Memorandum by British Society of Plant
1. BSPB Ltd represents the interests of plant
breeders covering all farm crops (except sugar beet), vegetables
and some ornamentals. The society's principal vote is to licence
and collect plant variety royalties. In 1996-97 the society collected
and disbursed £24.7 million royalty income.
2. Biotechnology plays a vital role in many
of the society's members research programmes. It is an enabling
technology that facilitates the breeding of new crop varieties
which enhanced value to agriculture. Such improvements include
resistance to pests and diseases, and increased yields and better
3. Biotechnology will allow plant breeders to
continue to have a beneficial impact on agriculture, horticulture
and the environment. The technology has value for developed agricultural
systems like Europe and the UK (and North America) as well as
potential to help the development of sustainable agricultural
systems in other parts of the world. The long term export potential
for British breeders will be enormous.
4. The first products developed from the use
of this technology are based on changes controlled by single gene
traits (herbicide tolerance, insect resistance). In time more
complex gene combinations will be obtainable with even higher
added value for the plant breeding industry and UK agriculture.
5. The committee should be aware of the UK's
influential role in developing and implementing regulations covering
this technology. The regulations are science based, have been
carefully considered and sensibly introduced. The UK example has
been used as a template by other countries outside Europe. In
contrast, the European system has not been successful being prone
to indecision and political interference with little leadership
6. Regulatory uncertainty is a significant problem
in plant breeding because of the lengthy timescales involved in
producing novel varieties. This uncertainty leads to a negative
climate, notably on consumer perceptions of the new technology.
7. In addition the European regulations have
not kept pace with the technology. As an example the European
Novel Food Regulation became law in 1997 after almost a decade
of debate. There are still no EU labelling guidelines for genetically
8. The lack of leadership by the EU leads to
increased costs and delays in variety development. In the decision
making process in developing new varieties the cost of regulatory
approval and the schedule for achieving this status are key factors.
At the moment it is not possible to estimate these factors of
cost and timing. A good example is the gm tomato paste which has
yet to be approved in the EU despite UK approval in January 1995.
There is still no regulatory approval to grow and process these
gm tomatoes in the EU. This position is in stark contrast to North
America where approvals take around six months.
9. These uncertainties feedback into the industries
involved. These adversely affect SMEs with the net effect that
the European entrepreneurial position is weaker then in North
America. This in turn discourages investment.
10. This climate of confusion undermines public
confidence in the technology which leads to a feedback affect
on the regulators which again produces a downward spiral. Without
clear leadership the position will get worse with potentially
damaging consequences for UK plant breeders.
11. International trade in gm plants and seeds
will be affected, with trade disputes the likely consequence of
inadequate harmonisation of the regulatory process.
12. The science base of the regulations must
not be compromised. The principles of risk assessment are sound
and our politicians and leaders must respect the independent advice
given by our scientific community. The risk assessment approach
should not be expected to give political, sociological or ethical
decisions an undeserved credibility.
13. The only valid approach to a risk assessment
on biotechnology in plant breeding for agriculture is based on
a case by case approach. Each crop species and novel trait should
be examined independently. It is misleading to decision makers
and consumers to be told that the risks posed by different crop
plants are the sameit is equally unhelpful to assert that
all applications are dangerous or safe!
14. The overall effect of this lack of clarity
and unpredictable planning will have serious long term effects
on Europe's competitive position.
5 June 1998