Select Committee on European Communities Minutes of Evidence



Presented to NFU Council

March 1998



  The potential benefits of the application of biotechnology to UK agriculture and horticulture are outlined. Some concerns about the technology are given, and suggestions for future action are made.


  Biotechnology provides additional opportunities to adapt to the pressure for change. It cannot solve all our problems, but can play an important and innovative role in maintaining the competitiveness of UK agriculture and horticulture. Biotechnological innovations have the potential to make farming and growing more effective by maximising potential yields, improving the consistency, nutritional content and quality of crops, and by reducing pesticide and herbicide use. Other benefits relate to the development of perennial crops, crops that can fix nitrogen, and plants that are more resistant to disease, cold, drought, salinity, and higher temperatures. Manipulation of features of plants that control flowering, germination, photoperiodism, growth, and shade avoidance, should also give benefits.

  Genetic modifications that are sensitive to local farming conditions may also provide a means of increasing the reliability of food production in underdeveloped and developing countries in response to an increasing world population. Bioremediation of polluted soils, and similar developments could also prove to be beneficial. It should be emphasised that the modifications required to obtain the benefits referred to in this paragraph would be very difficult, if not impossible, to achieve by conventional breeding methods.

  In animals the use of genetic markers for breeding purposes is likely to improve animal welfare. This will be by breeding animals that are more resistant to disease and parasites, and have improved reproductive efficiency. Further potential benefits include parentage verification, and identification of traits for high feed conversion efficiency and improved carcass quality and meat purity. The use of transgenic animals for the production of pharmaceutical products and possibly as a source of organs for humans (xenotransplantation) are other benefits.


  The recognised risks of the introduction of biotechnology into farming are considered by most observers to be low. However, there are some concerns. The first relates to the use of antibiotic resistant marker genes in genetically modified crops. The likelihood of gene expression is determined by the type of DNA promoter sequence that is associated with the marker gene. It is possible that specific antibiotic resistance could be transferred to livestock and to humans. While this risk is considered to be very small the NFU has a policy that discourages the use of such genes. They are unacceptable to many consumers and alternative marker genes are available.

  Other concerns are environmental and relate to the integrity of the food chain. For example, there is the possibility that resistance to a variety of herbicides could become transferred to and aggregated into a weed species so that it becomes difficult to control. There is also the possibility that the use of herbicide tolerant crops, and ones that contain a built-in pesticide, could reduce the number of insects so that predatory species, ranging from other insects to birds and mammals, may be reduced in numbers. Resistance to in-built pesticides may also develop in insects, so reducing the availability of effective pesticides. Because of these environmental uncertainties the NFU recommends that a 10 year monitoring period be instituted when a specific genetically modified crop is commercially grown in the UK for the first time. The results of the monitoring programme should be in the public domain, and should form the basis for continued registration of the genetically modified crop.

  Animal welfare concerns have centred on the rapid development of reproductive manipulation methods. For example, the excessive size of animals at birth produced by in vitro reproductive methods, including cloning, certainly has negative animal welfare implications. A further welfare concern with cloning is the risk related to the potential vertical transmission of disease from donor to cloned offspring and surrogate mother (e.g., bovine viral diarrhoea).


  The NFU has a policy that genetically modified crops should be segregated when grown in the UK so that traceability and appropriate labelling is possible. However, experience gained in segregating the Canadian canola crop in 1996, and detailed consideration of the practicalities of such practices suggest that complete segregation is difficult to achieve and can be costly. Labelling would enable consumers to choose whether or not they wish to eat a food that contains material derived from genetically modified crops. Codes of practice, developed by the NFU, in association with the British Society of Plant Breeders and the United Kingdom Agricultural Supply Trade Association, aim to ensure that GM crops grown in the UK are segregated throughout the food chain so that they can be appropriately labelled to allow consumer choice.


  The importation of unsegregated genetically modified crops such as soya and maize have provided UK consumers with little choice. While there is no simple answer to this problem, the Institute of Grocery Distribution, supported by the NFU and other groups, has produced voluntary labelling guidelines for foods derived from genetically modified constituents. These were introduced for genetically modified soya and maize in 1998. It is likely that all foods which contain such products will have to be labelled in the future. However, labelling is unlikely to be required for foods that do not contain the genetic material (DNA) in its native state (e.g., oils, sugar, etc.). Because of discrepancies between the United States and Europe it has become obvious that internationally agreed regulations to control the introduction of biotechnological innovations into farming are urgently required. The NFU fully supports attempts to harmonise regulations at European and international levels.


  The NFU is sensitive to the concerns of undeveloped and developing countries on the possible exploitation by multinational companies of products derived from their naturally occurring flora and fauna. The NFU supports attempts to develop and harmonise international legislation in this area.

