The majority of consumers in Germany do not want genetic engineering to play any part in food, in plant cultivation, or where livestock is kept. They wish to see strict criteria for safety and risk assessments for genetically modified plants, and the use of clear labelling.
There is intensive discussion about new genomic techniques (NGTs) such as genome editing, for example CRISPR/Cas. Some plant breeder associations, companies, and scientists call for plants and animals created with the help of NGTs to be exempt from European legislation on genetic engineering.
The Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband – vzbv) wants to see the genetic engineering legislation retained, and for it to continue to apply to NGTs without any loss of stringency. Plants and animals created in this way must be traceable every step of the way and clearly labelled. It is essential to assess any potential environmental or health risks they may pose and monitor how they are used.
- Mandatory labelling when genetic engineering, including NGTs, is used in food.
- Protecting agriculture that does not use genetic engineering via strict co-existence rules in order to safeguard consumers’ freedom of choice.
- Retaining the current European legislation on genetic engineering and thus also strict approval procedures and risk assessment, including for NGTs.
- Funding for independent research into risks and the development of obligatory documentation procedures in the case of NGT use.
- Comprehensive risk analysis for NGTs by the European Food Safety Authority (EFSA).
- Potential special approval procedures for NGTs must contain a comprehensive assessment of the technology’s impact.
- A national ban on cultivating genetically modified plants based on the European directive on the release of genetically modified organisms (GMOs) into the environment.
- No patents on life, even in the case of conventional breeding.
Consumer interest in product and process quality has risen strongly in the last twenty years, particularly due to numerous food crises. The fact that the 2003 EU Regulation on GMOs included labelling for production processes was thus very much in consumers’ interest. It legislates not only food and animal feed containing GMOs, but also food and animal feed produced from GMOs.
If it is no longer possible to prove the presence of GMOs themselves, for example in the case of refined plant oil, then proof in the form of documentation is required. Origins and production processes must be traceable and the products clearly labelled. The development and use of such instruments, including with respect to NGTs, reflects consumer expectations and must be safeguarded by the European Commission.
After all, the majority of people in Germany take a critical view of the use of genetic engineering in food and agriculture, even after twenty years of debate about the respective risks and opportunities. This also applies to NGTs such as CRISPR/Cas.
More than two decades ago, traditional genetic engineering campaigned with a promise to make agriculture more sustainable, to reduce hunger, and produce especially healthy plants for human consumption. These promises have not been fulfilled – on the contrary. Plants brought to market, particularly in North and South America, were above all herbicide-resistant plants that can survive weed killer spread over an entire field and thus threaten biodiversity.
Proponents of NGTs from science and the food industry now once again promise plants that can contribute to sustainable agriculture and thrive despite climate change. It is, however, unlikely that NGTs can help develop such types of plants. The processes in nature and the interaction between genome, plant, and the environment are too complex for this.
Sustainable, resilient cultivation systems are indeed needed to adapt agriculture to climate change. However, genetically modified plants that are generally cultivated as monocultures and over large areas may displace plant types that are adapted to the location and require less fertiliser, protective agents, and irrigation.
Once genetically modified plants have been introduced, they can spread in an uncontrolled manner. It is not possible to reverse this development and in the worst-case scenario it may threaten an entire ecosystem. Furthermore, once genetically modified plants have been introduced, they make it much more difficult to practice GMO-free or organic agriculture in the area.
The properties that NGTs produce often lead to far-reaching changes and entirely new biological properties that are extremely unlikely in the case of conventional breeding. This may lead to unintended and not entirely controllable interactions with the environment and pests, with a knock-on effect on, for example, climate, animal protection, and food safety. Such unintended effects may also arise when the genetic intervention is judged to be targeted and precise.
A large majority oppose genetic engineering in agriculture and do not wish to purchase products produced in this way. This opposition extends to new techniques such as CRISPR/Cas. Surveys repeatedly confirm this (see, for example, here, here (pdf) and here (pdf) - in German).
Many consumers are worried that genetically modified animals and plants will spread uncontrolled in nature and thus threaten ecosystems. Consumers also oppose genetic engineering techniques designed to improve the “performance” of livestock, for example in milk production, as this focus on performance often comes at considerable cost to animal welfare. Most consumers want to see a careful consideration of and research into risks, and use of the precautionary principle. They also want to see continued, strict regulation of genetic engineering in agriculture.
The European Court of Justice’s (ECJ) 2018 ruling stated that genome editing is to be regarded as a form of genetic engineering and will thus continue to be subject to the EU’s risk assessment and approval procedures as well as labelling rules for genetic engineering. The justification for the ruling is that genome editing can aim at effects similar to traditional genetic engineering and, furthermore, the associated risks are unknown.
Following the ECJ’s ruling, Member States asked the European Commission to investigate how the various EU countries are dealing with the topic and what potential problems they have identified. The European Commission also planned to assess the potential consequences, so that new legislation can be proposed. The Commission has said that it regards relaxing legislation with respect to NGTs as one option. Proposed legislation is expected in 2023.
A broad alliance of stakeholders opposed to relaxing current legislation, including environmental, agricultural, and consumer associations, wants to see the current genetic engineering laws retained and applied to new techniques with a case-by-case analysis of modified organisms. This alliance opposes the European Commission’s idea to possibly exempt certain techniques from the current regulations.
Numerous organic and traditional retailers and food producers are also in favour of maintaining the current legislation. They argue that abiding by the precautionary principle is the sole way to ensure risk assessment, transparency, and freedom of choice.
An expert opinion commissioned by vzbv shows that certain important questions relating to NGTs still require clarification. Many scientists point out that the new techniques pose potential risks to people and the environment that have not yet been sufficiently investigated. A comprehensive risk analysis of NGTs, which also systematically looks at the unintended effects, has yet to be carried out.
vzbv calls for continued strict regulation and labelling to protect consumers from risk, enable freedom of choice, and prevent damage to ecosystems and biological diversity. Promises about sustainability from providers of these techniques are not sufficient reason to relax safety and labelling standards.
Specifically, vzbv considers the following points key:
- Risk assessment and approval procedures: All animals and plants that are produced using NGTs must be subject to risk analysis and an approval procedure.
- Labelling and freedom of choice: Food produced with the help of NGTs must continue to be labelled as such.
- Assessment of possible consequences: If the European Commission introduces new, special approval procedures for NGTs, they must consist of obligatory risk analysis and a thorough and forward-looking assessment of the techniques’ possible consequences. In accordance with the precautionary principle, the actual need for such techniques as well as other, potentially less risky alternatives should be considered in detail.
- Thorough risk analysis by the EFSA: The European Food Safety Authority (EFSA) must be entrusted with presenting a thorough risk analysis of NGTs which also systematically examines the possible unintended effects.