Select Committee on European Communities Second Report - Written Evidence

Memorandum by Consumers in Europe Group


  1. Growth in the biotechnology sector of the food industry in recent years has been enormous and is likely to accelerate in the future. New technologies, new raw materials and the use of genetic engineering in the food sector have resulted in the rapid development of novel foods, ingredients and processes. An increasing proportion of the food we eat is likely to come from genetically modified organisms (GMOs) and their derivatives. Such developments could potentially lead to significant changes in the composition of individual foods and subsequently to overall nutritional and toxicological effects on an individual's diet. It is therefore of the utmost importance that a sound legislative framework for evaluation and approval of new substances and foods operates within the EU to guarantee to consumers that all necessary steps are being taken to ensure the safety of genetically modified food.

  2. CEG is not against biotechnology in itself provided it is closely controlled. Preventing progress in developing genetically modified (GM) foods is not in the consumer interest: however, the emphasis must be on caution, maximum information and learning from the past. It must be recognised that some customers, for a range of reasons, may choose to avoid eating GM foods and they must be able to express that choice.

  3. The consumer interest must be represented in the approval process to ensure the safety of new products and processes, to maintain and open up choice, to create access to information on the novel foods and processes used to produce them, and to protect the environment.


  4. CEG welcomes the steps taken to clarify the approval procedures within the Commission's proposed revisions to the current directive on release into the environment (90/220/EEC). We acknowledge that the approvals process could be simplified but this should not mean that the protection of human health comes second to commercial interests. The pursuit of speed and reduction of documentation should not reduce the opportunities available for consumers to give their views.

  5. There needs to be a link between all EU legislation on GM products to ensure consistency of approach, especially between the Novel Foods Regulation and Directive 90/220/EEC. This coherence in policy was implied in the Commission's 1997 orientation on labelling.

  6. Labelling of GM produce is a key area of concern and, as such, needs to be covered in more depth than is currently proposed in amending Directive 90/220/EEC. All seeds and agricultural produce from GM plants must be labelled; animal feed containing GM material must also be labelled. CEG does not support the use of "may contain" labelling because it does not give any helpful information to consumers. Moreover, the information and labelling of GMOs and GM produce must enable them to be traced back through the food supply. This would give the opportunity to recall products should any adverse health effects occur.

  7. Further clarification is needed on the important aspects of how the assessment of risk to health and to the environment will be carried out. There needs to be a clear methodology developed for risk assessment. Assessments must be standardised throughout the EU. Where the scientific information needed for a risk assessment is insufficient or inconclusive then this should be made clear and any decisions based on that assessment should err on the side of safety to the public.

  8. Consumers are concerned that there may be adverse long-term effects from the cultivation and use of GMOs. These effects may not be apparent at the time of approval because of their long-term nature. It is crucial that the approval process requires that the impact on human health and on the environment is monitored, and reported back to the regulatory authorities. The impact of both individual products and also of genetically modified products as a whole need to be considered. Guidelines are needed on the methodology to be used for monitoring, for the treatment of waste and for emergency response. The frequency of monitoring and the techniques to be used should be specified. In addition, farmers may need training to recognise potential problems caused by horizontal gene transfer from GM crops to other crops or weeds.

  9. The approval process must be open and transparent. The dossiers provided by companies for approval of releases must be made available to interested parties. We consider that it is particularly important for competent authorities to be provided with the full dossier on request. They must be able to fully assess the data in order to make any appropriate substantial objections to the release and/or marketing of a GMO.


Approval process

  10. An effective approval process based on sound scientific evaluation is of key importance for ensuring the safety of novel foods and processes. These are essential for the consistent assessment of applications by Member States. The Scientific Committee for Food (SCF) should be closely involved in the approval procedures for novel foods. The SCF should be consulted, and provided with a copy of the initial assessment report, whenever an assessment for authorisation is referred to the Standing Committee for Foodstuffs and there are concerns for human health. The Scientific Committee for Food's guidelines for applications should be reviewed and updated once the new procedures have been in operation for a couple of years.

  11. All novel foods must undergo an appropriate safety assessment by an officially-designated competent authority. It should not be acceptable for companies to place novel foods directly onto the market based only on their own evaluation of substantial equivalence; however, this is allowed under the EU Novel Foods Regulation. This loophole for establishing the substant equivalence of novel foods should be closed as soon as possible. Until then, the UK's Advisory Committee on Novel Foods and Processes (ACNFP) should evaluate, as a matter of priority, all the supporting evidence for substantial equivalence provided by companies to the Commission and take immediate action if there are concerns for human health.

