The Food Standards Agency (FSA) are undertaking a consultation on The Genetic Technology (Precision Breeding) Bill 2023 which we'd ask you to consider responding to. The consultation can be accessed using the button below.
Whilst there is considerable concern about this act from the organic sector bodies, including the Certifiers and English Organic Forum there has been little heard from the organic farming community both in the UK. Concerns arise from the poor process around the implementation of this Bill which is well summarised in this letter sent by Organic Farmers and Growers but signed by Soil Association, English Organic Forum and Doves Farm. However. as farmers it is probably best to focus less on process and more on the practical affects of the implementation of GE crops.
There have been some seemingly exciting and exotic claims of rapid genetic advancements, such as N fixing wheat, that may be interesting were they ever to be delivered. Such claims may be attractive but exceed the record of success to date. Also, if we are working in a system-based agricultural it is questionable whether the breeding objectives would suit organic farmers. Imagine weed growth in organic arable systems that have excess nitrogen due to crops that fix nitrogen!
A major area of concern for organic producers is the issue of co-existence with GE products. GE products are deemed to be Genetically Modified Organisms (GMO) and so not allowed under organic standards. This would mean that unless suitable co-existence rules are established there could be burdensome and expensive requirements placed upon organic producers when selling and moving organic products. For us, that could require testing of lots (or in extremis), loads.
If we look at the experience of US organic producers we see organic loads being rejected and downgraded at the point of delivery. This is expensive for the producer and inconvenient for the customer who doesn't have the product available and so is more likely to lead to more frequent testing and so cost.
Having GM products in the market may provide an opportunity for the organic food sector as consumers wishing to avoid it would turn to organic as an alternative. However there is no provision for labelling in the new legislation and so consumers would not be able to make informed choices. Labelling or at least traceability (to allow for understanding of GE-food supply chains) should be mandatory to protect consumer choice.
We would encourage you to engage with the consultation process. You do not require to have a significant technical understanding of GE technology in order to do so. The number of responses received will be important for the outcome. The consultation has a shorter version and a longer version that can be completed and the shorter version takes just a few minutes to complete. There is useful guidance on the consultation here. We are not outlining model answers as the consultation will be scanned by AI and such duplication of entries reduces the "value" of the entry so please use your own form of words. Try to include the following in your response.
That you are a business that will potentially be damaged as you will likely lose access to export markets
Unless co-existence can be successfully be determined additional administrative and cost burdens will need to be met.
That consumers should have the choice as to whether to buy GM foods or not and so labelling or traceability should be mandatory
In this clip from a recent Organic Europe webinar Dr Angelika Hilbeck from Swiss Federal Institute of Technology explains her objections to the GE technology that will be introduced through this legislation.