TWN Info Service on Biosafety
14 May 2024
Third World Network
www.twn.my
Dear Friends and Colleagues
Improving Traceability to Prevent Unauthorised GMOs in the EU
Advancements in so-called “new genomic techniques (NGTs)” have led to challenges for detection and identification. Traceability involves the ability to monitor the movement of food and feed through specified stages of production, processing and distribution.
Improvements to the existing traceability strategy for GMOs are investigated in this study. There are a number of exisitng regulations that prohibit the import of certain products without analytical control methods available to prove that the imported products comply with the regulation.
For GMOs, the authors propose reversing the burden of proof: All companies importing agricultural commodities must identify risks of unauthorised GMOs (including NGTs) in their supply chain and, where appropriate, take measures to minimise the risk to raw material imports. This necessitates the declaration of not only authorised GMOs (as per current requirements) but also the absence of GMOs and would have to apply to everyone, not just the non-GM sector. This could be ensured through a specific due diligence regulation that requires that importers introduce a traceability system for their supply chains and identify and assess the risk of GMOs in their supply chain.
With best wishes,
Third World Network
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STRATEGIES FOR TRACEABILITY TO PREVENT UNAUTHORISED GMOS (INCLUDING NGTS) IN THE EU: STATE OF THE ART AND POSSIBLE ALTERNATIVE APPROACHES
Teufel, J., López Hernández, V., Greiter, A., Kampffmeyer, N., Hilbert, I., Eckerstorfer, M., … & Simon, S.
Foods, 13(3), 369
https://doi.org/10.3390/foods13030369
https://www.mdpi.com/2304-8158/13/3/369
Abstract
The EU’s regulatory framework for genetically modified organisms (GMOs) was developed for “classical” transgenic GMOs, yet advancements in so-called “new genomic techniques (NGTs)” have led to implementation challenges regarding detection and identification. As traceability can complement detection and identification strategies, improvements to the existing traceability strategy for GMOs are investigated in this study. Our results are based on a comprehensive analysis of existing traceability systems for globally traded agricultural products, with a focus on soy. Alternative traceability strategies in other sectors were also analysed. One focus was on traceability strategies for products with characteristics for which there are no analytical verification methods. Examples include imports of “conflict minerals” into the EU. The so-called EU Conflict Minerals Regulation requires importers of certain raw materials to carry out due diligence in the supply chain. Due diligence regulations, such as the EU’s Conflict Minerals Regulation, can legally oblige companies to take responsibility for certain risks in their supply chains. They can also require the importer to prove the regional origin of imported goods. The insights from those alternative traceability systems are transferred to products that might contain GMOs. When applied to the issue of GMOs, we propose reversing the burden of proof: All companies importing agricultural commodities must endeavour to identify risks of unauthorised GMOs (including NGTs) in their supply chain and, where appropriate, take measures to minimise the risk to raw material imports. The publication concludes that traceability is a means to an end and serves as a prerequisite for due diligence in order to minimise the risk of GMO contamination in supply chains. The exemplary transfer of due diligence to a company in the food industry illustrates the potential benefits of mandatory due diligence, particularly for stakeholders actively managing non-GMO supply chains.