  Following many years of negotiation a revised draft of the EC Directive for the Legal Protection of Biotechnological Inventions, which aims to harmonise intellectual property laws in the EU member states, appears likely to become law in the near future. The NFU has been one of the groups who have been instrumental in ensuring that clauses are included in the Directive that should protect farmer's right with regard to genetically modified crops and livestock. These rights would include the right to "use the product of his harvest for reproduction or propagation by him on his own farm", and "implies authorization of the farmer to use the protected livestock for an agricultural purpose. This includes the sale for the purposes of agricultural activities".


  The NFU is committed to providing accurate up-to-date information on biotechnology and farm use. In addition practical instruction may also be required. The NFU also believes that information on biotechnology should be freely available to the public, and is encouraged by the variety and number of sources of information that are now available. These range from supermarket leaflets to detailed explanatory booklets. These should allow the public to develop their attitudes to biotechnology based on science rather than supposition.


  The NFU is committed to the development of sound agriculture practices. The NFU believes that the responsible introduction of genetically modified crops and livestock will form part of this farming equation in the future.


  This report examines the potential benefits of the application of biotechnology to British agriculture, horticulture and associated processing and manufacturing industries. It identifies a number of concerns and makes suggestions for future action.


  In the broadest sense biotechnology is the use of biological processes in industry. Biotechnology plays a part in the making of cheese, bread, wine and beer which all utilise natural biological processes. However, the term "biotechnology" is now more commonly applied to modern technologies such as genetic modification, genetic fingerprinting and antibody technology.

  Biotechnology covers such a broad spectrum of techniques and applications that it cannot be accepted or rejected as a whole. Different applications offer different opportunities and raise different concerns. This must be recognised and an assessment made case by case regarding benefits, risks and ethical concerns.

  Within this document the term "biotechnology" is restricted to the range of techniques and applications that can be used in the production and manufacture of animal and crop based products. The science underlying biotechnology is advancing rapidly. We can therefore only examine the technology available today. No doubt future applications will offer further benefits and present different concerns.


  UK agriculture and horticulture are part of a food industry which is adapting to the pressures of change from an expanding European Union, CAP reform, GATT and environmental pressures, as well as responding to changing consumer concerns and market requirements. In order to survive and succeed UK farmers and growers must continue to be competitive primary suppliers to the food chain. They must continue to minimise costs, improve productivity, enhance quality and develop new market opportunities while maintaining high animal husbandry and welfare standards, and helping to protect the environment.

  Biotechnology provides further opportunities to adapt to the pressures for change. It cannot be the solution to all our problems, but can play an important and innovative role in maintaining the competitiveness of UK agriculture and horticulture.

  Biotechnology was identified as one of the most promising technologies for sustainable development in the Commission of European Communities' 1993 white paper "Growth, Competitiveness, Employment: The Challenges and Ways Forward into the 21st century". It was also pinpointed as a key area for future development in the Governments' Office of Science and Technology document entitled "Progress through Partnership", which was the report from the Steering Group of the Technology Foresight Programme 1995. One of the key recommendations in that report was the need to "Exploit the growing capabilities of biotechnology to modify the properties of agricultural products." The UK has the strongest scientific and industrial base in the EU in biotechnology and so there is considerable scope for development in that area.


  The NFU believes that biotechnology may help improve the efficiency of production, develop new market opportunities, enhance the marketability of many existing products and contribute to better standards of animal health and welfare. We also believe biotechnology is capable of delivering environmental benefits.

4.1 Efficiency of Production

  Biotechnology has the potential to improve the efficiency of production. Genetic mapping and marker-assisted breeding programmes are already being used to develop, through conventional breeding processes, livestock and crop varieties with improved performance. The development of biotechnological kits for rapid diagnosis of disease will allow more targeted disease and pest control. Genetically modified crop varieties which are resistant to pests or a specific herbicide are already in the marketplace. These can be used as part of integrated crop management systems and can reduce the need for pesticides and herbicides. Other developments that could lead to more efficient farming are the development of perennial crops that would be sown once and harvested each year. This would lead to a reduction in labour costs, and would have environmental benefits by reducing soil erosion and encouraging better water retention. Crops that were modified to include root nodules that could fix atmospheric nitrogen would greatly reduce the need for the application of nitrogen fertiliser.

  The use of these new technologies could result in fewer losses from disease, reduced expenditure on agrochemicals and veterinary medicines, and increased marketable yields.