  12. The approval system must be transparent so that consumers can find out what applications are in the approval system and what procedures are being followed within it. An EU-wide system for monitoring applications for novel foods in the approval process should be put in place by the Commission and regular reports published.

Antibiotic resistance marker genes

  13. The presence of antibiotic resistance marker genes in GMOs may create a risk to human health. The concern is that the marker genes could be transferred to a micro-organism pathogenic to humans and so make the control of infection needlessly difficult. This could happen if, for instance, GM maize containing an antibiotic resistance marker gene is used unprocessed (i.e., with live genetic material) in animal feed. The probability that resistance will be transferred is very low but the potential impact on human health could be very great. The precautionary principle should be applied in cases such as this.

  14. Antibiotic resistance marker genes are often used in the early stages of the development of GMOs. They serve no purpose after this stage and alternative marker genes are available. It is technically possible to excise the marker gene before the GMO is marketed. To protect public health, GMOs containing viable antibiotic resistance marker genes should not be marketed. The guidelines for scientific assessment of novel foods should make it clear that these marker genes are not acceptable in the final product. Their use in GMO development should be phased out as soon as possible.


  15. The Novel Foods Regulation does not apply to processing aids, additives, flavourings and extraction solvents. However no EU legislation exists on processing aids at present. This means that many enzymes used in the food industry (that are increasingly derived from genetic modification) are not subject to any safety assessment at an EU level. There is also no present requirement to label processing aids. CEG considers that processing aids should be regulated (with priority given to enzymes).

Consumer representation

  16. Representation of public interest in the evaluation process is not specifically included in the Novel Foods Regulation. Although some Member States may have some degree of consumer involvement in their own systems, consumers are not represented at the EU level. While the re-organisation of the Consumer Policy and Health Protection Directorate-General (DG XXIV) has led to more open decision-making by the scientific committees, there is scope for more consumer representation. Representation by consumers and public interest groups in the evaluation process of novel foods should be increased.

Areas requiring research

  17. Genetic modification is a relatively new technology and there are still many unknowns and uncertainties about its use, especially over the long-term. Research should be directed at some of the assumptions made in the approval process and into methods for detection of GM material in foodstuffs. Research should be funded by the EU and UK into these areas and the effect of processing on the viability of GM material.


  18. We fully support the principles of consumer choice and information. Therefore, all GM food must be clearly labelled. Consumers must be able to make an informed choice between those foodstuffs produced using genetic modification and those which have been produced conventionally. This is particularly important in the early years of this new technology's introduction. As part of this, non-GM alternatives must be available to consumers to make sure that they have a genuine choice of food products.

  19. Segregation of GM produce at source and traceability throughout the food supply chain are the best ways to ensure full and accurate labelling for consumers. CEG considers that the labelling of food from GM crops must be based on derivation, not purely on analysis of chemical differences. This must include processed products from GM crops; many of these would not need to be labelled under EU Regulations. Without credible systems for segregation and labelling, consumers will not know if they are eating GM food, and their confidence in this new technology is likely to be reduced. Segregation systems must be supported by analytical spot-checks at points throughout the food chain to check their validity.


  20. The wording of the Novel Foods Regulation is open to interpretation in several key areas including marketing procedures and labelling. Therefore there is a risk that Member States may decide to implement the Regulation in different ways, undermining the Single Market and potentially restricting consumer choice. It would be very helpful to have EU-wide guidelines on the Novel Foods Regulation.

Monitoring long-term effects of consumption

  21. Consumers are concerned that there may be adverse long-term effects from the consumption of novel foods. The impact of individual products and also of genetically modified products as a whole need to be considered. Although the Novel Foods Regulation recognises these concerns, more detail is needed on how monitoring will operate.


  22. There is a need for an "over-arching" body, at both UK and EU level, to consider the broad picture of the use of genetic modification and its impact on the environment and food safety. Case by case assessments made under Directive 90/220/EEC or the Novel Foods Regulation do not cover this broader viewpoint. It is disappointing that the Commission has not set up a Scientific Committee on Biotechnology. The remit of such a committee could extend beyond human health and incorporate environmental and ethical considerations. It could be closely involved in the approval process and be consulted alongside the SCF.

1 June 1998

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