Potential benefits and risks

172.  Biotechnology in general and genetic modification in particular offer great potential benefits to agriculture, industry, consumers and even to the environment. We consider that GM technology may offer much to organic systems, for example through reduced inputs (paragraphs 65-72, 78).

173.  There are potential risks relating to the environment, including the impact on ecosystems of out-crossing, pest resistance and stress and multiple tolerances (paragraphs 0-0).

174.  We consider that environmental risks and benefits should be assessed at the same time (paragraphs 87-88).

Risk assessment

175.  The risks involved in genetic modification can, we believe, be controlled, if a strict risk management process is in place. A clear, coherent set of principles for environmental impact analysis is needed which allows for consistent interpretation by Member States (paragraphs 89, 92-93).

176.  We recommend that risk assessment should include direct, indirect, immediate and delayed effects. The regulatory system should attempt to predict interactions. A system which attempted to identify an integrated approach would be preferable to what amounts to a first come, first served approach (paragraphs 94-95).

177.  In assessing risk, we recommend that modified plants and their management schedules should be compared with the use of a similar non-modified crop and best agricultural practice (paragraph 90).

178.  We recommend that there should be triggers other than genetic modification which bring the assessment and management system into action, as is the case for novel foods. We recommend that, from now on, any crop with novel traits which may have the potential to impact significantly on the environment should be subject to an oversight system (paragraph 91).

179.  The knowledge of how a crop grown on farm and commercial scales will interact with the environment can only be acquired by growing it on such scales. Large scale trials are needed. We consider that an outright moratorium would be inappropriate (paragraphs 96-99).

Risk management

180.  We welcome the ability to set specific conditions for each commercial release. We are however concerned that the draft Directive does not envisage an end-point at which the GM crop is considered safe enough to be released into the environment without such constraints (though perhaps with certain management conditions) (paragraphs 100-101, 170).

181.  Conditions and regulations should only be imposed where necessary, but must be adhered to when imposed. The general conditions may best be established through a (preferably pan-European) government-sponsored code of practice. It may be the case in this instance that a voluntary code of practice will not be sufficient; if so, the code of practice should be backed up by regulation (paragraphs 105-107).

182.  Monitoring is not a substitute for risk assessment but can complement it. We consider that those involved should report on any predicted effects which do not occur and any unexpected events which do occur. We recommend that monitoring (to Community-wide standards) should be performed by an independent organisation, funded through levies on applicants. There must also be a Community-wide audit of enforcement as monitoring standards (in many fields) have in the past been subject to too great a variation (paragraphs 102-104).

GM food

183.  We consider the regulatory process for assessing the safety of novel foods to be thorough and proper and we see no reason to doubt the safety of foods which have been approved by the regulatory process. The emphasis should not be on "genetically modified" but on the new characteristics of any individual product (paragraphs 109-116).

184.  Antibiotic-resistant marker genes should be phased out as swiftly as possible. Research needs to be conducted into how best to consider applications involving genes without proven track records of food use. We support the call for the accumulation and sharing of national data to assist regulators (paragraphs 75, 109-116).

185.  Internal work at MAFF to prepare for the Food Standards Agency is poor substitute for its launch. We would be encouraged if legislation were to be brought forward in this Session (paragraphs 118-122).

186.  Genetic modification does not concern a single product or variety but will soon affect the whole spectrum of agriculture. To require traceability for all agricultural commodities would be an exceedingly costly exercise for little benefit, especially when there is no anticipated risk to human health (paragraph 117).

Consumer choice

187.  Once the regulatory process has ensured safety, the success or failure of the technology must be left to consumer choice in the marketplace. The two issues involved in providing choice are the supply of GM and non-GM products and labelling (paragraph 128).

188.  Segregation must be driven by the market and not required by Government. Producers and manufacturers should however be under no illusion as to the climate of consumer opinion in Europe and it would be advisable for the immediate future for segregation to occur to facilitate consumer choice. The identity preservation system is to be commended. The crop and product must still be subject to the standard testing and labelling regimes as GM material has often been found in supposedly unmodified shipments (paragraphs 129-134).