4.2 New Market Opportunities

  Biotechnology can be used to develop new crops and extend uses for existing crops offering wider market opportunities for the farmer and grower. For example, oilseed rape plants from which biodegradable plastics may be produced have been bred using genetic modification. These plants are now being further developed and may provide a cheaper and renewable source of plastic. The development of livestock that produce milk with reduced allergenic properties is another possibility. The development of crops that have a greater climatic range may allow the growing of plants in the UK that will produce products to supplant those presently imported.

  Other potential market opportunities include biofuels from modified fast growing trees, new varieties of ornamental, industrial oils, cosmetics, paper production, pharmaceuticals and novel foods.

  It is likely that this technology will initially be used to develop a range of niche markets for a small number of farmers and growers.

4.3 Marketability of Existing Products

  Biotechnology can be used to modify food to meet consumer needs more closely. Market research indicates that better eating quality, reduced allergenic properties, improved flavour, enhanced safety, superior nutritional content, and environmental gain, are of increasing importance. In addition, food manufacturers and retailers are seeking ways to add value, differentiate their products, reduce waste and satisfy the ever-increasing demand for convenience foods.

  The application of biotechnology has the potential to help meet these changing consumer needs—not least by offering a wider choice of better value for money products which are attractive and safe. Improvements can be made to fresh produce and to the raw materials used in the manufacture of processed foods. The introduction of more desirable food processing characteristics could mean less processing and less waste. Biotechnology can also be used to add value beyond the farm-gate, for example, through the use of food processing enzymes to enhance flavour. Through using this technology to meet consumer needs, benefits should accrue to primary producers, food processors and manufacturers and to the retail sector.

  Plant and animal breeders as well as food processors and manufacturers are already striving to meet consumer needs using conventional methods. Biotechnology can help to achieve their objectives. Below are two examples:

  Genetic modification in potatoes could:

    —  Increase availability of UK varieties by extending growing seasons through introducing stress tolerance characters.

    —  Improve flavour and mash texture through modification of starch and sugar content.

    —  Reduce the water content in potatoes to limit the fat retained in crisps and chips and meet the processors' needs more closely.

    —  Extend shelf life by suppressing sprouting and reducing rots.

    —  Reduce chemical residues by introducing herbicide tolerance, disease and pest resistance traits.

  In pigs, biotechnology could:

    —  Help improve animal health through the development of new vaccines and diagnostic kits for rapid disease diagnosis.

    —  Give the potential to provide disease and parasite resistant animals and so improve animal welfare.

    —  Improve flavour, texture and fat content and distribution through the application of marker-assisted breeding technologies.

    —  Improve the efficiency of food surveillance through the development of rapid tests for bacterial contamination or antibiotic residues.

    —  Include opportunities for xenotransplantation.

4.4 Animal Health and Welfare

  Biotechnology could make a major contribution to animal health through the development of new vaccines and diagnostic systems. Genetic mapping and marker-assisted breeding could also be used to help select for disease and parasite resistance characters.

  Vaccination is a central strategy for disease control. Genetic modification can be used to develop new, more effective vaccines. These could be particularly important for viral infections which have proved difficult to control through conventional vaccines. The use of such vaccines in human medicine is already well accepted.

  Diagnostic systems based on antibodies will provide rapid and accurate disease diagnoses. Such systems are highly sensitive and will detect very low levels of a pathogen. They are likely to prove a valuable veterinary tool. While not only of welfare interest, diagnostic systems could be used to improve parental verification and provide other genetic information.

4.5 Environmental Benefits

  Applications of biotechnology could help reduce our dependence on chemical inputs. For instance, in-built pest resistance and built-in herbicide tolerance, developed through genetic modification, are already being used with genetically modified maize and soya as part of integrated crop management systems in North America.

  The use of biotechnologically produced diagnostic kits which are accurate, sensitive and reliable will allow more targeted pest control. Agrochemicals can then be applied only when and where needed, reducing the total amount used.

  "Cleaner" raw materials for manufacturing could reduce the amount of harmful chemicals released into the environment. For example, the oil profiles of oilseed crops are being modified to provide industrial feedstocks such as adipic acid for nylon production and lauric acid for detergents. This resource is renewable and potentially more environmentally friendly (or "cleaner") than the conventional petrochemical feedstock.

  Biotechnology is already used for cleaning up waste and contamination. Techniques used for bioremediation are likely to be further developed to allow cleaning up of soil contaminated with pesticides, heavy metals, or other pollutants. This could help "repair" environmental damage.

4.6 The Developing World

  Biotechnology is an affordable technology and if applied sensitively is capable of delivering significant benefits to countries with less developed agricultural systems. For example, the introduction of stress tolerance characteristics will improve the reliability of yields by helping crops withstand extreme conditions, new disease and pest resistance traits will help reduce crop losses, and genetic improvement of local crops and livestock can be accelerated through the use of genetic maps and marker-assisted breeding programmes.


