Memorandum by Iceland Group plc
Iceland Frozen Foods Plc is 28 years old, comprises
primarily a retail operation with 770 stores, 20,000 staff and
a turnover of £1.7 billion. Iceland is a frozen food specialist
but also offers a wide range of both chilled and ambient products.
Genetic modification clearly can provide significant
benefits for society but also has associated risks and raises
a wide range of issues for consumers.
We believe that the introduction of GM commodity
crops is a significant departure from traditional breeding methods.
We share the concerns raised by several independent scientists
regarding the way in which these products are being brought to
We believe customers need to be informed as
to what is going on and need to be given a choice as to whether
or not they buy GM products. As a result we have been raising
the profile of this issue.
We believe that many of the advisory bodies
at EU and UK level had a strong bias towards bringing this technology
to market. We have been working to ensure that consumer concerns
are addressed within the process. Progress is being made but there
is still some way to go.
OF EU AND
As a food retailer we have had to spend a great
deal of effort of late ensuring that regulations are effective,
clear, practical to implement, allow innovation and minimise the
disruption and cost to the trade.
The difficulty in achieving consistent regulation
across the EU often leads to prescriptive regulations that are
inflexible and difficult to apply in parts of the community. The
complexity and wide range of food operations lead enforcement
agencies generally to prefer end point testing and prescriptive
checklists. Operators on the other hand generally prefer risk
assessment and in-process controls. This latter approach provides
the flexibility to develop new solutions to the issues with compliance
that face their specific operation.
We believe that often the best solutions arise
from co-operative ventures that involve all interested parties
at an early stage.
(a) Introduction of GM Commodity Crops
Unfortunately with the introduction of genetically
modified (GM) commodity crops the biotech industry and those responsible
for legislation were unwilling to listen to, or act on, the concerns
raised by retailers and customers within the UK and across Europe.
We believe this is because there was a general
feeling that the profit to be made was so great that no country
could afford to be left behind and no-one believed there would
be any point in standing up to the might of the large conglomerates
that operate in this sector. As a result Governments have invested
heavily in research in this area and are in fact very closely
aligned to the biotech industry. The significance of this industry
is such that major world trading markets believe that they equally
cannot get behind in the race to exploit the technology.
(b) Independence of Advisers
Many of the scientists and academics that would
historically be relied on to provide independent advice on behalf
of the community now have strong dependencies on industry. As
a result we believe that many of the advisory bodies at EU and
UK level have a strong bias towards bringing this technology to
market. When deliberating issues it is within the context that
the approval of these products must not be delayed rather than
proceeding with due caution.
(c) Compartmentalisation of the Review Procedure
As with this Sub-Committee particular aspects
of the approval process tend to be dealt with separately. However
in order to decide whether or not these products should come to
market the benefits must be balanced by consideration of all the
accumulative impacts. Hence the fact that a product may pass an
environmental assessment in isolation should not remove the need
for the environmental impact that does exist to be considered
in the final equation.
(d) Products On The Market Before The Controls
Perhaps with this background we should not be
surprised that at both EU and UK level the authorities have failed
the consumer. We should all be embarrassed that we have the new
GM commodity crops on the market before we have appropriate controls
in place to allay the fears of the consumer.
We believe that the biotech industry only has
itself to blame for the delays in their new products being approved.
They could have been proactive in determining the appropriate
practical controls with consumers' interests in mind rather than
lobbying for the authorities to consider the possible impact of
trading relationships and denying the concerns of the consumer.
(a) Consumer Link with BSE
We have been amazed that it has taken so long
to recognise that the European consumer might be a little concerned
about scientists playing with their food so soon after the BSE
scare. The two issues may have no connection technically but that
is not the view of the consumer. When GM soya was introduced we
felt that the industry had something to hide because of their
negative attitude to the wishes of the UK retail trade.
As with the BSE situation food operators must
be able to rely on the advice provided by the competent authority.
After the BSE scare we are now understandably not as confident
in these authorities.
(a) Agreed Timescales for Reviews
The provision of agreed periods for reviews
to be completed should make the process more efficient. The timescales
act as a good guide but in practice we feel that some of the timescales
may be difficult to comply with. Whether the system works in practice
will depend on the pressure on the committee to approve the product
or to throw the application back when there are grey areas, and
further expert advice is required to make the decision. At present
this may not be an issue but if the number of applications increases
as expected difficulties may arise.
