Inter-association letter to the European Commission and Member States
POSITION PAPER
Brussels, 9th January 2020
Object: EC study on the status of novel genomic techniques
Dear Mrs Juelicher,
The undersigned value chain partners strongly support Council Decision (EU) 2019/1904 requesting the Commission to submit a study on the status of novel genomic techniques1 and welcome the potential for a Commission proposal, which we hope will deliver more enabling rules for products resulting from the latest breeding methods, while keeping high standards of EU food production. In this context we would like to re-emphasize our position that products should not be subject to Directive 2001/18 requirements and related regulations if they could also have been obtained through conventional methods or result from spontaneous processes in nature. This differentiated regulatory approach, which looks at both, the process and the product, thus taking into account the benefits of these novel genomic techniques and the resulting products is taken up in a growing number of countries around the world.
We count on you that the above-mentioned study will take a differentiated view on the diverse “new genomic techniques” that might be covered by the study as well as the kind of applications in different groups of organisms. Also, we regard it important to address this topic from a global perspective, taking into account the trade aspect in relation to the policy developments around the world and their implications for competitiveness of the EU Agri-Food value chain as well as the enforceability of the ECJ ruling. The ENGL/JRC report on “Detection of food and feed plant products obtained by new mutagenesis techniques”, published on 26 March 2019 has provided very important insights in this context that must not be ignored.
European Agriculture and its associated value chains will have to meet an increasing demand for high-quality food, feed and bio-based goods using limited resources and producing less emissions. However, it is also one of the sectors already suffering from climate change and more extreme weather conditions. The challenging goals of the European Green Deal and of one of its key components, the Farm to Fork Strategy, can only be achieved if the food chain is part of the solution to adapt to and to mitigate climate change. We agree that in this context the EU “needs to develop innovative ways to protect harvests and animals from pests and diseases and to consider the potential role of new innovative techniques to improve the sustainability of the food system” 3. Also, the IPCC report on climate change4 underscores the need for further breeding innovation to mitigate its effects such as resistance to water and heat stress and resistance to changing pest and disease risks.
However, as a result of the ECJ judgement in case C-528/16 on mutagenesis breeding, the potential of the new breeding techniques remains untapped in Europe. With this, European agriculture and some other of the EU’s most innovative sectors are disconnected from scientific progress, putting them at a competitive disadvantage compared to their counterparts in a rapidly growing group of countries with more enabling regulations. Consequently, Europe’s leading position in innovative breeding is at stake, as are jobs in agriculture, bioindustries and their associated value chains, international trade flows and sustainability.
Farmers and consumers must form a central part of the “Farm to Fork Strategy” under the European Green Deal and we believe that farmers in particular need to have the right toolbox available to support a sustainable food supply chain. As mentioned in its communication on Green Deal, European Commission underlines that new technologies, sustainable solutions and disruptive innovation are critical to achieve the objectives of the European Green Deal. The undersigned agri-food value chain partners are committed to contribute to society and consumer expectations in view of healthy diets, biodiversity and a sustainable agricultural model. We are convinced that targeted mutagenesis breeding (including with genome editing) can contribute to various goals of the European Green Deal by saving land resources, reducing crop protection products, antibiotics and emissions while stabilizing and increasing crop yields and improving animal health and welfare to ensure food security (concrete examples can be accessed here 5).
Given that discussions on the status of novel genomic techniques have been going on for more than 10 years, we call on you to ensure that this Council decision is part of the European Green Deal and its respective Farm to Fork Strategy and will be implemented in due time.
Yours faithfully,
Céline Duroc, Director General of MAIZ'EUROP' for the Platform Agriculture and Progress
Céline Benini, Acting Secretary General Association of Manufacturers and Formulators of Enzyme Products
Dirk Carrez, Executive Director of Bio-based Industries Consortium
Paul Girard, Sector Group Manager, Specialty Chemicals, The European Chemical Industry Council
Marie-Christine Ribera, Director General, European Association of Sugar Manufacturers
Jérôme Bandry, Secretary General, CEMA - European Agricultural Machinery
Céline DUROC, Permanent Delegate CEPM, European Confederation of Maize Production
Elisabeth Lacoste, Director C.I.B.E.-International Confederation of European Beet Growers
Iliana Axiotiades, Secretary General, European Association of Cereals, Rice, Feedstuffs, Oil Seeds, Olive Oil, Oils and Fats and Agrosupply Trade
Marc Casier, President, Confederation of European Yeast Producers
Catherine Entzminger, Secretary General European Cocoa Association
Ana Granados Chapatte, Director, European Forum of Farm Animal Breeders
Gary Sharkey, President, European Flour Milling Association
Thierry de l'Escaille, Secretary General – CEO, European Landowners' Organization
Joanna Dupont-Inglis, Secretary General, EuropaBio – The European Association for Bioindustries
Raquel Izquierdo, Secretary General, European Potato Trade Association
Aleksandra Malyska, Executive Manager, European Technology Platform Plants for the Future
Garlich von Essen, Secretary General, Euroseeds
Nuria Moreno, Secretary General, EUVEPRO - European Vegetable Protein Association
Ernesto Morgado, President, Federation of European Rice Millers
Nathalie Lecocq, Director General, FEDIOL - EU Vegetable Oil and Protein Meal Industry Association
Nick Major, President, European Feed Manufacturers' Federation
Joerg Seifert, Secretary General, FEFANA - EU Association of Specialty Feed Ingredients and their Mixtures
Mella Frewen, Director General, FoodDrinkEurope
Paul Mejster, President Primary Food Processors
Jamie Fortescue, Managing Director, Starch Europe
Object: EC study on the status of novel genomic techniques
Dear Mrs Juelicher,
The undersigned value chain partners strongly support Council Decision (EU) 2019/1904 requesting the Commission to submit a study on the status of novel genomic techniques1 and welcome the potential for a Commission proposal, which we hope will deliver more enabling rules for products resulting from the latest breeding methods, while keeping high standards of EU food production. In this context we would like to re-emphasize our position that products should not be subject to Directive 2001/18 requirements and related regulations if they could also have been obtained through conventional methods or result from spontaneous processes in nature. This differentiated regulatory approach, which looks at both, the process and the product, thus taking into account the benefits of these novel genomic techniques and the resulting products is taken up in a growing number of countries around the world.
