetic principles and statistic probabilities: “However, the proposal underlies a misconception that all conceivable genetic changes or combinations could occur at some point if crosses or mutagenesis were only carried out long enough. Neither the proposals overall concept nor the Annex I criteria are able to capture the ultimately decisive genomic context that determines functionality and the risk potential of NGT-produced plants.

Consequently, the scientists consider the Commission proposal to be invalid to correctly address the risks of NGT applications. They also underline that artificial intelligence (AI) can be used to generate very complex biological constructs, which could nevertheless still be below the proposed threshold. The latter could include the production of new proteins, potentially insecticidal molecules or drastic changes in gene regulation.

Testbiotech and others recently showed that the criteria proposed by the Commission can be used by AI, for example, as guidance to specifically design insecticidal NGT plants that are purposed to avoid environmental risk assessment and benefit from fast track approval.

Currently, the Commission proposal is being discussed in trilogue negotiations and will face a final vote in the next weeks or months. Testbiotech is demanding that the Commission proposal be rejected as it does not provide adequate regulation for the safe handling of NGT plants.

Contact:

Christoph Then, info@testbiotech.org, Tel + 49 151 54638040

Further information:

The study by BfN experts

The report on AI-designed insecticidal NGT 1 plants