Select Committee on European Communities Second Report - Written Evidence

Memorandum by Horticulture Research International


  1. Horticulture Research International (HRI) is a Public Sector Research Establishment (PSRE) with the principal objective of carrying out horticultural research and development. It is the principal contractor for horticultural R&D in the UK and is recognised as a centre of excellence providing cost-effective R&D. HRI has a significant research effort in genetic modification which is used in two distinct ways. The first as a research tool to identify gene properties and functions and the second is to produce improved cultivars by incorporating specific genes through genetic engineering. Targets are primarily fruit and vegetables for fresh consumption or processing and ornamental species for amenity and leisure purposes.

  2. Containment (90/219/EEC). HRI has carried out basic research involving genetic modification for over 10 years, including the first transformations of apple and strawberry. Most of the current work is carried out under the provisions of 90/219/EEC. This has provided a safe, effective framework for contained research. Risk assessments use well-established methods and information, which has proved to be robust The assessments and supporting practical protocols protect operators from potential risks and avoid harm to the environment.

  3. Release (90/220/EEC). The release of GMOs arising from HRI R&D into the environment is so far limited to studies on long term stability of transgenes in Apple. The application procedure for consent for release of GMOs for experimental purposes requires comprehensive details on the transgenic organism and a detailed assessment of the risk of harm to human health and the environment. Where consent has been given and the trials carried out in accordance with the protocols detailed in the application, the system has been successful in allowing experiments to proceed without adverse consequences. The system is open and releases are publicised. This has led to problems such as vandalism and attacks on GMOs. There is thus currently a conflict between the need for transparency in GMO trialling, essential to retain public confidence, and the need to maintain security of the trials.

  4. Consent for Marketing under this directive requires the agreement of all 15 member states of the EU and is consequently a major barrier to GMOs reaching the marketplace. This is in contrast with the relatively streamlined system for consent in the USA. While protecting the rights of individual states is a political necessity, it is important that agreement for non-controversial GMOs does not place European firms and their products at a competitive global disadvantage.

  5. Novel Foods (EC) 258/97. Regulations for the approval of Novel Foods is based on the concept of substantial equivalence. This approach, used by ACNFP, WHO and OECD is based on the demonstration that a novel food produced by or representing GMO is as safe as its conventional counterpart. The levels of variation must be within the natural range of conventional counterparts. This is a rational approach, but needs to be combined with an appropriate labelling strategy to sustain public confidence. For example, a refined oil derived from herbicide-tolerant oilseed rape would be substantially equivalent to the conventional product. However, consumers will demand the right to know that the ingredient is derived from a GMO.

  6. The labelling of Novel Foods derived from or containing GMOs must be open and informative. If possible the type and reason for the modification should be available to the public to enable them to make informed choices. This could possibly be achieved through a code or symbol system. Labelling should be clear, avoiding statements such as "this product may contain". Consumers will be suspicious if labelling is based on the measurable amounts of product from GMOs, although information on the content should be available for monitoring and enforcement of regulations. Consumers will need to know the provenance of the ingredients in Novel Foods and traceability should apply to GMO derived products, even where substantially equivalent.

  7. GM horticultural products will, in many cases, be the GMO itself, e.g., where fresh products are modified to maintain quality on the supermarket or consumers shelf. In some cases, these foods may contain elevated levels of compounds known to have positive health benefits, i.e., functional foods or nutraceuticals. By definition, these products will not pass the test of substantial equivalence, being outside the natural range of variance. Regulation for Novel Foods should anticipate this situation. Full safety evaluation of such products will be required to sustain consumer confidence.

  8. Genetic modification offers substantial benefits in terms of environmental enhancement through reduced chemical inputs and health and quality enhancement. For the Horticulture industry to take advantage of the opportunities, the regulatory regime will need to be rigorous, rational and transparent, to reserve public safety and confidence. A regime, which is over-complicated, slow and expensive, or only nationally based, will inhibit the application of this important technology.

4 June 1998

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