GeneSprout members have responded enthusiastically to the EU commission’s call for comments on the process for new legislation to regulate New Plant Breeding Techniques / New Genomic Techniques.
Please bear in mind that all of our comments below are made in our personal capacities as young plant scientists in the EU, and reflect a spectrum of individual views within our organisation.
We strongly encourage all stakeholders to comment on the EU Commission proposal at the Commission site here.
Juriaan Rienstra
GeneSprout Board Member
"Using NGTs creates a synergy between biotechnology and organic agriculture that is greater than the parts"
We need sustainable solutions to prevent the climate catastrophe, and we need the solutions fast! Research on the use of new genomic techniques (NGTs) in plant breeding have shown what great potential this technique holds: we can domesticate locally adapted crops, we can finally target some key issues like allergens in plants (e.g. peanuts and wheat), and we can increase the nutritional value of our crops (GABA tomato). The genome of these plants are indistinguishable from plants that we find in nature. If this mutation can happen in nature, then why are we so worried about the technique used to make this mutation? At the same time we have an enormous potential of early career scientists who would dedicate their life to making our agriculture more sustainable. We are the generation of scientists who recognize, worry and fear about the bleak future if we cannot stem the tide of climate change. So with our own futures in mind, we would do anything in our power to make our way of life more sustainable. Yet this potential and sustainability drive remains unutilised because the current prohibitive GMO legislation means that there is no funding for any of our research. I recognize that the EU wants to do the right thing with the Green Deal and Farm to Fork strategy, but I worry that putting all the focus on organic agriculture alone to stave off the climate crisis will fail. While I am in favour of organic agriculture, the yield gap is still huge, so changing our conventional agriculture land will logically necessitate using more land for agriculture. This opposes the idea of decreasing our land use and increasing biodiversity. We urgently need to change the legislation to allow the use of new genomic techniques. Using these techniques would create a synergy between organic agriculture and biotechnology that allows us to reach the goals of the Green Deal. It will also fully harness the talents of the younger generations of scientists in creating a sustainable future.
Matteo Martina
GeneSprout Ambassador
"These technologies can have a huge impact on crops resistance to both biotic and abiotic stresses"
I welcome the legal initiative by the Commission because I see a need for a novel legislational approach to New Genomic Techniques. In a world that is constantly changing, at a tremendous speed rate, classical breeding cannot easily keep pace with the society needs. Climate change is a fact, as well as global population increase, and we need technologies to face these challenges. NGTs can help breeders speeding up cultivar development, allowing to introduce mutations already present/potentially present in the environment in crops material, without requiring years of breeding projects. These technologies can have a huge impact on crops resistance to both biotic and abiotic stresses, such as pests, pathogenes, drought, heat/cold, and flooding and cannot be evaluated in the same way we evaluate pesticide-resistant transgenic crops. I do understand major concerns about health safety, but I cannot see how NGTs technologies could be more dangerous than the classical mutagenesis approach that was used in the development of already well-established and often-called “ancient” – in a positive way – crops varieties. If mutagenesis (application of chemical or radiation treaments to induce random mutations in a plant) is possible and varieties obtained through this randomic technology have been marketed since the second half of the XX century, why cannot we move forward with a on point and specific tool, such as NGTs?
Halford Dace
GeneSprout Board Member
"we will not meet our goals through wishful thinking, nor through unwieldy regulations designed to manage different technologies."
I welcome the EU initiative to refine and improve the regulation of New Genomic Technologies.
The European Union has committed itself to ambitious goals for improving the sustainability of its agricultural practices over the coming decade. In the face of climate change, population growth and migration, and increasing land use pressure, farmers and crop breeders will be challenged to assure yields while improving crop resilience and resistance, all while reducing the application of plant protection chemicals.
Achieving these goals will require the rapid development of new varieties that are resistant to pests, diseases, drought, salinity and temperature fluctuations.
The time required by conventional breeding would typically be a decade or more to introduce a single such trait by introgression, with this time being reduced to 2-3 years using NGTs.
The climate crisis is now well and truly upon us, and we will not meet our goals through wishful thinking, nor through unwieldy regulations designed to manage a very different class of technologies.
Through both refined regulation of NGTs and of the IP framework surrounding them, the EU must enable breeders of all sizes, from nonprofits and SMEs to well-resourced corporates, to contribute solutions as fast as possible.
Ramon de Koning
GeneSprout Board Member
"Let's use these new breeding tools to give Europe the leading role in sustainable agriculture!"
I’m very happy to hear that the commission is willing to give gene editing a chance!
This technique can introduce beneficial traits in crops in a fast, accurate, and especially secure way.
With the current climate crisis and the aim to make farming more sustainable, these techniques are especially important and could provide a solution to tackle these challenges.
Conventional and organic farming could substantially be helped if these crops produced with gene editing would not be seen as GMOs and these crops could further enhance the sustainability in agriculture.
