Memorandum submitted by Food and Drink
Federation
GM GOVERNMENT DECISION
EXECUTIVE SUMMARY
The Food and Drink Federation (FDF) is the leading
representative of the UK food and drink manufacturing industry.
Our members are downstream users of UK agricultural produce. Our
industry aims to offer choice to its customers, and in so doing
has established supply chains to provide non-GM food and food
ingredients.
Any decision to allow the growing in the UK
of GM crops would need to provide for the co-existence of all
agricultural sectors, whether GM, organic or conventional (intensive).
We believe the food manufacturing industry has appropriate systems
in place to manage separate supply streams, provided upstream
separation is achievable.
1. Introduction
1.1 The Food and Drink Federation (FDF)
is the leading representative of the UK food and drink manufacturing
industry. As such we are downstream users of primary produce of
both vegetable and animal origin, which is the basis of most of
our raw materials. We believe that genetic modification (GM) could
offer benefits throughout the food chain, from primary producers
to final consumers. However, as food manufacturers operating in
a highly competitive market, we have to meet the needs and demands
of our customers, whether part of the food processing chain, or
retailers, or end consumers. The majority of our customers currently
chooses not to purchase products of GM origin. Hence complex supply
chains have evolved since the introduction of GM soya and GM maize
in the commodity supply chain from the USA in 1996, to ensure
consumer choice of non-GM soya and maize where these are used
as ingredients, or products have been reformulated to remove soya
and maize and their derivatives as ingredients.
2. Assessment of potential impact of HMG's
decision
2.1 Experience with identity preserved (IP)
supply chains, coupled with the new traceability and labelling
requirements which apply from 18 April 2004[13]suggests
that any GM maize grown in the UK as a result of the Government's
decision, can be managed in such a way as to provide choice to
those purchasing maize as a fodder crop, or to the purchasers
of the products of the animals fed on the maize. Whilst the separation
of supply chains inevitably adds costs along the chain, the situation
is no different from that at present. We do not anticipate large
scale planting of GM maize in the UK, where climatic conditions
do not favour this crop. Indeed the company responsible for developing
the GM maize variety in question announced on 31 March 2004 that
it would not proceed with the commercial planting of this variety.
3. In relation to co-existence, what physical
separation will be required between GM and non-GM crops in order
to guard against cross-contamination?
3.1 FDF, representing processors rather
than primary producers, has no specific expertise in this area.
We are aware of the recommendations of the Agriculture and Environment
Biotechnology Commission's (AEBC) Report "Crops on trial"[14]
and its subsequent report on co-existence and liability[15]
In addition, the European Commission last year published recommendations
to ensure co-existence of GM and non-GM crops.[16]
These appear to us to provide a sensible framework for detailed
consideration at national level.
4. If cross-contamination occurs, how will
liability be established and responded to, who should be legally
responsible and what should the limits of that responsibility
be—and what role should Government play in determining these
matters?
4.1 The question implies that cross-contamination
would be deleterious and invoke a chain of liability and fault.
"Liability" is a complex legal concept which, we understand,
involves proving that harm has been caused or a loss suffered.
The issue is generally associated with organic farming, though
in a system which operates to a self imposed "zero tolerance"
threshold for GM, it is difficult to see how a legal liability
regime could be imposed. In the event of any harm being caused
to the environment in general, it would appear evident that an
assessment of the damage and its consequences would need to be
carried out and legal procedures invoked in a manner similar to
any other environmental pollution. The AEBC has explored these
issues in detail and recommended that "Government should
use the general approach of the draft EU Environmental Liability
Directive to develop the UK's liability regime for any damage
caused by the release of GMOs to the environment"[17]
The AEBC further recommends amendments to the Environmental Protection
Act 1990 in respect of environmental remediation if environmental
harm were to be caused by the release of GMOs, and placing responsibility
for dealing with any environmental effects with the competent
regulatory authority. This appears to us to be a logical and reasonable
approach.
