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Agriculture and Environment Biotechnology Commission (AEBC) | |||
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CONSUMER CHOICE GROUP Ms Helen Browning Dr Rosie Hails Ms Julie Hill Professor Jeff Maxwell Dr Sue Mayer Dr Roger Turner (Convener) Apologies 1. Dr Sue Mayer had sent apologies. Minutes of previous meeting 2. The minutes of the previous meeting were agreed. Evidence from DEFRA and FSA officials 3. The group welcomed Linda Smith and Claire Lewis from DEFRA, Louise Ball from the ACRE Secretariat and Sue Hattersley from the Food Standards Agency. 4. Roger Turner began by asking the background to why the figure of 1% was chosen in EC legislation as the threshold for adventitious presence (AP) of GM in non-GM products and the thresholds for seed. 5. Linda Smith said that the figure had been chosen as an achievable level of detectability, giving sufficient margin for error, and acceptable to consumers. It continued to be used because it seemed to be working as a limit. 6. The group asked what principles DEFRA adopted when taking its position on AP thresholds for seeds and other material. Linda Smith said that technical limits informed the UK Government view, as did proportionality - not increasing unduly the regulatory burden, while recognising the desire on the part of some consumers to exercise a choice not to eat GM foods, which implied a threshold of some sort because of the impossibility in many cases of guaranteeing a zero threshold and not being able to test for it. Different countries had different views on what was a desirable threshold but DEFRA were unaware of any country imposing a lower threshold than 1% in this context. In some countries higher thresholds often applied for bulk commodity crops: in Japan, where there was a market for identified-preserved (IP) soya, 5% was a usual threshold. Lower thresholds than 5% commanded a premium in the market. 7. The group asked what studies DEFRA had carried out on the costs associated with and practicability of the 1% threshold prior to its adoption. The answer was none as such: the UK Government view had been informed by advice from Central Science Laboratories (CSL) and other parties at the time. The decision has been made at EU level. Asked if DEFRA had weighted the advice from the various parties and whether their advice could be made available to the group, Linda Smith said that she was not aware of a body of material as such; and the 1% figure had not been revisited by Government in the context of the current EU negotiations. None of the submissions in the context of consultations on the seeds, food and feed and labelling and traceability draft regulations had persuaded Government that there was a better option than a 1% threshold (with corresponding lower thresholds for seeds). CSL continued to provide advice to DEFRA on detection methodologies. 8. Sue Hattersley explained that the FSA had undertaken research on detection of GM soya in processed bakery products; and confirmed that the FSA had not commissioned research into IP production systems. The sub-group asked about the methodology underlying the baked goods study. Ms Hattersley promised to write with details of the soya study. Action: FSA 9. The FSA had also funded a study by NERA (National Economic Research Associates) on the economic implications of labelling options. This had been used to underpin a partial Regulatory Impact Assessment (RIA). The sub group asked how important the NERA study had been to determining UK policy on the proposed regulations. Was the NERA study not supposed to have been a multi-criteria assessment? It did not appear to have turned out that way. What principles had underpinned it? Had it been peer-reviewed? Sue Hattersley said that the report had certainly been published on the FSA website. She would write to the group with more details about that and the partial RIA. The sub-group said that they might wish to pursue the question of the methodology used in the study. Action: FSA 10. The group asked about the costs to farmers and other parts of the agricultural supply chain of the informal moratorium on new GM approvals. Linda Smith said that it was a costly and serious problem. A large number of the constructs presently unapproved for consumption or cultivation in the EU were licensed for production elsewhere. Others were licensed for import into but not cultivation in the EU. There were associated increased costs for industry in testing, particularly for unauthorised material, as well as for levels of authorised GM constructs. One seed producer had told DEFRA that extra costs of £6m per annum were being incurred as a result of testing for unauthorised GM constructs. DEFRA thought that the extra costs problem was likely to get worse rather than better. 11. The group asked how testing and approval regimes compared abroad. Linda Smith said that the criteria for approval in the US, the most important country in terms of GM cultivation, were almost identical to those in the EU in terms of human health and environmental impact. The OECD was looking at the possibility of a harmonised set of standards for approvals. 