  The contribution of biotechnology to the competitiveness of UK agriculture, and associated industries, could be limited by the lack of harmonisation of regulatory controls between Britain, Europe and the rest of the world.

5.1 Safety Controls

  The first priority of the regulatory framework must be to guarantee protection of the consumer and the environment, but should not be an unnecessary burden on industry, nor discourage beneficial development. Government must ensure that a competitive environment exists.

  Differences currently exist in the regulations concerning the approval of applications of biotechnology. The process for safety approval of foods derived from genetic modification in the UK and the EU differs from that in the USA. There is also variation in the regulatory control of releasing genetically modified organisms into the environment. Lack of harmonisation will continue to impede the development of biotechnological industries both within the UK and internationally. The NFU therefore believes that co-ordination of regulatory controls is essential to maximise regulatory efficiency.

  Action is already being taken to develop and co-ordinate international policy in this area by the United Nations Environmental Programme, the World Health Organisation (WHO), the United Nations Food and Agriculture Organisation (FAO), the Organisation for Economic Co-operation and Development, and Codex Alimentarius.

5.2 Patenting

  The NFU is sensitive to the concerns of underdeveloped and developing countries on the possible exploitation by multinational companies of products derived from their naturally occurring flora and fauna. The NFU supports attempts to develop international legislation in this area.

  Following many years of negotiations, and the failure of the 1995 draft EC Directive for the Legal Protection of Biotechnological Inventions because of ethical objections, a new version of the legislation is again under consideration. The aim of the Directive is to harmonise the intellectual property laws of member states. The Directive was revised and again presented to the European Commission and Parliament in 1997 and has still not been approved. It now includes satisfactory clauses which give derogations for farm use, and should allow farmers, and the companies producing GM products, to benefit from them.

  The NFU considers that the absence of a harmonising directive hampers the competitiveness of British industry and urges the EC to pass satisfactory and appropriate legislation as soon as is practical.


  Whilst biotechnology is already highly regulated, there are a number of concerns: the likely impact on the environment; the practical problems which face farmers, growers and the food industry; the concentration of power and control of biotechnological applications on the input side of agriculture in the hands of a few multinational agri-food companies; and, the public attitudes toward this new science.

6.1 Changes to the Natural Environment

  Those intending to conduct an experimental release or to market a genetically modified organism (GMO) must obtain consent from the Secretary of State for the Environment, who is advised by the Advisory Committee on Releases into the Environment (ACRE)[2]. In order for consent to be granted safety and risk is evaluated.

  The NFU believes that the regulatory controls do not take sufficient account of all the potential environmental post-release hazards and their implications when genetically modified plants are grown on a commercial scale. There is the possibility that genetically modified crop plants will spread into the natural environment, or that gene transfer into wild species by cross pollination will occur. This is considered genetic pollution by some environmentalists and could lead to an erosion of genetic diversity if "foreign" genes replace those already present in native plants. Field trials indicate that the likelihood of a genetically modified crop spreading into a natural environment is no different from that of the conventional crop from which it is derived. Other field trials show that cross pollination is inevitable but that the significance of it depends on the crop species being used, and the types of weed or wild plants that naturally occur in the environment.

  Other concerns relate to the effects that herbicide tolerant genetically modified (GM) crops, or GM crops that contain a natural pesticide, will have on the environment. For example, a more complete destruction of weed species at field margins and hedgerow bottoms could reduce the habitat availability for insects. Also, if herbicide resistant volunteers become a problem in following crops, a less acceptable herbicide may have to be used to control them. Both of these results could cause a reduction in the numbers of birds and other predators that rely on the weed and hedgerow environment and the animals that live therein. In a similar manner, a more effective method of killing systemically feeding insect pests will reduce the availability of food for predators. A balance needs to be struck between the legitimate desire of farmers to provide a livelihood for themselves and their families and the continuing need to maintain a sustainable environment for future generations.

   More worrying are studies that suggest that some GM pesticide-containing crops may affect the longevity and fecundity of predator insects, such as ladybirds, or may affect the behaviour of pollinators, such as bees. Also, the attainment of resistance by pest insects to the Bt toxins may ultimately reduce the usefulness of such GM crops. Other concerns relate to the possible transfer of genes between plant viruses and their hosts. There is relatively little information on the relationships of plant viruses and the field environment, so if such transfers do occur the significance of them cannot yet be accurately forecast. In general it can be said that scientists do not have a complete understanding of natural ecosystems. It is therefore impossible to predict accurately the effects of large scale release of genetically modified organisms.