Crops produced with gene editing where only small changes occurred can not be differentiated from crops produced with more traditional breeding methods.
This will make enforcing the law much harder if the EU keeps its strict regulation and will most likely lead to consumers being misled because the EU will import crops produced with these new techniques without labeling them correctly.
Furthermore, it’s been shown that easier and more clear regulations could especially be beneficial for SMEs and institutions to bring their innovative solutions to the market. If the EU would keep its strict and unclear regulation, Europe will lack behind in terms of tools to build a more sustainable world, will hamper its economic growth, and you will get a drain of experts who will use their knowledge outside the EU.
Let’s use these new breeding tools to give Europe the leading role in sustainable agriculture!
Nikita Sajeev
GeneSprout Co-Founder
"As a young plant scientist, I am passionate about using the knowledge I generate for the benefit of our planet."
As a young plant scientist, I am passionate about using the knowledge I generate for the benefit of our planet. We spend years trying to discover ways to help plant survive challenging environmental conditions. The application of this knowledge in a fast, efficient and targeted manner has become even more urgent to combat the threats of climate change and ensure food security. New genomic techniques gives us the opportunity to apply our knoweledge into food crops like never before. We can also domesticate wild species to make new food crops that are better suited to the local environment thereby increasing the biodiversity of the crops used in agriculture. In my opinion that what makes new genomic tools even more special is that it can be used to create modified plants that are genetically similar to those found in nature. I see this as a huge step for the acceptance of this new technology in agriculture, because public perception is also important.
As a young plant scientist, I CARE that my research has a positive impact on our planet. I CARE about the future of scientific innovation, I CARE about the generations yet to come and I am very CONCERNED, about climate change, the depleting resources and our population growing in an unprecedented manner. I realize it can be easy to ignore the fact that, that the global temperature is rising and farmers are facing huge crop losses, as long as our fridge is stocked. But if we make a choice today that is unsustainable, it will have a cost on our future and the generations to come and that is just not ethical. We need to use these tools now to be able to feed the world in a sustainable manner.
Anon
Anonymous GeneSprout Supporter
"If the use of NGTs leads to the same risks than these from conventional breeding (EFSA opinions), then why would two different regulations be used?"
I will first use some of the valuable 4000 characters to note the massive spamming that is made by “EU citizens” that ask the Commission to regulate strictly NGTs under existing GMO regulations.
Here is a different view that hopefully will be visible in the sea of spam feedback.
Firstly, seeing that a proposal is made to review and hopefully change the existing regulatory system that the Commission has dubbed “no longer fit for purpose” is excellent news! But why just address two specific applications? The GMO regulatory system needs a thorough review and rectification of a number of inconsistencies that are linked to its wrong design that has only shined more because of the new technologies.
Specifically, the fact that a minuscule number of products are handled apart from other similar products because somewhere in their development people used biotechnology. An argument has been made in the past that this is because of a precautionary approach to new technologies. Well, how long will this precautionary approach last and should it not be questioned in light of the massive amount of scientific evidence that is available to us today?
In moving forward, the EC must explain when exactly should the precautionary principle be still evoked and when it is not appropriate any longer.
The current regulation includes mandatory labeling of safe products to allow “consumer choice”. The “GMO technology” label is broadly understood to be a safety warning and has made many of us very concerned with the circulation of GMOs in our food and the environment. But in reality, given that the products are on the market, it is clear that they are safe. So the mandatory labelling is not about safety but about the production method.
When all other production method labels are voluntary (e.g. organic labelling) and are used to signal value to the consumers that may be inclined to pay more, why would the GMO production label be compulsory?
In their considerations about the future legislation for new technologies the Commission must reflect on how to rectify the current situation with the GMO labelling. One way would be to ensure that all “production method” labels are voluntary, including the one for GMOs or any other NGTs. This will be very just and non-discriminatory.
The opposite approach – to seek mandatory labels because some group of consumers may have specific preferences is not justifiable. If it was, the Commission may wish to regulate also cultural or religious production claims – all currently, and rightly so, handled by private bodies.
The Commission is asking views on what should be appropriate regulation for plant products developed with NGTs – targeted mutagenesis and cisgenesis? Ideally, such plants should be handled as any other “conventional” plants. If the use of NGTs leads to the same risks than these from conventional breeding (EFSA opinions), then why would two different regulations be used? If a risk arises from conventional breeding, are we to believe that this will have unforeseen and catastrophic consequences? And that there is no regulation? Obviously, there is plenty of product, health and safety and environmental regulation to ensure quality and safety of non-GM products. So why would there be a need for a dedicated GMO regulation, and even more so, for a dedicated NGT regulation?
The Commission should, therefore, also consider if NGT plant products can simply be handled within existing regulation outside of the GMO framework? There is no reason why this should not be the case for comparable products.
