Select Committee on European Communities Minutes of Evidence

Memorandum by Iceland Group plc


  Iceland Frozen Foods Plc is 28 years old, comprises primarily a retail operation with 770 stores, 20,000 staff and a turnover of £1.7 billion. Iceland is a frozen food specialist but also offers a wide range of both chilled and ambient products.


  Genetic modification clearly can provide significant benefits for society but also has associated risks and raises a wide range of issues for consumers.

  We believe that the introduction of GM commodity crops is a significant departure from traditional breeding methods. We share the concerns raised by several independent scientists regarding the way in which these products are being brought to market.

  We believe customers need to be informed as to what is going on and need to be given a choice as to whether or not they buy GM products. As a result we have been raising the profile of this issue.

  We believe that many of the advisory bodies at EU and UK level had a strong bias towards bringing this technology to market. We have been working to ensure that consumer concerns are addressed within the process. Progress is being made but there is still some way to go.


  As a food retailer we have had to spend a great deal of effort of late ensuring that regulations are effective, clear, practical to implement, allow innovation and minimise the disruption and cost to the trade.

  The difficulty in achieving consistent regulation across the EU often leads to prescriptive regulations that are inflexible and difficult to apply in parts of the community. The complexity and wide range of food operations lead enforcement agencies generally to prefer end point testing and prescriptive checklists. Operators on the other hand generally prefer risk assessment and in-process controls. This latter approach provides the flexibility to develop new solutions to the issues with compliance that face their specific operation.

  We believe that often the best solutions arise from co-operative ventures that involve all interested parties at an early stage.

(a) Introduction of GM Commodity Crops

  Unfortunately with the introduction of genetically modified (GM) commodity crops the biotech industry and those responsible for legislation were unwilling to listen to, or act on, the concerns raised by retailers and customers within the UK and across Europe.

  We believe this is because there was a general feeling that the profit to be made was so great that no country could afford to be left behind and no-one believed there would be any point in standing up to the might of the large conglomerates that operate in this sector. As a result Governments have invested heavily in research in this area and are in fact very closely aligned to the biotech industry. The significance of this industry is such that major world trading markets believe that they equally cannot get behind in the race to exploit the technology.

(b) Independence of Advisers

  Many of the scientists and academics that would historically be relied on to provide independent advice on behalf of the community now have strong dependencies on industry. As a result we believe that many of the advisory bodies at EU and UK level have a strong bias towards bringing this technology to market. When deliberating issues it is within the context that the approval of these products must not be delayed rather than proceeding with due caution.

(c) Compartmentalisation of the Review Procedure

  As with this Sub-Committee particular aspects of the approval process tend to be dealt with separately. However in order to decide whether or not these products should come to market the benefits must be balanced by consideration of all the accumulative impacts. Hence the fact that a product may pass an environmental assessment in isolation should not remove the need for the environmental impact that does exist to be considered in the final equation.

(d) Products On The Market Before The Controls

  Perhaps with this background we should not be surprised that at both EU and UK level the authorities have failed the consumer. We should all be embarrassed that we have the new GM commodity crops on the market before we have appropriate controls in place to allay the fears of the consumer.

  We believe that the biotech industry only has itself to blame for the delays in their new products being approved. They could have been proactive in determining the appropriate practical controls with consumers' interests in mind rather than lobbying for the authorities to consider the possible impact of trading relationships and denying the concerns of the consumer.

(a) Consumer Link with BSE

  We have been amazed that it has taken so long to recognise that the European consumer might be a little concerned about scientists playing with their food so soon after the BSE scare. The two issues may have no connection technically but that is not the view of the consumer. When GM soya was introduced we felt that the industry had something to hide because of their negative attitude to the wishes of the UK retail trade.

  As with the BSE situation food operators must be able to rely on the advice provided by the competent authority. After the BSE scare we are now understandably not as confident in these authorities.


(a) Agreed Timescales for Reviews

  The provision of agreed periods for reviews to be completed should make the process more efficient. The timescales act as a good guide but in practice we feel that some of the timescales may be difficult to comply with. Whether the system works in practice will depend on the pressure on the committee to approve the product or to throw the application back when there are grey areas, and further expert advice is required to make the decision. At present this may not be an issue but if the number of applications increases as expected difficulties may arise.