  The NFU is seeking further clarification about what might be considered "harmful" to the environment, or how any "harm" will be observed and quantified. Moreover, whose responsibility is it to ensure that "harm" does not result, and on whom does legal liability fall if it should?

  The NFU is concerned that there is currently no requirement for monitoring environmental change after consent to market has been granted. However, it is recognised that widespread monitoring would be very difficult and costly. It is also acknowledged that a condition of consent to market a GMO requires the applicant to inform the Secretary of State of any environmental problems that subsequently occur. Nevertheless, the NFU believes that this requirement is not adequate to ensure that any environmental change will be observed and acted upon. Governmental should therefore be proactive in setting up a process of post-release monitoring of newly approved commercial growing of GM plants.

  The NFU think that the monitoring programme should be independent of the company that is expected to profit from it, should be paid for by government, and should either be directed by government, or under government contract. We believe that this post-release monitoring programme should last for a 10 year period and that the review that follows should form the basis for the continued licensing of the GM crop. The report and data that arise form the monitoring programme should be in the public domain. Any severe environmental changes that arise within the monitoring period could lead to immediate withdrawal of approval. Prompt action would then have to be taken to limit environmental damage if such an event occurred. The NFU has noted that suggested changes to EC Directive 90/220 on deliberate releases of genetically modified organisms into the environment has included a provision for a mandatory monitoring of products after their placing on the market, which will be linked to a consent granted for a fixed time period of seven years. These proposals generally correspond with NFU proposals in this area.

  The NFU believes farmers will continue to have an important role to play in observing any changes in the agricultural environment. A clear regulatory framework would help them properly to fulfil this role.

  Further ecological research should therefore be a priority, in order to improve our understanding of natural ecosystems and the implications of releasing novel organisms into them.

6.2 Agricultural Controls

  During the approval process ACRE considers the environmental hazards of the genetically modified organisms submitted to it. ACRE evaluates the likelihood of a hazardous event occurring and its possible impact on the environment. However, the NFU continues to recognise that ACRE's remit is limited and we believe that some wider issues should be formally considered by regulators and advisory committees with appropriate expertise. One example of such a problem would be that of the development of herbicide tolerant plants, and whether the use of such plants is a good strategy for weed control both environmentally and agronomically in the long term. An integrated system, applying principles similar to those applied to agrochemical approvals, might be appropriate, and deserves further consideration.

  Under current regulatory controls, responsibility for the sensible use of the technology falls to the farmer, whose decision making is influenced by numerous socio/economic and environmental factors. Furthermore, it is important not to under-estimate the influence of the commercial companies supplying production inputs to the farmer, nor the specified requirements of the processors and manufacturers who will purchase the end product. In order to ensure that the technology is used responsibly it is essential that explanatory information is provided to the farmer. Information is necessary to explain how to use the product and to identify potential risks.

  In view of this the NFU, in association with the British Society of Plant Breeders and the United Kingdom Agricultural Supply Trade Association, in 1997 produced codes of practice that relate to the provision of information for genetically modified crops. The main features of the codes are the requirement for a clear identifier that a seed is genetically modified to be placed on all seed packets/sacks. This should be supplemented by more detailed information supplied in a leaflet that accompanies the seed, sales literature, and the National Institute of Agricultural Botany recommended lists. The explanatory information should provide details of the specific genetic modification, and should give details of the agronomy of the GM plant. Farmer training schemes may also be necessary. When the crop is harvested the produce should be segregated from that of non-GM crops. Each GM crop consignment should be accompanied by a post-harvest declaration, which should include the name of the variety. The provision of such information should be maintained during subsequent transportation. These codes of practice will require detailed record keeping both on and off farm, which will form the basis of traceability of the crop.

6.3 Practical Considerations

  The NFU has examined the practical problems which the farmer and grower may face as a result of growing genetically modified crops. For example:

    —  Herbicide tolerant volunteers;

    —  Reduced efficacy of agrochemicals;

    —  Cross contamination between GMO and conventional crops.

  Herbicide tolerant crop varieties will lead to herbicide tolerant volunteers in future crops on that land. Volunteer oilseed rape in arable crops is already posing an increasing problem to UK farmers. Herbicide tolerance may compound this problem and increasingly limit crop rotation and management systems.

  Through genetic modification, herbicide tolerance is being incorporated into many crop species, such as soya, maize, oilseed rape, and sugar beet. Widespread use of these herbicide tolerant crops might result in over reliance on one herbicide, or a few such herbicides. This will increase the selective pressures on the weeds which may accelerate the development of resistance to the herbicide.