We count on you that the above-mentioned study will take a differentiated view on the diverse “new genomic techniques” that might be covered by the study as well as the kind of applications in different groups of organisms. Also, we regard it important to address this topic from a global perspective, taking into account the trade aspect in relation to the policy developments around the world and their implications for competitiveness of the EU Agri-Food value chain as well as the enforceability of the ECJ ruling. The ENGL/JRC report on “Detection of food and feed plant products obtained by new mutagenesis techniques”, published on 26 March 2019 has provided very important insights in this context that must not be ignored.
European Agriculture and its associated value chains will have to meet an increasing demand for high-quality food, feed and bio-based goods using limited resources and producing less emissions. However, it is also one of the sectors already suffering from climate change and more extreme weather conditions. The challenging goals of the European Green Deal and of one of its key components, the Farm to Fork Strategy, can only be achieved if the food chain is part of the solution to adapt to and to mitigate climate change. We agree that in this context the EU “needs to develop innovative ways to protect harvests and animals from pests and diseases and to consider the potential role of new innovative techniques to improve the sustainability of the food system” 3. Also, the IPCC report on climate change4 underscores the need for further breeding innovation to mitigate its effects such as resistance to water and heat stress and resistance to changing pest and disease risks.
However, as a result of the ECJ judgement in case C-528/16 on mutagenesis breeding, the potential of the new breeding techniques remains untapped in Europe. With this, European agriculture and some other of the EU’s most innovative sectors are disconnected from scientific progress, putting them at a competitive disadvantage compared to their counterparts in a rapidly growing group of countries with more enabling regulations. Consequently, Europe’s leading position in innovative breeding is at stake, as are jobs in agriculture, bioindustries and their associated value chains, international trade flows and sustainability.
Farmers and consumers must form a central part of the “Farm to Fork Strategy” under the European Green Deal and we believe that farmers in particular need to have the right toolbox available to support a sustainable food supply chain. As mentioned in its communication on Green Deal, European Commission underlines that new technologies, sustainable solutions and disruptive innovation are critical to achieve the objectives of the European Green Deal. The undersigned agri-food value chain partners are committed to contribute to society and consumer expectations in view of healthy diets, biodiversity and a sustainable agricultural model. We are convinced that targeted mutagenesis breeding (including with genome editing) can contribute to various goals of the European Green Deal by saving land resources, reducing crop protection products, antibiotics and emissions while stabilizing and increasing crop yields and improving animal health and welfare to ensure food security (concrete examples can be accessed here 5).
Given that discussions on the status of novel genomic techniques have been going on for more than 10 years, we call on you to ensure that this Council decision is part of the European Green Deal and its respective Farm to Fork Strategy and will be implemented in due time.
Yours faithfully,
Céline Duroc, Director General of MAIZ'EUROP' for the Platform Agriculture and Progress
Céline Benini, Acting Secretary General Association of Manufacturers and Formulators of Enzyme Products
Dirk Carrez, Executive Director of Bio-based Industries Consortium
Paul Girard, Sector Group Manager, Specialty Chemicals, The European Chemical Industry Council
Marie-Christine Ribera, Director General, European Association of Sugar Manufacturers
Jérôme Bandry, Secretary General, CEMA - European Agricultural Machinery
Céline DUROC, Permanent Delegate CEPM, European Confederation of Maize Production
Elisabeth Lacoste, Director C.I.B.E.-International Confederation of European Beet Growers
Iliana Axiotiades, Secretary General, European Association of Cereals, Rice, Feedstuffs, Oil Seeds, Olive Oil, Oils and Fats and Agrosupply Trade
Marc Casier, President, Confederation of European Yeast Producers
Catherine Entzminger, Secretary General European Cocoa Association
Ana Granados Chapatte, Director, European Forum of Farm Animal Breeders
Gary Sharkey, President, European Flour Milling Association
Thierry de l'Escaille, Secretary General – CEO, European Landowners' Organization
Joanna Dupont-Inglis, Secretary General, EuropaBio – The European Association for Bioindustries
Raquel Izquierdo, Secretary General, European Potato Trade Association
Aleksandra Malyska, Executive Manager, European Technology Platform Plants for the Future
Garlich von Essen, Secretary General, Euroseeds
Nuria Moreno, Secretary General, EUVEPRO - European Vegetable Protein Association
Ernesto Morgado, President, Federation of European Rice Millers
Nathalie Lecocq, Director General, FEDIOL - EU Vegetable Oil and Protein Meal Industry Association
Nick Major, President, European Feed Manufacturers' Federation
Joerg Seifert, Secretary General, FEFANA - EU Association of Specialty Feed Ingredients and their Mixtures
Mella Frewen, Director General, FoodDrinkEurope
Paul Mejster, President Primary Food Processors
Jamie Fortescue, Managing Director, Starch Europe