4.2 Other matters are likely to relate to
consumer choice and are best dealt with under protocols for positive
environmental management of the cultivation of GM and other crops[18]
and by reference to the Commission's recommendation of 23 July
2003.
5. What processes will be involved in determining
how GM free zones will be established at both a regional and local
level and what role should Government play in this development?
5.1 The Government will need to consider
carefully the rights and choices, both of those who wish to grow
GM crops, as well as those who wish to avoid them. We refer again
to the establishment of protocols and the Commission's guidance,
noting that "GM free" may be difficult to achieve, depending
on how "GM free" is defined and what powers are vested
at either national or local level to designate specific zones
as "GM free".
6. What changes to legislation will be required
to allow GM crops to be grown?
6.1 We understand that, following approval
at EU level under the Deliberate Release Directive, 2001/18, HMG
may impose specific restrictions on the marketing consent, as
in the case of Chardon LL maize, and that commercial cultivation
cannot proceed until the variety has been added to the UK National
List of Seeds.
7. What will be the scope and scale of the
2006 relicensing procedures?
7.1 This is a matter outside our competence.
We understand that, in the case of Chardon LL maize, the company
responsible for the development of this variety does not propose
to proceed with the 2006 relicensing procedures for economic reasons.
Food and Drink Federation
April 2004
Annex
THE UK FOOD AND DRINK MANUFACTURING INDUSTRY
The Food and Drink Federation (FDF) represents
the food and drink manufacturing industry, the largest manufacturing
sector in the UK, employing over 500,000 people. The industry's
annual turnover is over £66 billion. It purchases some £11
billion worth (about two thirds) of UK agricultural produce and
imports a further £7 billion worth of produce for processing.
UK food and drink exports in 2002 were nearly £9 billion.
About two fifths, £3.3 billion, of these exports went to
non-EU countries.
The following organisations are members of the
Food and Drink Federation:
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| abim | Association of Bakery Ingredient Manufacturers
|
| ACFM | Association of Cereal Food Manufacturers
|
| AMPM | Association of Malt Product Manufacturers
|
| BCA | British Coffee Association
|
| BCCCA | Biscuit, Cake, Chocolate and Confectionery Association
|
| BOBMA | British Oats & Barley Millers Association
|
| CFA | Chilled Food Association
|
| CIMA | Cereal Ingredient Manufacturers'
|
| FA | Food Association |
| FOB | Federation of Bakers |
| FPA | Food Processors' Association
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| GPA | General Products Association
|
| IDFA | Infant and Dietetic Foods Association
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| MSA | Margarine and Spreads Association
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| MG | Meat Group |
| NABIM | National Association of British and Irish Millers
|
| NACM | National Association of Cider Makers
|
| OHG | Out of Home Group |
| OFDMLG | Organic Food and Drink Manufacturers Liaison Group
|
| PFMA | Pet Food Manufacturers' Association
|
| SB | Sugar Bureau |
| SG | Seafood Group |
| SIBA | Society of Independent Brewers
|
| SMA | Salt Manufacturers' Association
|
| SNACMA | Snack, Nut and Crisp Manufacturers' Association
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| SPA | Soya Protein Association
|
| SSA | Seasoning and Spice Association
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| UKAFFP | UK Association of Frozen Food Producers
|
| UKAMBY | UK Association of Manufacturers of Bakers' Yeast
|
| UKTA | UK Tea Association |
| VG | Vegetarian (Meat Free) Group
|
13
Regulation (EC) 1830/2003-Traceability and Labelling of GMOs and
Regulation (EC) 1829/2003 on Genetically Modified (GM) Food and
Feed. Back
14
Crops on Trial AEBC, September 2001. Back
15
GM Crops? Co-existence and Liability, AEBC, November 2003. Back
16
Commission Recommendation of 23 July 2003 on guidelines for the
development of national strategies and best practices to ensure
the co-existence of genetically modified crops with conventional
and organic farming-Brussels, 23 July 2003, C (2003). Back
17
Recommendation 6, GM Crops? Co-existence and Liability, AEBC,
November 2003. Back
18
Recommendation 9, ibid. Back
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