Brussels, Belgium
December 10, 2002

EuropaBio welcomes the Environment Council's decision to complete the GM legislative package. "While yesterday's decision paves the way for a common position on new legislation for GM food and
feed in Europe it places onerous burdens on the European Agro-Food industries and on national authorities who will have to enforce the law," says Simon Barber, Director of the Plant Biotechnology Unit at EuropaBio (1). "It is important to underline that these rules are not about safety rather they are
about how to extend labelling of GM products to meet consumer choice."

The Environment Council has confirmed its policy of extending labelling to all end products derived from GM crops irrespective of whether they are physically and chemically identical to products derived from non GM like sugars and oils. "In theory labelling must apply to all ingredients derived from GM products, but in practice can only be checked in those that have detectable novel DNA or protein," says Simon Barber. This will force the food industries to duplicate their systems to meet European requirements of keeping identical products separate, increased costs will be incurred (2).

"In essence, the labelling regime now proposed requires GM labels on foods that do not contain any GM material, so that people can avoid something that is not there." EuropaBio, supports labelling of food and feed that can be verified through testing (3)

It is because of the policy decision to extend labelling to products that do not contain GM protein that the traceability proposal has to go further than simply putting in place the requirement for detection tests for the tracing of GM protein. The traceability requirements for GM Food and Feed, and derived ingredients are in addition to the existing EU traceability rules for food and feed (4). Furthermore, rules governing the growing of GM crops (Directive 2001/18/EC) already provide for a high level of safety by
requiring the monitoring of their behaviour to enable their tracing and withdrawal from the market if a safety issue is identified (5).

The Environment Council has also broken with the Cartagena Protocol, by insisting that bulk commodities be labelled differently to what the International Treaty demands. The same Environment Council had agreed to the Protocol text only a few months ago. EuropaBio supported the Commission's proposal to label bulk commodities intended for food, feed or processing as "may contain" accompanied by a single list of all GM crops that made up the bulk of the commodity at its original source.

The consequences of increased demand for non-GM food and feed supplies to Europe has not been adequately considered by the Environment Ministers either. Globally, more than 5.5 million farmers are growing GM crops on more than 50 million hectares (6), which will lead to some technically unavoidable trace levels (adventitious presence) of these in non-GM food and feed products. EuropaBio supports the Commission's proposal to exempt products that have less than 1% trace levels of GM from labelling.

The Council Common Position will be submitted for a Second Reading to the European Parliament in early 2003. EuropaBio looks to the Parliament to agree practical rules that are enforceable and that strike a proper balance between the interests of the environment, consumers, industry and authorities. EuropaBio asks legislators to consider biotechnology as a part of the toolkit that will help European agriculture develop a more harmonious balance between food production and our surrounding environment. Evidence that GM crops are good for the environment and for the competitiveness of agriculture is mounting in those parts of the world that are already growing GM crops (7).

(1) EuropaBio has almost 40 corporate members operating worldwide and 20 national biotechnology associations representing some 1200 SMEs involved in research and development, testing, manufacturing and distribution of biotechnology products. EuropaBio, the voice of European bioindustries, aims to be a promoting force for biotechnology and to present its proposals to industry, politicians, regulators, NGOs, and the public at large. http://www.europabio.org 

(2) Costs
a. GM Crop Market Dynamics: - the Example of Soya Bean The European Federation of Biotechnology
http://www.efbpublic.org
b. University of Guelph in Ontario estimated that labeling could result in a 9 percent to 10 percent increase in retail prices.
c. Arcadia International - Additioinal costs for European Agro-Food Sector by the labelling and tracing to avoid GM in European Food and Feed

(3) The House of Lords Select Committee on Traceability and labelling (April 2002) sees problems enforcing mandatory labelling on products that cannot be tested.
http://www.parliament.the-stationery-office.co.uk/pa/ld200102/ldselect/ldeucom/117/11701.htm 

(4) Regulation on Novel Foods and Novel Food Ingredients of 27 January 1997 (Regulation (EC) 258/97). General Food law (Regulation 178/2002/EC).

(5) Directive 2001/18 - European Commission Questions and Answers on GMO
http://europa.eu.int/rapid/start/cgi/guesten.ksh?p_action.gettxt=gt&doc=MEMO/02/160|0|RAPID&lg=EN&display=

(6) ISAAA -
http://www.isaaa.org/publications_download/Brief%2024.pdf

(7) Environmental and economic benefits of agricultural biotechnology
a. EuropaBio Fact Sheet - Green biotechnology - a help to the environment (www.europabio.org)
b. Agriculture Biotechnology Europe (ABE) - Economic impacts of crop biotechnology
http://abeurope.dynamicweb.dk/images/files/abe_issues_paper_5.pdf