GMO in seeds actual state of affairs

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GMO in seeds actual state of affairs The EU concept of co-existence costs of co-existence liability GMO free regions and zones Seed contamination, labelling and approval Save our Seeds Benedikt Haerlin Foundation on Future Farming

production chain and critical points =testing point GMO Seed production Seed packaging and distribution Planting GMO growing g potential GM contamination Import processing A storage A transport A processing B-n storage B-n Import Import animal feed GMO harvest transport B-n animal feed storage transport GMO packaging trade Import collection Import retail Import adapted from: GAFTA commodity fact-sheet

Key questions regarding co-existence Is it feasible? What happens when GMO and non-gmo farming are not compatible? Which measures will be effective and necessary? Who is responsible? GMO and Seed industry GMO users / farmers Non-GMO farmers / organic producers bee keepers and other stakeholders Who will be liable for which h type of damages? Who will cover the costs of prevention, control and market impacts? Can entire regions be kept GMO free?

Co-existence policy - mission impossible? EU Commission wants to leave to the member states 1. to establish code of good agricultural practice, 2. protection o of non-gm and organic farmers, 3. protection of ecologically sensitive areas, 4. liability and redress Many member states & EU Parliament demand EU wide regulations on co-existence EU wide civil and environmental liability regulations Option to establish GMO free areas where co-existence is not reasonably feasible Denmark, Austria and soon Germany established coexistence and liabilty rules in their national legislation, which already differ significantly. EU Directive 2001/18, Article 26a Measures to avoid the unintended presence of GMOs 1. Member States may take appropriate measures to avoid the unintended presence of GMOs in other products. 2. The ecommission sso shall gather and coordinate information based on studies at Community and national level, observe the developments regarding coexistence in the Member States and, on the basis of the information and observations, develop guidelines on the coexistence it of genetically modified,conventional and organic crops.

EU Commission guidelines and recommended measures isolation distances and buffer zones pollen traps, barriers, hedgerows field monitoring and elimination of seed spillage sowing and crop rotation agreements between farmers cleaning of machinery and facilities reduced seed saving of farmers (only where "save") use mandatory land-register of GMO cultivation (GIS system) review of national liability legislation Source: Commission Recommendation of 23 July 2003 on guidelines for the development of national strategies and best practices to ensure the coexistence of genetically modified crops with conventional and organic farming

Initial calculations on contamination levels Source: Scientific Committee on Plants (2001) 0,9 0,8 0,7 0,6 0,5 0,4 0,3 0,2 0,1 0,0 0,09 0,05 0,05 0,2 0,33 0,05 0,2 0,2 0,3 0,3 seed seed 0,28 0,1 05 0,5 seed rape seed maize beet Prof. Jeremy Sweet: 02 0,2-04% 0,4 General agreement: Not possible margin storage transport harvest volunteers outcrossing Seed EU-Commissioner David Byrne to European Parliament, 19.9.2003: "...the SCP clearly shows that starting with seeds at the limit of such thresholds will result in a product with a GM presence of around 0,8%, which still leaves a margin vis à vis the 0,9 % threshold for the final product."

No solid scientific basis EU Scientific Committee and other scientific institutions are very cautions regarding the feasibility of co-existence are sceptical on keeping contamination below of 0,9 % emphasise that "zero" contamination is impossible agree on need for further research disagree on key details such as outcrossing frequency, distances, seed survival in soil, role of bees and other insects, impact of scale (small GMO islands vs. small non- GM islands), accumulation of GMOs over time have no concept for critical species such as oilseed rape base their findings mostly on small scale experiments and computer models and not on large scale and long term experience (poor documentation in GMO growing g countries)

some worrying facts Non-GM growing of oilseed rape no longer feasible in Canada emergence of recombined multiple l herbice resistant t GMOs (gene stacking) Seeds found in soil 13 years after initial planting; UK ministry of agriculture prohibits planting of oilseed rape on former test sites Outcrossing events found up to 26 km from source Outcrossing frequency proves not to be linear Massive GM contamination ti found in non-gm seeds in the USA "Starlink"-maize found in 12% of test samples in the US 3 years after ban and massive recall measures and even in Mexican landraces

Costs of co-existence Estimated additional production costs due to co-existence 53-345 per ha Source: EU Joint Research Centre: Scenarios for co-existence

testing costs

No conclusive picture of total costs of co-existence few scientific studies and scenarios; no systematic overview available from EU Commission or governments available estimations only refer to costs in agricultural production, not to total costs within the food and feed production chain (processing, retail, trade) seed purity is a key factor and still undeciced Who will pay the bill? Allocation of most cost factors unclear, massive share of costs will have to be borne by those not wishing to plant or use GMO under current legal and market conditions Scientists calculate insurance costs as they expect frequent contamination above the labelling threshold level. But insurances explicitely exclude coverage for GM-contamination.

The EU Commissions planned GMO Seed Directive Contamination of conventional and organic seeds with "adventitious and technically unavoidable presence of GMO" needs not be labelled below thresholds of 03% 0,3% in Oilseed Rape and in Maize (new) 0,5% potatoes, tomatoes, beet, chicoree 0,7% in Soybeans Initial proposal withdrawn after massive protest New proposal by Commissioner Wallström expected soon Legal basis: "Commission i Directive" i to be approved by Standing Committee on GMOs (regulatory procedure)

every 200th maize plant on a non-gmo field could be a GMO To scale: Maize field with 0,5 % GMO contamination

No precaution no control no co-existence Unlabelled seed contamination would prevent registration of GM planting make monitoring impossible prevent GMO free zones and regions Make a recall pracitally impossible disable co-existence and liability regulations

European "Save our Seeds" initiative no forced GMO cultivation through the back door GMO labelling in seeds at the detection limit no additional costs for GMO free farming 200.000 European citizens signed "Save our Seeds" Petition to EU Commission and governments 350 organisations of farmers, consumers, environmentalists, co- operatives and companies with more than 25 Mio members EU wide support "Save our Seeds" An increasing i number of EU governments and the European Parliament support labelling of GMOs in seeds at the detection limit

Positions of EU member states on seed purity 19 for detection ti level l (0,1) 19 for contamination ti thresholds h 49 undecided d Country *France Votes 10 Germany 10 Italy 10 UK 10 Spain 8 Belgium 5 *Greece 5 Netherlands 5 *Portugal 5 *Austria 4 Sweden 4 *Denmark 3 Ireland 3 Finland 3 *Luxemburg 2 TOTAL 87 qalifiied 62 majority * = Moratorium States Remarks requested review of Scientific Committee assessment at Seed Committee split between Greens and some SPD ministers "Zero tolerance" policy presently reviewing its position firmly in favour of GM growing and high thresholds expressed concern in Council, split between flamish and wallonian Ag minister rather critical position on Commission proposal major point of EU imports from US, notoriously on Commissions i side expressed concerns in Council, rather critical of Commission proposal All party agreement, has seed law with 0,1 % in force So far supported Commission position, reviewing position Minister asked Parliament to confirm his 0,1 % position Presidency from 1.1.2004, outspoken pro-gmo position So far firmly on Commissions side All party agreement for 0,1 % position European Parliament: Resolution (2003/2098) labelling at detection level

Conclusions 1. EU seed purity legislation at the detection limit 2. EU wide liability to be borne by GMO producers 3. EU wide standards for GMO planting 4. All costs and financial i risks must be estimated and taken into account 5. GMO producers and users must cover all additional costs 6. No approvals for GMO cultivation without t EU wide co-existence measures 7. No special GMO-thresholds for organic farming 8. GMO free regions and zones should be established and protected

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