PRRI letter about the EU Commission proposal on cultivation of GMOs

PRRI Letter to EFSA (2010)
November 30, 2010

Download the original letter as a PDF.

To: the Members of the European Commission,
the Members of the European Parliament,
the Members of the European Council of Ministers

In 2008 the Public Research and Regulation Initiative (PRRI) shared its concern, in a letter to the European Commissioners, about the negative impact that EU policies on genetically modified organisms (GMOs) have on public sector research. This letter is available on the PRRI website (

PRRI was grateful that the Science and Technology Options Assessment Panel of the European Parliament (STOA) picked up our signal of concern and agreed to organise with PRRI in February 2010 a seminar on the impact of EU GMO Regulations on research in biotechnology for the public good. The report of that seminar is available on the STOA and PRRI website.

Key problem of the current situation is that several EU Member States take decisions on the basis of emotions and short term political motivations, rather than on the basis of sound science. In this situation, the European Commission hesitates to act, which leads to serious delays in the approval process. This practice damages the credibility of the EU regulatory system, and is detrimental to the goal of achieving sustainable agricultural production in Europe, because important research is slowing down or moving outside Europe. This practice of ignoring science also has a detrimental effect outside the EU, particularly in developing countries. This involves not just the research (be it public or private) but the whole range of industries that depend on that research.

PRRI was very encouraged when in March of this year the newly installed Commission broke with this approach, by announcing the approval of a GM crop for cultivation, with the accompanying statement that the Commission is not for or against GMOs, but builds its decisions on sound science. PRRI commends Commissioner Dalli for this demonstration of vision.

However, our enthusiasm has dampened after the publication of the Commission proposal to change the GMO Directive 2001/18/EC that would allow Member States to restrict or ban the cultivation of an approved GMO on the basis of other grounds than scientific risk assessment, which can include all kinds of political motivations.

The major concerns of PRRI with regard to this proposal are:

  • Although presented as leaving the central EU science-based authorization system intact, it is in fact the end of it. It allows Member States to restrict or ban the cultivation of an EU- approved GMO on their territories, or parts of it, for reasons that lack a scientific rationale. As scientists we believe it is very dangerous to allow decisions in this area to be taken on the basis of political motivations.
  • If adopted, the proposal will lead to great uncertainty whether the products of public sector research will actually be able to ever reach the farmers. This uncertainty will discourage European scientists to start or continue important research. In addition it will reduce the interest of funding agencies (mostly Ministries for R&D), to commit funds to long term research projects in modern biotechnology, while R&D efforts in this area in others parts of the world will continue to accelerate.

PRRI is not alone in its concerns. The proposal to alter the GMO directive has provoked pertinent criticism from many stakeholders inside and outside the EU, including a number of important Member States. Criticisms focused on various aspects, such as the legality of the proposals, inconsistency with the EU internal market principles and the treaties governing international trade, uncertainty for farmers and others in the agricultural chain, a breach of the freedom of choice, and ignoring that the ability to maintain different agricultural production systems is key to food security.

It is a general principle in Europe that products and services should be accessible to all, unless there are scientifically identified risks for human health or the environment. Allowing any political reason to restrict access to products or services further marginalises science as the basis for informed decision making. This precedent will have implications that will go far beyond modern biotechnology.

PRRI additionally wishes to point out that the Member States that currently oppose the cultivation of GMOs do so because farmers in their country do not wish to grow GMOs or consumers in their country do not wish to buy GM food. The current regulatory system, which is built on the principle of free choice, already allows these choices to be made and there is therefore no reason to alter it. It would be a strange situation that the wish of some farmers or consumers not to have such products at this point in time, would lead to a prohibition for other farmers and consumers to have them.

Having said this, PRRI is also aware that raising concerns about these proposals alone does not help getting the failing regulatory system for GMOs back on its feet. PRRI stands ready to assist the European policy makers in exploring alternative ways to address the regulatory crisis, to the extent possible within the existing rules.

Yours sincerely,

Em. Prof. Marc baron van Montagu
Chairman of the Public Research and Regulation Initiative