GeneSprout Initiative’s statement on EC’s proposal for a regulation on plants obtained by certain NGTs



Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on plants obtained by certain new genomic techniques and their food and feed, and amending Regulation (EU) 2017/625

July 11, 2023

GeneSprout Initiative is a collective of early-career researchers in Europe dedicated to promoting responsible adoption and advancement of New Genomic Techniques (NGTs) in agriculture. By facilitating open dialogues and constructive discussions, we aim to foster collaboration and knowledge exchange among scientists, policymakers, industry representatives, farmers, and the general public. Our platform provides a unique opportunity for these diverse stakeholders to actively participate in the exploration of plant genome editing and its sustainable applications in agriculture. 

Europe has always been an important scene for the advancements of plant biology, plant technology and genetics that we rely on today. NGTs enable the development of new plant varieties at unprecedented speed and efficiency, based on a priori knowledge. Currently, the legal status of genome-edited plants in the European Union is unclear, due to different interpretations of the CJEU C-528/161, and not fit-for-purpose, as pointed out by the European Commission (EC) study on NGTs2. GeneSprout Initiative welcomes the EC’s proposal for a regulation on plants obtained by certain NGTs and their food and feed3.

This proposal will allow for a legal framework that supports the translation of promising research findings to the European market. We consider it important that the proposal guarantees equal access to the market for genome-edited crops with modifications that cannot be distinguished from their conventional counterpart (category 1). The criteria of these DNA changes are clearly defined and endorse a fit-for-purpose regulation of genome-edited crops. The same way as conventionally-bred crops, genome-edited crops will be subjected to the Novel Food Regulation if their nutritional value is affected. This proposal further establishes that category 1 crops are not required to have any detection methods, which GeneSprout Initiative considers a rational decision given that these genome-edited crops cannot be distinguished from conventionally-bred plants on the genetic level and thus any detection requirements could not be enforced. However, to assure traceability, the proposal requires these genome-edited crops to be listed in a public register. Our initiative supports this transparency requirement that gives consumers freedom of choice. We also  welcome the case-by-case approach for risk assessment on genome-edited plants of category 2. 

GeneSprout Initiative is concerned with the right to the delegated acts that allows the EC to adapt the defining criteria of category 1, as we are apprehensive about the legal leeway this allows for. Finally, our initiative regrets the exclusion of genome-edited plants from organic farming systems. We consider it as a missed opportunity to provide organic cultivation methods with all the tools available that support the ethical values of organic farming.

In summary, GeneSprout Initiative supports the proposal of the European Commision for a regulation on plants obtained by certain NGTs and their food and feed3. We are convinced that an ongoing open dialogue about the proposal and a science-based approach will allow for a fit-for-purpose regulation that will assure Europe’s position at the international forefront of plant breeding and as a leading example for a sustainable agricultural future. 

1 CJEU Case C-528/16
2.EC study on new genomic techniques 
3”and amending Directives 68/193/EEC, 1999/105/EC, 2002/53/EC, 2002/55/EC, and Regulation (EU) 2017/625”.