Joint Oireachtas Committee on Agriculture and the Marine 09 June 2015
Presentation by the Department of Agriculture, Food and the Marine.
I thank the Chairman for inviting us to update the Committee on the Proposal for a
Regulation of the European Parliament and of the Council amending Regulation (EC) No
1829/2003 as regards the possibility for the Member States to restrict the use of genetically
modified food and feed on their territory.
EU Commission Proposal
This proposal is to allow each Member State decide if they wish to permit or ban the import
and use of GM food and feed in their territory. The proposal states that such prohibitions or
restrictions must be reasoned and based on compelling grounds and must not conflict with the
EFSA risk assessment.
Introduction
Genetic modification is a science-based technology which, in the case of plants, alters the
gene structure in a way that does not occur naturally through fertilisation or natural
recombination. This modification confers certain traits to the plant that can be advantageous
to agriculture and food/feed production. However the application of the technology has
proven to be controversial.
Current EU legislation defines a GMO as “an organism, with the exception of human beings,
in which the genetic material has been altered in a way that does not occur naturally by
mating and/or natural recombination”.
Global Status of GM Crops
According to the International Service for the Acquisition of Agri-Biotech Applications, 18
million farmers in 28 countries planted more than 181 million hectares of GM crops in 2014.
Cultivation is concentrated in five countries with 90% planted in the USA, Brazil, Argentina,
India and Canada. The main GM crops cultivated are maize, soyabean, cotton and oilseed
rape. While herbicide-tolerance and insect resistance are the predominant traits of the
commercialised GM crops, there is an increasing spectrum of traits emerging, which include
drought and salinity tolerance, yield enhancement through more efficient use of nutrients,
disease resistance, improved nutrition content and improved food safety profile.
Regulation of GMOs in the EU
The cultivation and marketing of GM crops within the EU is strictly controlled by EU-wide
legislation which has been jointly adopted by the European Parliament and the Council of
Ministers.
Over the past 15 years the European Union has introduced a suite of regulations governing
the safety, labelling, marketing and traceability of GM crops, food and feed. Central to these
regulations are four main legislative acts, namely:
(i) Directive (2001/18/EC), which outlines the conditions for the deliberate release of
GMOs into the environment and sets out aspects of the risk assessment required
prior to their release;
(ii) Regulation 1829/2003 which sets out the conditions for authorisation, supervision and
marketing of GMOs for food and feed use;
(iii) Regulation 1830/2003 establishes the conditions for labelling and traceability of GM
food and feed
(iv) The Contained Use Directive (2009/41/EC), which lays down measures for the
contained use of genetically modified micro-organisms.
The main aim of this legislation is to give the consumer a clear choice, through labelling,
between GM and non-GM products and the confidence that all GM products placed on the
EU market are safe for human and animal consumption and to the environment and can be
traced back to source.
Authorisation Procedure
GM crops, food and feed are subject to a comprehensive risk assessment by the European
Food Safety Authority before they are authorised for use in the EU. The risk assessment is
designed to ensure GM crops and GM food and feed do not pose a risk to human health,
animal health and the environment.
Preparation of an application to have a new GM crop cultivated in the EU, or to have a new
GM food or feed derived from a GM crop authorisated for import and use in the EU, is the
responsibility of the breeder. The application must be prepared according to standard
guidelines established by EFSA and the OECD. Experts in EFSA then carry out a risk
assessment of the data presented in the application to ensure the GM crop, food or feed are
safe to human health, animal health and the environment.
Following a favourable opinion from EFSA, the EU Commission presents a draft proposal to
the EU Regulatory Committee on GMOs, i.e. the Standing Committee on Plants, Animals,
Food and Feed (SCoPAFF) for vote on approval or rejection of the application for
authorisation in the EU. If no qualified majority is achieved for or against the application, the
proposal is submitted to the higher level ‘Appeals Committee’. If no majority is achieved at
the Appeals Committee, the proposal reverts to the Commission for final decision.
To date, no application to authorise a GM crop for cultivation, or for food and feed use has
received a qualified majority at standing committee. In general, votes have been split
approximately 12 in favour, 12 against and 3 – 4 abstentions. The decision then reverts to the
Commission who have generally approved the applications in line with standard EU policy.
Once a GM product is approved, the authorisation is valid for ten years.
To date, 57 GMOs have been approved for food and feed use in the EU. However, only one
of these (MON 810 – an insect resistant maize) has been approved for cultivation. Of the 57
approved, 30 are maize, 12 soyabean, 10 cotton, 4 oilseed rape and one sugarbeet.
The GM maize, MON810 is cultivated in five EU Member States, namely, Spain, Portugal,
Czech Republic, Romania and Slovakia. The total GM maize plantings in the EU in 2014
amounted to 143,016 hectares, with over 90% of this cultivated in Spain.