  There is also the possibility that a gene conferring herbicide tolerance could be transferred to weed species by natural cross breeding. Tolerance to the herbicide might than spread through the weed population. The spectrum of weeds controlled by a particular herbicide would be reduced, limiting the efficacy of that agrochemical. A more severe complication of this might be that of gene "stacking", where the genes for tolerance to several different herbicides become concentrated in one weed species. Obviously, other herbicides would be available to control volunteers and weeds, but these may be less "safe" and increase the complexity of weed control.

  Oilseed rape volunteers in a future crop of a different variety will result in cross-contamination, affecting the marketability of the crop. Although this problem is not new, it is likely to be increasingly important as new types of "designer" oilseed rape, with specific oil profiles for industrial use, become commercially available. Controlling such volunteers may be difficult. Methods of zoning[3] or isolation may be necessary. These are unpopular, difficult to implement and will reduce the flexibility of land use.

  Another concern was highlighted by the decision of the US Environmental Protection Agency (EPA) in 1998 to reduce the level of the herbicide bromoxynil to which humans can be exposed. The EPA rules state that human exposure must be 100x less than the lowest concentration shown to cause birth defects and cancer in laboratory mice. A bromoxynil tolerant GM cotton plant passed this test and in 1997 170,000 hectares of it were planted in the USA. The EPA changed the acceptable levels to a tenth of that previously used because pregnant women and infants are considered to be at extra risk. Residues of bromoxynil on fields planted with the GM cotton have been said to exceed this lower threshold. Assuming that the reduced levels are upheld by the EPA Scientific Advisory Committee the GM cotton may have to be withdrawn from the market.

  The NFU believes that advisory panels should take account of these wider implications when granting consent to market.

6.4 Animal Welfare

  The NFU acknowledges that genetic modification of animals raises greater moral and ethical concerns than genetic modification of plants or micro-organisms.

  There are currently four main areas of research where the use of genetic modification of animals is being investigated. These are disease and parasite resistance, growth promotion, the use of livestock for pharmaceutical production, and for supplying organs for transplantation to humans (xenotransplantation). Biotechnology might be used to enhance an animal's resistance to specific diseases. Marker-assisted breeding can be used to transfer naturally occurring disease resistances into commercial livestock, but in some cases efficient resistance may only be achievable by genetic modification. Such developments must deliver positive health benefits without compromising animal welfare. Some initial research into enhancing productivity of livestock through genetic modification resulted in unexpected deleterious effects (although these have since been overcome).

  The third area of interest is pharmaceutical production. Therapeutic proteins which cannot easily be synthesised in vitro can be synthesised by genetically modified animals. This technology can be valuable for producing human and veterinary pharmaceuticals and vaccines. An example of this is the production of a,-antitrypsin extracted from the milk of a herd of transgenic sheep that is being clinically tested as a treatment for cystic fibrosis. It should be pointed out that altering milk composition can also be done for human nutritional reasons. Another possible use of transgenic animals is to use them as models for the study of animal or human diseases.

  The final area is that of xenotransplantation. This area was extensively explored by the Advisory Group on the Ethics of Xenotransplantation. Their report entitled, "Animal Tissue into Humans" was published in 1996. They concluded that there were no particular ethical objections to the use of animal organs for human transplantations. However, they concluded that the use of primates for such purposes should be precluded because of the risk of disease transfer to humans. They also recommended that a two year moratorium be put on actual animal to human transplants to try to determine what risks of disease transfer, if any, there are in practice. Recent studies of the retroviruses of pigs, the animals that are expected to be the most likely organ donors, have shown that some viruses are intimately integrated into the pig's genome. This means that producing virus-free pigs may be impractical. This issue will have to be thoroughly evaluated before pigs, or for that matter other mammalian species, are used for transplantation purposes.

  The development of cloning technology, and its application to animals such as cattle and sheep, has raised other issues. One of the first is that cloned animals have proved to be much larger than non-cloned ones, with the animal welfare considerations that this has raised for the mother of such animals. Another problem that could arise would be if cloning was so widespread as to result in an unacceptable level of inbreeding. However, theoretical studies suggest that this problem could be limited. On the beneficial side cloning could be used as a useful technique to aid in the preservation of rare breeds. Nevertheless, the NFU expects that in due course cloning will become one of many accepted techniques for livestock reproduction.

  The report of the Banner Committee on The Ethical Implications of Emerging Technologies in the Breeding of 7Farm Animals closely investigated a range of techniques from selective breeding to genetic modification. Amongst its recommendations, the Committee called for a number of techniques to be considered further by the Farm Animal Welfare Council. The NFU supported this recommendation. Government must ensure that applications of new technologies do not lead to animal welfare problems.