(b) Transparency and Consumer Involvement

  The proposed greater transparency of the decision making process and the involvement of consumer groups is welcomed. Effective debate with consumer groups across Europe may be difficult to facilitate in the timescales suggested (30 days).

(c) Segregation—Cross Pollination—Cross Contamination

  Iceland has achieved segregation of GM Ingredients and no Iceland Own Label products are currently made with GM Ingredients.

  If we are going to be able to maintain the segregation of a non-GM alternative we must limit the risks from cross pollination. We understand that in the US some states have introduced controls that prevent the growing of crops which may increase the likelihood of pesticides resistance being gained. In the UK we are concerned that if GM oilseed rape is planted this will quickly contaminate Non-GM crops. We understand that oilseed rape cross pollination can occur over a substantial range. At present trial plots are planted at least 50 metres from the nearest farmer with a six metres gap round the outside of the crop. This may not be sufficient. Once crops are approved similar controls must be implemented if Non-GM crops are not to be contaminated. Regional segregation for oilseed rape should be mandatory if practical farm segregation distances cannot be found. In addition haulage controls for seed would need to be introduced to prevent the current spread of seed along haulage routes.

  We believe that farmers that wish to maintain a Non-GM crop should have an ability to claim compensation if their crop is contaminated by a neighbour's GM crop or they incur greater costs due to having to use herbicides to remove GM weeds.

(d) Fixed Approval Period

  Once products are released into the environment the DNA structure continues to evolve. Materials that were deemed to present no risk to consumers or the environment may create problems due to the presence of foreign DNA. The environmental impact of GM crops may also take some time before it becomes evident. We thus support the proposal for approvals to be given for a limited period. We believe that the criteria for a continuation need to be well defined to ensure a thorough but practical review is completed of all key areas. We would like to see more details as to what exactly is required to pass such a review.

(e) Monitoring

  The key criteria for monitoring the implementation of GM crops should be specified as part of the amendment or within an agreed period. At present this is to be decided on a case by case basis when appropriate. This is too vague. Food safety and environmental impact assessments should be completed. Even so monitoring is difficult unless segregation is maintained.

(f) Substantial Equivalence—Gene Stacking

  We are still concerned at the use of "substantial equivalence" and believe that the failure to require a full DNA profile will allow foreign proteins to be missed. Allergy testing must be completed on humans and be based on the product as intended to be placed on the market rather than, for example, the DNA to be inserted or the intended GM protein.

  With gene stacking providing several traits in one crop we believe approval should again be sought. At present it is expected that once a genetic modification is approved additional changes still maintain the substantial equivalence criteria.

(g) Terminator Genes

  We are also concerned about the approval of "terminator" traits which prevent the farmer from retaining seed for the following year. We understand the need to protect intellectual property rights but believe that this trait may be used to exploit farmers.


(a) Labelling

  We support the changes that have been made to the Novel Foods regulations on 26 May. The labelling changes are more practical for those that wish to sell GM products.

  As ever the period for implementation is inadequate even at 90 days, when considering the number of products affected. For long life products such as grocery and frozen products it is not unusual to print packaging once per year. We assume that as usual enforcement officers will be asked to take a pragmatic approach.

  We are still concerned that some ingredients derived from GM crops will not be identified to consumers, such as oil. We believe that consumer pressure will continue to build and this will be amended eventually. We have already removed all GM soya derivatives from our Own Label range whether or not the DNA is present.

  We are concerned that lecithin may either be treated as an additive, or if the appropriate purity criteria are not met, lecithin would be placed on the ingredient exemption list for labelling. Lecithin clearly contains GM DNA.

(b) Threshold Values

  The introduction of a threshold for Non-GM products is essential if customers are to be given a Non-GM alternative. Having established ID preserved materials we are building a picture of the ability of our suppliers to minimise co-mingling.


  It is pleasing to see that some of the biotech companies are now acknowledging that consumers should be given the choice of Non-GM alternatives and that segregation is possible. We are looking forward to working with anyone who genuinely has these aims. We are confident that we will be able to re-establish trade with our traditional sources as well as supporting those that have helped Iceland make this a possibility.

4 June 1998

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