(b) Transparency and Consumer Involvement
The proposed greater transparency of the decision
making process and the involvement of consumer groups is welcomed.
Effective debate with consumer groups across Europe may be difficult
to facilitate in the timescales suggested (30 days).
(c) SegregationCross PollinationCross
Iceland has achieved segregation of GM Ingredients
and no Iceland Own Label products are currently made with GM Ingredients.
If we are going to be able to maintain the segregation
of a non-GM alternative we must limit the risks from cross pollination.
We understand that in the US some states have introduced controls
that prevent the growing of crops which may increase the likelihood
of pesticides resistance being gained. In the UK we are concerned
that if GM oilseed rape is planted this will quickly contaminate
Non-GM crops. We understand that oilseed rape cross pollination
can occur over a substantial range. At present trial plots are
planted at least 50 metres from the nearest farmer with a six
metres gap round the outside of the crop. This may not be sufficient.
Once crops are approved similar controls must be implemented if
Non-GM crops are not to be contaminated. Regional segregation
for oilseed rape should be mandatory if practical farm segregation
distances cannot be found. In addition haulage controls for seed
would need to be introduced to prevent the current spread of seed
along haulage routes.
We believe that farmers that wish to maintain
a Non-GM crop should have an ability to claim compensation if
their crop is contaminated by a neighbour's GM crop or they incur
greater costs due to having to use herbicides to remove GM weeds.
(d) Fixed Approval Period
Once products are released into the environment
the DNA structure continues to evolve. Materials that were deemed
to present no risk to consumers or the environment may create
problems due to the presence of foreign DNA. The environmental
impact of GM crops may also take some time before it becomes evident.
We thus support the proposal for approvals to be given for a limited
period. We believe that the criteria for a continuation need to
be well defined to ensure a thorough but practical review is completed
of all key areas. We would like to see more details as to what
exactly is required to pass such a review.
The key criteria for monitoring the implementation
of GM crops should be specified as part of the amendment or within
an agreed period. At present this is to be decided on a case by
case basis when appropriate. This is too vague. Food safety and
environmental impact assessments should be completed. Even so
monitoring is difficult unless segregation is maintained.
(f) Substantial EquivalenceGene Stacking
We are still concerned at the use of "substantial
equivalence" and believe that the failure to require a full
DNA profile will allow foreign proteins to be missed. Allergy
testing must be completed on humans and be based on the product
as intended to be placed on the market rather than, for example,
the DNA to be inserted or the intended GM protein.
With gene stacking providing several traits
in one crop we believe approval should again be sought. At present
it is expected that once a genetic modification is approved additional
changes still maintain the substantial equivalence criteria.
(g) Terminator Genes
We are also concerned about the approval of
"terminator" traits which prevent the farmer from retaining
seed for the following year. We understand the need to protect
intellectual property rights but believe that this trait may be
used to exploit farmers.
We support the changes that have been made to
the Novel Foods regulations on 26 May. The labelling changes are
more practical for those that wish to sell GM products.
As ever the period for implementation is inadequate
even at 90 days, when considering the number of products affected.
For long life products such as grocery and frozen products it
is not unusual to print packaging once per year. We assume that
as usual enforcement officers will be asked to take a pragmatic
We are still concerned that some ingredients
derived from GM crops will not be identified to consumers, such
as oil. We believe that consumer pressure will continue to build
and this will be amended eventually. We have already removed all
GM soya derivatives from our Own Label range whether or not the
DNA is present.
We are concerned that lecithin may either be
treated as an additive, or if the appropriate purity criteria
are not met, lecithin would be placed on the ingredient exemption
list for labelling. Lecithin clearly contains GM DNA.
(b) Threshold Values
The introduction of a threshold for Non-GM products
is essential if customers are to be given a Non-GM alternative.
Having established ID preserved materials we are building a picture
of the ability of our suppliers to minimise co-mingling.
4. THE FUTURE
It is pleasing to see that some of the biotech
companies are now acknowledging that consumers should be given
the choice of Non-GM alternatives and that segregation is possible.
We are looking forward to working with anyone who genuinely has
these aims. We are confident that we will be able to re-establish
trade with our traditional sources as well as supporting those
that have helped Iceland make this a possibility.
4 June 1998