6.5 Antibiotic-Resistant Marker Genes

  One of the first genetically modified crops that was adopted for commercial planting was Novartis's Bt maize. This contained an antibiotic-resistant "marker" gene. The Advisory Committee on Novel Foods and Processes (ACNFP) recommended against the authorisation of this product for growing in the UK or Europe because of the perceived risk of the "marker" gene being transferred to the bacterial inhabitants of the gut of livestock, with eventual possible transfer of antibiotic resistance to human pathogens. This risk was considered to be low but it was felt that further investigations were warranted before the use of the maize was acceptable. This recommendation was eventually overturned by the EC, which led to considerable public protest. The whole matter is still not resolved as this document is written, as various legal and technical challenges to the decision have not yet been resolved. Because of these concerns it is the policy of the NFU that such "marker" genes not be included in genetically modified crops in the future. They are felt to be unnecessary, as consumers are reluctant to accept them, and alternatives are available.

6.6 Minor Crops

  Conventional crop protection methods often neglect the needs of minor crops due to the high cost of obtaining a licence compared with the relatively low expected financial return. The biotechnological techniques for disease and pest control already developed for major crops such as maize and soya, offer enormous potential for the protection of horticultural and other minor crops. There is need for agrochemical companies to license generic technologies in their use in minor crop development. Examples of these would be herbicide tolerance and pesticide inclusion. The government should also fund basic research to ensure that these new technologies can be transferred to minor crops which currently have little or no protection. This could be vital to the future viability of such crops.

6.7 Imports

  Imports of the GM commodity crops soya and maize have led to considerable public unease. The lack of segregation and consequently labelling has led to a situation where it will need a considerable effort for a consumer to avoid eating food that does not contain genetically modified components. Together with retailers and other UK bodies the NFU think that this situation is unsatisfactory. Ideally, international acceptance of data, and recognition of safety evaluation procedures, might counter these concerns. At the moment UK producers could be competitively disadvantaged as regulatory controls have not been harmonised, and appear unlikely to be in the near future.


  British farmers and growers aim to meet consumers' requirements by producing a variety of safe, fresh, wholesome and competitively-priced food. Consumers must have confidence in the food they eat, and in the regulatory system which protects their interests. Any loss of public confidence would be serious for consumers, producers and the food industry alike.

7.1 Public Perception

  Consumer research shows that the public has reservations over the use of biotechnology in food production. Attitudes vary according to the application. For example, applications involving genes derived from plants are perceived more favourably than those involving genes derived from animal sources.

  Public perception will be a significant influence in the uptake of the technology by food manufacturers and retailers. Application of biotechnology could be used to enhance the value of a brand, such as the Flavr Savr tomato paste. However, in other cases a poor perception of the application could damage the brand image. In such a case this could also damage public perception of the corresponding conventional product.

7.2 Food Safety

    The NFU's existing Food Policy States:

    —  the approval of new products must be based on sound scientific criteria and a clear understanding of the nature of the food and its safety hazards;

    —  legislation must be clear, practicable and enforceable;

    —  food safety controls should be harmonised internationally.

  In Europe all foods derived using the process of genetic modification are regarded as "novel". The EC Directive on Novel Foods and Novel Food Ingredients was enacted in May 1997. The Directive seeks to harmonise controls in Europe. One difficulty with the legislation is that a food is only considered to be a "novel" one, and so covered by the legislation, if it is "no longer equivalent" to an existing food. Unfortunately the term "no longer equivalent" is not clearly defined and this can lead to uncertainty. In addition, while a particular food may not be covered by the novel food regulations, there can be consumer concerns about how the product has been produced.

  We are concerned that products of biotechnology (genetic modification in particular) are reaching the market in Europe before harmonised controls are in place. The NFU believes that international guidelines for safety assessment are crucial and supports the programme being developed by the WHO/FAO to compare and co-ordinate international policies on this matter.

  The NFU believes that the safety assessment procedure carried out by the ACNFP provides adequate protection to the consumer. Openness is essential for building and maintaining public confidence in products of biotechnology. The approval process should be transparent and include consumer consultation.

7.3 Labelling

  Product labelling and further explanatory information is vital in ensuring that consumers can make an informed choice. A careful balance should be maintained between the information supplied on food labels and information provided from other sources to assist the consumer in understanding and interpreting these labels. Food labels should be clear, simple, truthful and meaningful. Misleading or confusing claims are unacceptable, do not serve the public interest and are commercially counter-productive.

