Memorandum submitted by Consumers' Association
GM GOVERNMENT DECISION
INTRODUCTION
1. Consumers' Association welcomes the Committee's
inquiry into the implications of the government's recent decision
to agree to limited cultivation of genetically modified (GM) maize
in the UK. We would like to draw the Committee's attention to
the implications of this decision for consumers and highlight
some of the findings from our consumer research into attitudes
towards GM foods which we consider need to continue to be borne
in mind.
2. In general we consider that the government
has given the go-ahead to cultivation of a GM crop prematurely.
We also consider that in doing so it failed to take account of
the results of its public dialogue and in particular the GM Nation
public debate. Its position also stands in stark contrast to its
rhetoric about reconnecting farmers with consumer demand. Fortunately
the decision by Bayer CropScience not to go ahead with commercialisation
of the crop concerned, Chardon LL maize, provides an opportunity
for the government to re-assess its position and the measures
that need to be taken before commercialisation should go ahead.
CONSUMER ATTITUDES
AND CONCERNS
3. We have monitored consumer attitudes
towards GM foods over the last 10 years. There is no doubt that
the use of genetic modification in food raises concerns for many
consumers. While proponents of the technology often dismiss such
reservations as media-fuelled and misinformed, our research highlights
that consumer attitudes to the technology have remained fairly
consistent over the years. Rather than being irrational, they
reflect the fact that many people still feel that not enough is
known about the implications of the technology and as they also
currently see no benefits offered by the technology they consider
it premature to go ahead with growing of GM crops. Our most recent
survey in 2002 found that less than a third (32%) of respondents
were in favour of growing GM crops at the current time[10]
The main reasons given were concerns that there was a lack of
information, concerns about food safety, environmental impact
and long-term consequences for health. However people acknowledged
that it was possible that the technology could offer consumer
benefits in the future.
4. The results of the Public Debate clearly
highlighted public unease about the technology. As the report
of the Debate makes clear: "They were uneasy not only about
issues directly related to GM technology but about a range of
broader social and political issues. The mood ranged from caution
and doubt, through suspicion and scepticism, to hostility and
rejection." The Debate also made clear that the more people
engage with GM issues and discover more about them, their attitudes
harden. Although these people are more willing to accept some
potential benefits from GM, they become more doubtful about the
others and express more concern about all of the risks most frequently
associated with GM.
5. The results of the GM Citizens' Jury[11]
that we jointly funded with Greenpeace, Unilever and the Co-op
and which was organised by Newcastle University also concluded,
after six weeks of hearing evidence from a wide selection of expert
witnesses, that there should continue to be a moratorium on growing
of GM crops at the current time. Similarly, the Citizens' Jury
organised by the Food Standards Agency last year also unanimously
agreed that more time is needed to understand the long-term environmental
implications of GM crops before farmers start to grow them in
the UK and that "growing crops in the UK would be irreversible
and might eventually reduce choice."
6. The government has stressed that under
Directive 2001/18, which deals with the deliberate release of
GMOs, it can only prevent cultivation on environmental or public
health grounds. It is also clear that the government sees clear
benefits from the use of GM technology and has concerns that failure
to go ahead with commercialisation may be damaging to the technology
overall. However, we are concerned that a decision to go ahead
before consumer concerns have been adequately addressed by more
fully investigating the environmental, health and consumer choice
implications, will be far more damaging in the long-term. As the
Strategy Unit's report into the costs and benefits of GM crops
which formed one of the strands of the government's public dialogue
acknowledged, there are unlikely to be any short term benefits
from growing of GM crops and any benefits will depend on consumer
acceptability.
PRESERVING CHOICE
7. While ultimately it should be a question
of choice whether or not consumers choose to eat GM foods, we
are concerned that that choice would not be a meaningful one.
The new GM food and feed regulations establish a threshold for
adventitious contamination by GM material of up to 0.9% in the
case of non-GM identity preserved supplies. Up until now, issues
around consumer choice have focused on dealing with the nature
of the global commodity crop market and potential for contamination
of crops grown in North America and Brazil. The 0.9% threshold
was established on this basis. At the moment, there is no consumer
demand for GM products. This is reflected by the policies of the
main retailers, manufacturers and caterers. A survey that we carried
out at the end of 2002[12]
highlighted that they all had non-GM policies and in most cases
these extended to GM derived ingredients. It is clear that they
have no plans to sell GM products for the foreseeable future.
8. Co-existence rules are therefore crucial
if consumer choice is to be maintained if GM crops are grown in
the UK. In her statement to the House of Commons outlining the
government's policy on GM commercialisation, the Secretary of
State Margaret Beckett stated that farmers who wish to grow GM
crops should be required to comply with a code of practice based
on the EU's 0.9% threshold and that this Code should have statutory
backing.