189.  We welcome the requirement for the explicit labelling of GM products in order to help provide consumer choice. We agree with the Commission and Government that only products where the transgene or its product are detectable should be labelled. To demand labelling where such detection is impossible would be meaningless. A Community list of products which do not require labelling is urgently required (paragraphs 135-139, 145).

190.  Any ingredient or additive to a product should be identified as GM when the presence of GM material can be detected above an established threshold. No labelling should be required below the threshold. Additionally, if a finished product contains GM material above a threshold the product itself should be labelled.

191.  The absence of a testing and thresholds policy is a serious gap in current European and domestic legislation. Until a Community policy is agreed we recommend that MAFF should issue interim guidelines. A workable but cautious threshold for GM presence would perhaps be 2 per cent. (paragraphs 136-139, 141-144).

192.  Information supplementary to that provided on the label of GM foods must be available to the consumer. We recommend that Member State governments co-ordinate (but not necessarily be responsible for) the establishment within each State of a source of information regarding GM foods, to which the consumer may resort for information not provided on the product label. In the United Kingdom, this should as soon as possible fall under the remit of the proposed Food Standards Agency (paragraph 140).

Regulation

193.  It is highly desirable that there should be competition between a sufficient number of agro-chemical/seed companies on a world-wide basis. We consider that consolidation should not progress any further (paragraph 85).

194.   Provided that the farmer can afford any extra costs, we do not consider either the licensing of the right to plant or the sale of seeds which will produce sterile crops to be a problematic development (paragraph 86).

195.  The regulatory process should only judge products on safety: ethical questions should be addressed before regulation, not during or after. In the same way as agreeing the principles for risk assessment, the Council of Ministers will need to agree on how to deal with potentially ethically sensitive modifications such as the inclusion of animal or fish genes in crops. The market might be a suitable arbiter. For some people the use of GM products to any extent is an ethical issue (paragraphs 126-127).

196.  The destruction of trials of GM crops by certain groups fundamentally opposed to the technology must be condemned, but increasing confidentiality is not the answer. The advisory committees should continue to place as much information as possible in the public domain. We welcome the Commission's proposal to do the same at Community level. We agree that public comment should be taken into account formally before ACRE makes its recommendation, rather than informally as at present. Transparency, however, must not affect the efficient working of the regulatory committees (paragraphs 123-125).

197.  We do not question ACRE's integrity, but it and its members must be seen to be acting independently. The remit of ACRE should be adjusted so that it considers, for example, indirect and cumulative environmental effects when judging individual applications (paragraphs 148-150).

198.  We believe that a new committee, similar to that proposed by the Royal Society, is needed to examine more general issues which arise from the use of genetic modification in agriculture and to co-ordinate and plan policy as a seamless whole (paragraphs 151-153).

199.  Domestic pressures, ecological and agricultural conditions vary across the Community. We consider that Member States should have the right to opt-out of growing certain GM crops for domestic or environmental reasons. The products of such crops, food or other, should however be available throughout the Community and the market will determine their acceptability and so success or failure (paragraph 160).

200.  We consider that consultation of the Commission's scientific committees will be useful for resolving inter-Member State disputes. The appointment, membership and operation of the committees must be open to scrutiny. The current method of appointment is inadequate. The structure of the committees could also be streamlined to increase their relevance to the regulation of GM releases. The committees require improved resources in Brussels (paragraphs 163-164).

201.  We welcome the introduction of strict time limits and the definition of risk assessment which should help end discrepancies between Member States and provide the predictable system desired by industry. There are however two flaws. The first is too ready a willingness to stop the clock. We consider that the efficiency of the scientific committees' working should be improved before resorting to stopping the clock. If this proves impossible, consideration will need to be given as to whether it would be preferable to make the committees permanent or to stop the clock. Additionally, the Commission has failed to set itself a time limit for approving or rejecting a release following the (in)decision of the Council (paragraphs 165-168).

202.  We find no merit in the proposal to limit marketing consents to seven year periods (paragraph 170).

203.  GMOs need to be regulated, at least until our knowledge develops further, but it would be extremely damaging if Europe's access to this technology was subjected to inappropriate impediments (paragraph 171).

Recommendation

204.  The Committee considers that the proposed revisions to the EC regulation of genetic modification in agriculture raise important questions to which the attention of the House should be drawn, and makes this report to the House for debate.