The Low Level Presence of Regulated Recombinant- DNA Plant Materials in Commodity Trade

Transcription

1 2008/SOM1/HLPDAB/006 Agenda Item: 1 The Low Level Presence of Regulated Recombinant- DNA Plant Materials in Commodity Trade Purpose: Information Submitted by: International Grain Trade Coalition (IGTC) High Level Policy Dialogue on Agriculture Biotechnology Lima, Peru February 2008

2 THE LOW LEVEL PRESENCE OF REGULATED RECOMBINANT-DNA PLANT MATERIALS IN COMMODITY TRADE Randal Giroux Ph.D. International Grain Trade Coalition Seventh Meeting of APEC High Level Policy Dialogue on Agricultural Biotechnology February 27-28, 2008, Peru IGTC Membership- 21 Organizations/ 3000 members / 80 countries Hungarian Grain and Feed Association COCERAL Canada Grains Council GAFTA Russian Grain Union ANIAME, APPAMEX CNAGS NAEGA, NCGA, NGFA, USGC, USW, CRA, ABIOVE, ANEC CEC Solvent Extractors Association, Soybean Processors Association NACMA 1

3 Few crops represent large share of global and use, production & consumption Sorghum 4% Barley 5% Soybeans 7% Other 42% Maize 12% Cotton Canola Wheat 18% Rice, Paddy 12% 50%..their production continues to grow..driven by growth in demand 100,000 90,000 80,000 Sunflower Oil Soy Oil Population & income growth drive 70,000 60,000 50,000 40,000 30,000 20,000 10,000 Canola Oil Palm Kernel Oil Palm Oil Corn Oil Coconut Oil Higher caloric intake Improved diets Increased consumption of oils Increased animal protein consumption 73% of global corn goes to feed , ,000 Poultry Meat Pigmeat Beef and Veal Copra 1% Palm Kernal 2% Fish 3% Peanut 3% Sunflower 5% 150,000 Cotton Seed 6% 100,000 50,000 - Soybean 69% Canola 11%

4 Where Are World Grain Markets Going? Demands on grain will continue to grow GDP growth Biofuels Water resources Easiest markets likely get the most attention Biofuels over Food/Feed Domestic over Export Generic over Specialty Global demand for raw crop materials is accelerating Million Metric Tons Principal grains, rice, oilseeds, fish meal, palm oil Source: USDA, Foreign Agricultural Service 3

5 World Bulk Grain Systems Characteristics Most grain used for food,feed or for processing is shipped by bulk handling systems Bulk system is characterized by high volumes to achieve low costs (economies of scale) Most of the world grain is utilized as feed 72% of world corn production 60% of oilseed production Food and feed grains move through the same infrastructure. Impact of biotechnology approval framework on global food and feed supply chain Compliance with National Requirements Regulatory Compliance (Unapproved events) Asynchronous Approvals Field Escapes Regulatory Compliance (Labeling Exemptions) Managing to a Threshold Customer specific-thresholds Compliance with International Requirements Biosafety Protocol (18.2.a) 4

6 Asynchronous Approvals leads to the LLP of unapproved events in grain shipments Low Level Presence (LLP) The potential for the unintended mixing between different crops or other impurities within grain, feed and food production LLP not a new concept to the grain industry Well recognized and widely understood in international trade. Standards currently exist to account for LLP of materials such as broken kernels, foreign material, diseased kernels, etc. LLP of GMOs will occur in all trans-boundary shipments of all commodities (both GMOs and non-gmos) shipped from countries having GMOs in commercial production What is LLP? Grain Perspective Unintentional Low level presence of a transgenic event(s) authorized in one or more countries but not in country of import Reasonably be expected to be present consistent with generally accepted agricultural and manufacturing practices 5

7 Why is the grain industry involved in LLP discussions? Agricultural biotechnology is here to stay As national and international regulatory frameworks emerge for modern biotechnology, the food and feed supply chain will be affected by these government decisions World s grain industry must be proactive to advocate regulatory frameworks in their respective countries that avoid disruptions in the international trade of grain, oilseeds, pulses and derived products Zero tolerance is the most disruptive policy for LLP in grain shipments for FFP Grain industry reasons to move off zero tolerance for LLP Zero threshold LLP policies expose grain industry/importers to exceptionally high risk: Demurrage, additional handling/storage costs/ disposal costs) Neither Identity-preservation (IdP) nor grain channeling can manage these events to zero tolerance To manage risk exporters/importers stop offering product: Trade stops; loss of export opportunity impacts entire export value chain Worst case leads to domestic industry downsizing 6