All applications for authorisation by the EU to place food and feed products consisting of, or
containing, genetically modified ingredients on the EU market are considered individually
following a comprehensive evaluation of the GMO by EFSA.
In line with Government policy of adopting a positive but precautionary approach on
biotechnology, a common voting position is adopted by Ireland for food and feed on the basis
of a favourable opinion from EFSA and the Food Safety Authority of Ireland.
The comprehensive risk evaluation procedure adopted by the EU has given rise to a time-lag
between the EU and third country authorisations, thus leading to trade difficulties between
the EU and the main global exporters of GM crops, namely the USA, Brazil, Argentina and
Canada. New GM crops that are authorised and cultivated in North and South America are
generally not authorised for a period of one to two years later in the EU leading to rejection
of unauthorised shipments of maize and soyabean at EU ports. Rejection of these shipments
occurs due to the zero-tolerance in the EU of unauthorised GM crops. This disparity in
authorisation timing (known as a-synchronous authorisation) has given rise to considerable
difficulties for the Irish and EU feed trade in past and alteration to the EU authorisation
process as suggested in the current proposal is likely to give rise to similar difficulties in the
shipment of feed materials to Ireland.
Regulation of GM Crops in Ireland
Regulation of GM crops in Ireland is shared between the Department of the Environment,
Community and Local Government (DECLG), the Department of Agriculture, Food and the
Marine (DAFM) and the Department of Health (DoH).
DECLG has primary responsibility for the deliberate release of GMOs into the environment
as governed by Directive 2001/18/EC. The department is also responsible for authorisation of
GMO trials – both field and contained use, including genetically modified micro-organisms.
The EPA assists the DECLG in risk assessment and setting of conditions for the conduct of
the trials as well as conditions for deliberate release.
The DoH has responsibility for use of GMOs as regards food.
DAFM has responsibility for the import and use of GM feed as well as control measures on
cultivation post commercialisation, should that arise.
GM Feed
The EU is only 35% self-sufficient in protein supplies for animal feed and soyabean is the
most favoured vegetable protein because of its nutritional efficacy and competitive cost.
In Ireland, up to 80% of animal feed for ruminants is provided by grass, hay and silage,
complemented where appropriate, by compound feeds. In the case of pigs and poultry,
virtually all their nutrition is derived from compound feeds.
The Irish cereal harvest is generally in the region of 2.2 millions tonnes per annum.
Approximately 1.7m tonnes of this is used for animal feed with the remainder used in the
food and drinks sector.
On average, Ireland imports about 3 million tonnes of animal feed materials per annum. In
addition, approximately 1.7 million tonnes of home-grown cereals is used in the production
of feed, bringing the total usage of feed mateerials to about 4.7 million tonnes.
Approximately 66% of these feed materials are used for ruminant feed, 16% for pigs, 12%
for poultry and 6% to other animals. Of the three million tonnes imported, approximately
55% is sourced from third countries outside the EU, mainly Argentina, the USA, Ukraine,
Canada and Brazil.
Over 1.2 million tonnes of soya and maize GM products were imported into Ireland for
animal feed in 2014, constituting 40% of total feed imports. The main commodities imported
are maize and maize by-products, soyabean meal and soya hulls and rapeseed meal. Up to
90% of the soyabean and maize products imported from Argentina, Brazil and the USA are
derived from genetically modified crops,
Significant quantities of non-GM maize and oilseed rape meal are imported from continental
Europe, including Ukraine.
Ireland is especially dependent on feed imports relative to other EU Member States in that
approximately two thirds of the feed materials marketed here are imported compared to 37%
in the UK, 27% in France and 26% in Germany.
The pig and poultry sectors, which employ almost 10,000 personnel in production and
processing, are particularly impacted as soyabean is an essential ingredient in the formulation
of these feed rations.
Feed Industry Position
The Food and Feed Chain Coalition (FFC) which represents 10 EU member organisations
from different parts of the food and feed chain have expressed their opposition to the
proposal from the EU Commission, as have the Irish Grain and Feed Association (IGFA).
The animal feed industry in Ireland considers that the import of significant quantities of
soybean and maize from North and South America, where GMO cultivation is widespread, is
essential to satisfy the protein fraction in animal nutrition. Trading difficulties have arisen in
the past due to zero tolerance of unauthorised GM crops and further difficulties with such
imports are likely to be exacerbated in the future as an increasing number of GM crop
varieties are cultivated in North and South America in advance of authorisations being
achieved in the EU. In previous years the US has delayed the cultivation of new GM varieties
to ensure compatibility with EU authorisations, but this practice is increasingly difficult to
implement due the widespread adoption of ‘stacked’ or multiple GM traits in GM crops.