And finally, the issue of sustainability is now being mainstreamed across many EU policies – if we want to see actual advances in this field, we must forget ideology and become technology neutral. It appears that close focus on selected product groups (the NGT plants) is not the way forward. Instead, a broader approach applying equally to all products should be pursued.
Harm
GeneSprout Ambassador
"The European Union must recognise that new genomic techniques have a unique potential to reach their sustainability goals."
Gwen Swinnen
GeneSprout Board Member
"New genomic techniques could contribute to the development of more climate resilient and more nutritious plant varieties."
Plant breeding has always depended on genetic diversity. By selecting for variation within the DNA of our foods for thousands of years, we have made them more nutritious, more productive and better adapted to agricultural practices. Much of what we eat today could not exist without it. While plant breeding initially had to depend on random DNA changes happening by chance, the introduction of mutagenesis breeding presented plant breeders with the ability to insert variation into DNA, but still at random and at many genetic locations simultaneously. Despite this and other scientific breakthroughs, plant breeding is still a time-consuming process. Targeted mutagenesis is a tool of precision, that can be used to introduce the same type of DNA changes but faster and in a specific genetic location. Targeted mutagenesis therefore allows knowledge-based and accelerated plant breeding. I believe that evidence-informed policymaking can put to use the scientific progress we’ve made in helping agriculture become more sustainable.
Elena Del Pup
GeneSprout Board Member
"I chose to study plants because I believe in their great potential in the face of the climate challenges ahead of us. And I believe that NGTs are the tool to uncover that potential."
If the GMO directive was applied to “all GMOs”, as most of these replies are asking, most of the fruits and vegetables from our tables will be gone, because they are the result of mutagenesis, which is also a “GM” by legal definition (Directive 2001/18/EC).
This is why I welcome the initiative of the Commission. I hope that we will make some clarity and distinction between the conventional transgenic GMOs, which are the ones raising this discontent, from other techniques which are promising for the future of agriculture and to fulfill the goals of the EU agricultural and environmental policy agenda.
I am a student of plant sciences and I am learning how plant breeding (natural crossing and follow-on artificial selection of plant progenies) is fascinating but also very hard to perform: mating plants is not at all easy (crossing barriers, polyploidy, etc.), and creating a new plant variety may take 5 to 15 years. Why is it important to create new plant varieties? Because the intensity and frequency of pests and resistances are increasing, together with drought or intense rainfall; the climate is changing and is posing agriculture at risk; too little biodiversity is on our tables and in our diets; we have ambitious goals for sustainability, which risk being an impossible burden for farmers and farming, while we are not looking at the only technology that can really make the difference: which is plants and plant seeds. Conventional plant breeding is simply not capable of addressing all these problems timely before it is too late: this is why New Genomic Techniques are the tool that we, as plant scientists and plant science students, are most excited about.
In addition, as plant breeders, we have limited opportunities to preserve biodiversity and to leverage minor crops with conventional methods, because they are less studied than other major crops (corn, wheat, rice). For those crops, the path of domestication (crossing them to make them suitable for farming) is simply not an option, because it required millennia for the current crops to be domesticated. New Genomic Techniques (NGTs) can protect biodiversity and enrich agricultural biodiversity because they can perform a “de novo domestication” of such minor crops.
We often forget that plants are one of the most beautiful technologies that humans have ever encountered on Earth: we have been changing plant genomes since the first farmers started sowing their seeds and selecting the best seeds for the next season (10.000 years ago circa). As a plant science student, I chose to study plants in my career, because I believe in their great potential in the face of the climate challenges ahead of us. And I believe that NGTs are the tool to uncover that potential.
Coming from a background in agricultural science, and being concerned about the complexity and the issues of farming and sustainable farming, I am most convinced that NGTs will be welcomed by farmers. Having studied organic agriculture and agroecology, and being greatly inspired by their approaches, and greatly concerned about the challenges that they are facing, I am convinced of the great synergy that can be established with NGTs.
If we were to drop preconceptions and misconceptions about tools, coming from suggestive terms such as “genetic modification”, and we would only focus on our social and environmental goals, we would understand how important it is to give these techniques a reasonable chance. Having said this, I am sure that NGTs are NOT the only tool to attain these goals. But, from my experience as a plant scientist, I know that for what concerns the subject that I am studying, they fundamentally are.
Like me, many young plant scientists and plant science students are dedicating their lives to sustainability goals, through studying plant genomes. If the future is of the next generations, why not hear what the next generations have to say about a tool that can preserve their future?
Jonathan Rudolph
GeneSprout Ambassador
"With genome editing I can easily introduce small, targeted genetic changes in crops."
I welcome the legal initiative by the Commission because with genome editing I can easily introduce small, targeted genetic changes in crops. These changes improve their root system which will result in better resistance to drought, better uptake of nutrients and improved soil quality. This will contribute to the reduction of yield losses in countries with harsh climates, and benefit countries where food is scarce and low in valuable vitamins and minerals.