8 LLP Risk Management Priorities IGTC urges governments to take a tiered approach to managing LLP: 1. Synchronize event authorizations among countries whenever possible. 2. Recognition of the exporting country s risk assessment system a) Grant full authorization to the event b) Move off of current zero thresholds by announcing lowlevel marketing thresholds. 3. Conduct a low level presence risk assessment for the event using the Codex Low Level AP Risk Assessment Annex and assign an LLP threshold. Proactive Use of Codex Low Level AP Risk Assessment Guidelines Some governments are expected to use the new Codex Low level AP Risk Assessment Guidelines only when an event is detected at unload Costly: Ship unloading may be delayed until low level risk assessment is completed, creating additional unnecessary costs (Discourages Trade) Grain industry urges governments to perform low level AP risk assessment as soon as information on the event is posted to the new FAO database and proactively announce a marketing tolerance. Less costly, marketing tolerance known in advance of shipment (Encourages Trade) 7

9 Setting an LLP threshold Since the biotechnology event has been approved at 100% inclusion in the exporting country, governments should look to existing marketing thresholds for guidance in setting LLP thresholds Clearly established minimum standards, enables markets to trade products with claims of identity and attributes (No.2 yellow, Organic, Waxy) Establishes thresholds that allows grain customers to maximize the value of the grain product and minimize cost inefficiencies and handling costs associated with the supply chain Domestic industry players can establish lower thresholds contractually, where there are market demands for such products Existing LLP marketing thresholds provide guidance Numerous grain and marketing standards currently exist to account for incidental LLP that are costeffective, technically feasible and practical for FFP shipments These standards are generally set at 3-5%, to maximize market accessibility and minimize added costs for special handling and risk management Through dialogue, governments and industry tend to establish marketing/quality standards that are consistent with generally accepted agricultural and manufacturing practices. 8

10 International and Grain Marketing Standards ISO and Codex Forums ISO wheat standard (ISO 7970: 1989) includes maximum tolerances for; other cereals (3%), harmful or toxic seeds (0.5%), etc. Codex Maize standard ( ) defines thresholds for factors such as broken kernels (6%), diseased kernels (0.5%) etc. Grain Marketing Standards No. 2 CWRS tolerances for wheats of other classes 4.5% total (CGC, August 2007) No.2 wheat tolerance for wheats of other classes- 5% (FGIS standards May 2006) Waxy corn. Corn that consists of 95 percent or more waxy corn. (5% AP tolerance) Biotechnology Labeling and Organic Marketing Standards Biotechnology standards trigger labeling: NAFTA trilateral agreement for labeling a cargo to comply with BSP BCH listing Tolerance exemptions for mandatory and voluntary labeling of products derived from modern biotechnology Voluntary GM food labeling tolerance for Canada and HK Organic Certification The Canadian Organic Products Regulations:..the contents of which are at least 95% organic products and single ingredient organic products may bear the logo Canada Organic; 'Organic Farming - EC Control System' [No 2092/91]:. products bearing this logo can be confident that at least 95% of the product's ingredients have been organically produced; 9

11 Conclusion Demands on global agricultural supply chain demands are increasing and agricultural biotechnology policy should aim to minimize the disruption of trade For agricultural biotechnology, zero tolerance is the most disruptive policy for LLP in grain shipments for FFP While synchronized approvals are the preferred outcome, approval of Codex LLP annex and national implementation of LLP policy in a proactive manner is encouraged Existing marketing standards should be consulted to help inform governments on what is cost-effective, technically feasible and practical for FFP shipments LLP levels of 5%, maximize the value of the grain product and minimize cost inefficiencies and handling costs associated with grain channeling. What can APEC Member Countries Do? Support the Codex LLP annex approval Proactively address the issue of LLP Get your private sector entities involved in the issue Start a industry-government dialogue on the topic Develop national policy that minimizes impacts LLP of agricultural biotechnology products Develop risk assessment policy that minimizes asynchronous approval gaps between trading partners Establish policies for agricultural biotechnology that create access and predictability for global supply chains Acknowledge the need for and support the development of practical and acheivable standards for low level presence in collaboration with industry 10

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