9. We consider that the approach outlined
by the UK government, as well as by the European Commission which
has failed to take a lead in this area, to be inadequate. If consumer
choice is to be effectively maintained, we consider that clear
and binding rules are needed if it is to be ensured that farmers
comply. It is also essential that these rules are adopted at European
level, while allowing some flexibility for the specific circumstances
that apply in Member States in order to ensure that consumers
are adequately protected. If different rules and measures are
adopted within different Member states it is impossible to see
how a meaningful choice could be maintained within the common
market. We do not consider that a code of practice with statutory
backing would go far enough. Once GM crops are grown there will
be no going back if non-GM and organic products are contaminated.
It is also vital that careful consideration is given as to how
choice will be maintained along the supply chain to prevent accidental
mixing and contamination. We are disappointed that the Food Standards
Agency has not represented consumer interests in this respect.
10. Consumers expect contamination to be
kept to an absolute minimum. We are therefore concerned that 0.9%
will be used as a threshold. The aim should be to work to the
lowest level of contamination that is possible. The government
acknowledges that specific concerns apply to organic crops and
has stated that it will explore further whether a lower threshold
should be applied to organic crops on a case by case basis. We
agree that this should be the case. We agree with the conclusions
of some members of the Agriculture and Environment Biotechnology
Commission (AEBC) that it is appropriate to work to a zero threshold
which in practice would mean a 0.1% threshold based on the practical
limit of detection.
LIABILITY
11. It is also essential that clear rules
dealing with liability are in place before commercialisation of
any GM crop should go ahead. Clear rules are needed to deal with
environmental damage (currently being considered at EU level based
on the "polluter pays" principle) and also in the event
of contamination. Margaret Beckett in her statement on the government's
policy announced that there will be a consultation on options
for providing compensation to non-GM farmers in such an event
and that such a compensation scheme would have to be funded by
the GM sector. We welcome such a consultation and believe it is
essential that such rules are clarified before any commercialisation
is given the go-ahead.
MEETING DEMAND
12. If commercialisation of the GM maize
had gone ahead, as the government has permitted, the maize would
be used for animal feed. Under the GM food and feed regulations
the animal feed would have to be labelled to indicate the presence
of any GM ingredients or derivatives although the final meat or
dairy product would not have to be labelled. We have welcomed
efforts by some retailers and manufacturers to provide consumers
a choice of meat and dairy products that are reared on non-GM
feed. Given that at the moment the majority of consumers have
no desire to consume products of genetic modification, it is again
very unfortunate that supply chain issues did not appear to have
been thought through. Provision of non-GM supplies to the consumer
have been a challenge that the food industry has had to meet in
response to consumer demand. It is incredible that the government
could put this at risk by authorising the growing of a crop which
offers no consumer benefits and for which there is currently no
demand.
13. Typical of the whole handling of the
introduction of this new technology, there has been a total failure
to recognise consumer attitudes and demands. Unlike any other
food, the introduction of new products has not been dependant
on consumer demand, but rather decisions about what is or is not
acceptable for us to consume has been made by those further down
the food supply chain. We welcomed the fact that the government
finally agreed to organise a public debate. However this was given
limited resources both in terms of financial support and time.
Despite this, many people participated and came forward with their
views. It is very unfortunate that the government has decided
to dismiss the concerns that were raised and which clearly reflect
the views of the vast majority of the population. We have still
to see an official response to the conclusions of the Debate.
INTEGRATING CONSUMER
CONCERNS
14. This highlights a broader need to have
more effective mechanisms for integrating public opinion into
policy decisions. The issues around genetic modification and the
extent of public concern are highly complex bringing together
issues around consumer safety, but also concerns about social,
ethical and environmental impacts of the technology. Despite this,
decisions about whether or not to grow GM crops are narrowly based
on a scientific assessment of risks to public health and the environment.
The extent to which the public perceives the risks associated
with GM and find them acceptable will be depended on these broader
factors—for example while the technology is perceived as
offering no consumer benefits, people are unlikely to be willing
to accept any risk. Within the recently agreed GM food and feed
regulations, there is the scope under Article 7 for "other
legitimate factors relevant to the matter under consideration"
to be taken into account when authorising products. As explained
in recital 32 of the regulation: "It is recognised that,
in some cases, scientific risk assessment alone cannot provide
all of the information on which a risk management decision should
be based, and that other legitimate factors relevant to the matter
under consideration may be taken into account." No similar
provision exists within Directive 2001/18 dealing with the deliberate
release of GMOs and this should be addressed.
Consumers' Association
April 2004
10 GM Dilemmas, Consumers' Association policy report
2002-998 in-home interviews were carried out with a nationally
representative sample aged 15 plus across Great Britain between
16 to 22 May 2002. Back
11
www.gmjury.org.uk Back
12
GM Dilemmas, Consumers' Association policy report 2002. Back
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