Testbiotech comment on EFSA’s assessment of genetically engineered soybean SYTH0H2 for food and feed uses, under Regulation (EC) No 1829/2003 (application EFSA-GMO-DE-2012-111) by Syngenta

TESTBIOTECH Background 20 - 2 -2020

Soybean SYTH0H2 contains genes conferring resistance to two groups of herbicides:
• pat - for tolerance to the herbicide glufosinate
• avhppd-03 - for tolerance to mesotrione and other HPPD inhibitors (such as isoxaflutole).

Implementing Regulation 503/2013 was not applied in this case because the application was submitted in 2012, one year before the Implementing Regulation came into force. Therefore, EFSA assessed the application under its old guidance documents which are now seven (!) years out of date.

Soybean (Glycine max) was genetically modified to express an hppd gene derived from oat (Avena sativa), designated avhppd-03. This gene encodes a modified p-hydroxyphenylpyruvate dioxygenase isozyme (AvHPPD-03) that differs from the native HPPD isozyme from A. sativa by one amino acid. The avhppd-03 gene is linked to a constitutive promoter that expresses avhppd-03 at a higher level than that of soybean native hppd gene (see EFSA, 2020a and 2020b).

Tolerance to glufosinate ammonium herbicides is accomplished by the expression of a pat gene derived from the soil microorganism S. viridochromogenes, strain Tü494. The PAT protein inactivates the herbicide glufosinate ammonium, which is an inhibitor of glutamine synthetase, an enzyme in the nitrogen assimilation pathway (see EFSA, 2020a and 2020b).

If the soybean would be allowed for import, it is not unlikely the products a unique toxic mix of residues from herbicides that are carcinogenic, endocrine disruptive and show reproductive toxicity - with no testing of combinatorial effects at the stage of consumption being carried out. Furthermore, it is likely that the genetic engineering caused the plants composition to change unintentionally. The data presented are insufficient to demonstrate safety.

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