12. The group asked for officials’ assessment of the prospective solutions. DEFRA believed that the decision-making process needed to be restarted. The informal moratorium was illegal. Member States, however, were split on the way forward. The UK also saw merit in pursuing the prospects for an international harmonisation of approvals or at least clarity about how the demands of EU-wide or national Member State approvals were to be reconciled with international trade. Importers had to exercise due diligence in testing for unapproved varieties. The present situation was already increasing costs in the food production chain. Costs lay where they fell; there had not been full consideration and public debate in Member States on where present costs and those which would result from the revised regulations ought to lie. There was also an issue about the proposed labelling of GM-derived products such as oils or sugar that could not be tested, as they contained no altered DNA. If adopted, these regulations would require a traceability regime that would again impose costs. The UK had made clear its opposition to this aspect of the regulations. New developments in the application of GM technology, such as plants engineered to produce pharmaceutical products, could potentially add to the testing burden, if there was seen to be a risk that produce from these plants could be found in food crops. 13. The group asked if the assessment was that the burden of the extra costs would fall primarily on importers. Given that there was already a need to test for unapproved material, how much of an additional burden would the new regulations impose on importers? Ought the costs to fall to those introducing the new technology? Or should it be up to those who wished to avoid it to pay extra for this, similar to the premium paid by some people for organic produce? 14. Officials said that what was clear was that the system imposed extra costs, but it was not clear where all the costs fell or would fall. DEFRA had been considering funding a study on where the costs would fall and the implications for UK farming and agricultural industries. It now expected that these issues would be covered in the study of economics announced by Mrs Beckett and expected to be carried out by the Prime Minister’s Strategy Unit alongside the GM public debate. 15. The group discussed how to determine the answers to the questions about the economic implications of the testing and labelling regime. There were technical limits to what could be tested for. Testing and traceability requirements imposed costs across the whole system of production and not only in respect of increased costs arising from the technical issue of testing. The group hoped that the SU study would undertake a sensitivity analysis and not focus only on absolute costs. 16. On the thresholds for AP in seeds, Linda Smith said that the UK was content with the figures set in the European Commission’s proposals, which were derived from the threshold of 1% for food. The sub-group said that it would be interesting to see the results of modelling of the impact of the proposed thresholds for seeds for co-existence of GM and non-GM agriculture in Europe. The impact of thresholds on potential co-existence did not seem at EU level to be the leading consideration in setting the threshold levels. 17. The group asked what thinking was going on within the UK Government and elsewhere in Europe on co-existence. Linda Smith said that there was a good deal of thinking going on. A number of recent studies had been published on the implications of AP thresholds for co-existence in Europe. As people would expect, DEFRA had been considering co-existence in the UK environment. This included thinking about both the technical issues and policy options. DEFRA expected that the technical issues and the options would feature in the public debate on GM and in the science review. DEFRA had no plans at present to commission new research relating to co-existence. 18. The sub-group said that it would be very helpful to know about the work going on in DEFRA or commissioned by the department. They felt somewhat in the dark about what Government planned in this regard. The group did not want to commission research to support its consideration of co-existence issues which would duplicate work already going on in DEFRA or elsewhere. The group agreed that it would be important to get abreast of the research going on in Europe and the UK. It might make recommendations to DEFRA about what research was needed, in the light of existing research and what work seemed likely to be undertaken as part of the science review and SU economics study. The group said that it was very important that the research and analysis was firmly grounded in practicalities - how co-existence might be possible depended on modelling that took account of agricultural practice and the realities of the agricultural supply chain. Officials agreed. NIAB had undertaken useful work on the implications for farm practice. 19. Officials said that Government would in particular welcome advice from the AEBC on public attitudes to options for co-existence; and more widely the work of the consumer choice group presented an important opportunity to review what information was needed for and what factors should be included in decision-making about co-existence. Ministers would have to take account of these and other relevant factors in policy-making on co-existence. 20. On behalf of the sub-group, Roger Turner thanked officials for the evidence they had given to the group. 21. After the officials had left, the sub-group decided in the light of the evidence they had heard that:
22. The group invited the secretariat to confirm dates for future meetings. (Secretary’s note: now set for 29 October, 21 November, 28 January and 4 March.) AEBC Secretariat September 2002 |
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