New genomic techniques as an opportunity for more sustainability

                      Why we need differentiated regulation

• Directive 2001/18/EC (Genetic Engineering Act), based on the knowledge of the 1990s, does not reflect the current state of the art in science and technology and is therefore not suitable for innovative technologies such as new genomic techniques (NGT).

• In its study published in 2021, the EU Commission has highlighted the potential of NGT to master future challenges and intends to "improve the legal regulations" within the framework of a proposed timetable to “adapt the legal regulations in accordance with scientific and technical progress".

• The EU's GMO legislation differs from that of many other non-European countries. The latter do not regard plants as genetically modified organisms (GMOs) if they merely exhibit changes that are indistinguishable from those obtained in natural mutants or from conventional breeding and do not contain foreign DNA. These non-EU regulations also correspond to the current state of scientific knowledge.

• Even relatively minor changes to the existing rules and regulations would allow European GMO legislation to be adjusted to the state of the art in science and technology.

• A blanket legal classification of genome-edited plants as GMOs is, from a scientific point of view, not comprehensible in many cases: NGTs can be used to introduce small mutations or larger genomic changes. If only small changes have been made in the genome, such a plant is indistinguishable from one that has been bred by conventional mutagenesis or occurred naturally.

• New plants must be assessed according to their potential risk to have effects on the environment and for their safety for human or animal consumption. They should be assessed according to their properties, but not according to the process by which they are produced.

• A scientifically comprehensible regulation of NGTs is essential in order to help address ecological, economic and societal challenges - for example, with regard to the urgent need for more climate-resilient, nutrient-rich, healthier and higher-yielding crops.

• The goal of a regulation cannot be a rigid adherence to a formal legal assessment of certain breeding methods. Instead, the sustainability balance of the resulting products should be evaluated. And this in all dimensions: sufficient and healthy food for a growing world population combined with environmentally and climate-friendly production.

• Without technical and breeding innovations, it will not be possible to produce enough food in Europe without at the same time bringing new areas (in Europe or elsewhere) into agricultural use at the expense of biodiversity.

• Ongoing climate change and the need for sustainable and resource-conserving agriculture make it necessary to overcome the prevailing confrontation among "organic/conventional/genetically engineered". Only in this way the EU can achieve its own goals - such as halving the use of "synthetic pesticides" by 2030 or increasing the share of organic farming to at least a quarter (farm-to-fork strategy).

• A combination of organic farming and NGT would be helpful in order to be able to grow more food with less land use and using fewer resources in the long term to ensure a sufficient supply of food.

• Small and medium-sized enterprises as well as research institutions can apply NGT with comparatively little financial investment. Broad access and use of the technology would therefore make sense in terms of innovation policy, since the diversity of approaches facilitates rapid learning, diversified solutions and increased participation.

• Failure to adapt genetic engineering legislation will have lasting negative effects on research and development:

 - Current genetic engineering legislation reduces the willingness to invest in research. Much

   needed climate- and disease-resilient, higher-yielding and healthier plants cannot be bred in

   a timely manner.

- The loss of research funding threatens a massive loss of know-how in Germany and Europe.

-  The use of the potential of NGT is increasingly becoming the privilege of a small group of

   financially strong multinational corporations. This makes investment in research and 

   development in Europe unattractive. European research will fall behind in international

   competition.

• The outdated GMO legislation in the EU is likely to disrupt international trade and have consequences for food security because many of the crops bred by NGT are identical to naturally occurring mutations and are often undetectable. This means that the EU's current controls under existing GMO legislation cannot be enforced at all when NGT-derived food and feed is imported in Europe.

• Dealing responsibly with technology-driven developments means weighing positive and negative effects against each other, to monitor them and, if necessary, to intervene. The precautionary principle must not be linked to speculative risks, but must be applied on the basis of science.

Contact:

WGG: zentrale@wgg-ev.de,

VBIO: berlin@vbio.de

13.10.2022