Select Committee on European Communities Second Report - Written Evidence

Memorandum by Unilever plc


  1. Unilever is one of the world's largest companies operating in the market for fast moving consumer goods. We manufacture and sell branded products in selected foods, home and personal care categories. We have operations in over 90 countries across the world and sell in over 160. We compete for the favour of the consumer through the long-term appeal of our brands. Their trust in our products relies on their confidence in their performance and quality, and of course their safety in use.

  2. Unilever supports the responsible use of modern biotechnology, including genetic modification, within the framework of effective regulatory control and the provision of information about its use. The use of this technology to improve food crops and food products can bring important benefits to society. Individual applications should be judged on their merits. However, these important scientific and industrial developments do raise issues. Unilever advocates effective, clear and properly enforced regulations. We believe that once society has agreed the ground rules setting out the conditions for the application of modern biotechnology, they should be adhered to strictly.

  3. As a leading consumer goods company, Unilever is in tune with consumers' needs to have access to information on product contents so that they can make informed choices. An essential component in maintaining public confidence in this technology is the existence of an effective regulatory framework in which consumers can trust.



  4. The UK was a pioneer in the development and implementation of regulations covering biotechnology, in order to protect workers, public health and the environment. Research involving genetic techniques in laboratories and contained facilities has a history of safe use in the UK, stretching back over the last twenty years. This is due in no small part to the co-operation and contact between scientists and public authorities which has been instrumental in developing appropriate science-based legislation.

  5. The UK Advisory Committee on Genetic Modification (and its predecessor, the Genetic Manipulation Advisory Committee) is widely respected for its expertise and competence. Composed of experts from academia and industry, together with public interest representatives, it is a model that has been adopted by many other countries.

  6. The European Commission's first legislative initiative in the biotechnology field was at the end of 1978, in order to standardise systems. However, it was not until 1990 that Directives were published which protected workers (90/679) and regulated the contained use of genetically modified organisms (90/219) and their deliberate release (90/220). Unfortunately, this legislation was already out-of-date before it was implemented. In the words of the House of Lords Select Committee on Science and Technology: "In framing the Directives . . . the European Commission took an excessively precautionary line based on a view of the technology which, in terms of scientific knowledge, was already obsolescent when the Directives were being prepared in the late 1980s".

  7. Complications were caused by the UK adopting EU Directive 90/219 on the contained use of genetically modified micro-organisms in the Genetically Modified Organisms (Contained Use) Regulation 1992. This legislation was never intended for plant materials: contrary to the Commission's intentions for the Directive, this inclusion created an "uneven" playing field in Europe, producing uncertainties and delays in research programmes.

  8. Harmonisation of legislation and its implementation across the European Union, and internationally, is essential for public confidence. See paragraphs 13 and 14 below.


  9. As with research, releases into the environment were anticipated by the UK Government and appropriate controls put in place at an early stage. As scientific knowledge and experience has grown these have been successfully incorporated into the statutory risk-assessment procedures. Unilever has had limited experience with release of GMOs into the environment because of the company's limited agricultural research base. The approvals for research releases were executed by the UK's Advisory Committee on Releases (ACRE) in a timely and effective manner.

  10. In 1990, the European Commission attempted to create a level playing field for industry with Directive 90/220. However, this created similar problems to Directive 90/219. It has failed to create a level playing field, implementation in member states has been patchy and the delays considerable. This, combined with a continuing difference in perspectives at European level, has had a negative impact on academic research, business and public perception alike.

Novel Foods and their Labelling

  11. Unilever recognised the need and supported the proposal for a Novel Food Regulation (NFR) in Europe. The Regulation was finally agreed in May 1997 after nine years. During the discussion period consumer concern has increased because of the perceived lack of control. Although the NFR constitutes a political compromise it is an important step in allowing the developments of modern technology into the market place in a controlled manner.

  12. With regard to labelling, the scientific principles articulated in early drafts of the NFR and embodied in the guidelines and those produced by the OECD and FAO have led to a compromise recommendation on labelling in the EU. This, it is to be hoped, will meet the needs of consumers and food manufacturers, such as Unilever, on the provision of information and choice and on a practical and meaningful approach to labelling.


  13. As global trade increases, business will increasingly be faced with the problems that flow from a lack of harmonisation of regulations relating to the use of genetic modification in agriculture. This has been highlighted recently by the continuing divergence of US and EU regulatory procedures as a result of different approaches to assessments of risk. Different regulatory regimes also risk undermining public confidence.

  14. Clearly, there is a role for both national regulations and international agreements, as well as industry-wide codes, as the modern biotechnology industry develops. Unilever recognises the value of shared international standards and approaches, both for public confidence and business competitiveness.


  15. Different regulatory regimes in different countries inevitably impact on competitiveness. For example, if there is a 90-day period for processing release applications in Europe, compared with 30 days in the US, European companies inevitably face a competitive disadvantage vis-a-vis their American counterparts.

  16. At the same time, since industrial competitiveness is increasingly built on innovation, and since innovation is as dependent on consumer trust as on technological developments, the effects of non-regulation or inappropriate regulation can have a negative impact on consumer confidence.

  17. The challenge is to develop regulatory frameworks which are workable, able to accommodate evolving best practice, as international as possible, and which command consumer confidence. This is an ongoing challenge, and companies and consumers have a shared interest in seeing this kind of regulatory framework properly developed.

11 June 1998

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