  Some consumers have moral and ethical concerns about foods derived from genetically modified organisms. In 1992 the Ministry of Agriculture, Fisheries and Food appointed a Committee to consider the moral and ethical concerns of such food products. It recommended that genetically modified foods containing "copy" genes of human origin or genes derived from animals should be labelled to allow consumer choice.

  The government's Food Advisory Committee also reviewed guidelines for labelling food produced using genetic modification in 1993. They recommended that food should be labelled where:

    —  It contains a gene originally derived from a human or an animal which is subject to religious dietary restrictions;

    —  It is plant or microbiological material containing genes derived from human or animal sources.

  The Group of Advisers on the Ethical Implications of Biotechnology of the European Commission, in May 1995, presented the opinion that labelling will be appropriate where modern biotechnology has led to a substantial change in composition, nutritional value or the use for which the food is intended. In such cases the label should specify not only the nature of the change but also the process used to achieve the change (e.g., genetic modification). If the product has not been substantially changed, it will not be appropriate to label.

  The food industry recognises that these guidelines provide only a baseline requirement. In order to ensure informed consumer choice labelling should go further than these guidelines. The NFU worked in association with the Institute of Grocery Distribution (IGD), who in 1997 produced a set of voluntary guidelines for the labelling of genetically modified foods. The announcement that these guidelines will be introduced for 1998 was made by the IGD, in association with the British Retail Consortium and the Food and Drink Federation (FDF) on 20 November 1997. Since then a draft EC Directive has been produced that relates to food that contains soya and maize. Labelling will use the specific wording of "produced from genetically modified soya/maize". Products can be labelled as not containing GM soya/maize as long as there is scientific analysis to support the claim. The third category is "may contain" GM soya/maize. The contents of this EC Directive has proved to be controversial and it is unclear whether it will be approved in its present form.

  Labelling regulations will ultimately need to be decided at European level, and be further incorporated into national legislation. They will also have to apply not just to foodstuffs, but also to animal feed.

7.4 Provision of Information

  Consumer reaction to the use of biotechnology in food production will be determined by many factors, such as perception of benefits and risks, knowledge, understanding and perceived freedom of choice.

  Food labels and appropriate supplementary information will be important factors in achieving understanding, maintaining confidence and allowing an informed choice. The provision of information alone may not improve public acceptance but it will allow consumers to make informed choices.

  The NFU recognises that there is a need for improving public understanding. Balanced and impartial information should be provided by government and the food industry. The Ministry of Agriculture, Fisheries and Food is commended for its Foodsense series of publications. Other useful booklets have been produced by the Biotechnology and Biology Sciences Research Council and the FDF. Further similar initiatives should continue.

  The NFU also supports food industry initiatives to develop communication strategies in order to improve public understanding of the technology and its applications. The NFU believes retailers are best placed to disseminate information to consumers and many of them have produced explanatory leaflets on biotechnology or specific aspects of it. Other explanatory leaflets have been produced by the IGD.

  It is important for the food industry itself to gain a greater understanding of biotechnology and consumer perceptions of biotechnology. The NFU recognises the importance of consumer science research, such as that carried out by the Institute of Food Research, and will continue to encourage research into this area.

  The NFU will continue to urge all levels of the food chain to develop effective communication strategies in relation to biotechnology.


  8.1 Encourage the international harmonisation of regulations controlling safety of biotechnology products.

  8.2 Ensure the principle of farmers' privilege is incorporated into the final version of the EC Directive for the legal protection of biotechnological inventions.

  8.3 Seek clarification of liability for any environmental harm resulting from release to the environment of genetically modified organisms.

  8.4 Promote the introduction of a statutory regime of post-release monitoring of commercially grown genetically modified crops.

  8.5 Urge government to consider formally certain wider environmental and farming implications when considering granting consent to market.

  8.6 Ensure farmers are provided with all necessary information to allow the responsible use of the technology.

  8.7 Encourage openness and consumer consultation during the approval process.

  8.8 Continue working closely with other levels of the food chain in order to develop a suitable food labelling system for foods derived from genetic modification: and ensure that any system does not cause any unnecessary bureaucratic or logistical problems for food producers.

  8.9 Work with government and other levels of the food chain to improve public understanding of biotechnology.

  9. Encourage research to improve understanding of public perception of food and biotechnology.

  9.1 Ensure that government research funding is maintained, so that the UK and its farming industry stay at the forefront of developments.


10.1 Biotechnology could improve the competitiveness of UK agriculture in a variety of ways such as:

  Reduced unit costs of production through:

    —  Increased yields

    —  Reduced expenditure on herbicides and pesticides

    —  Reduced losses through disease

  New crops and new crop uses offering wider market opportunities for:

    —  Industrial feedstocks

    —  Biofuel

    —  Pharmaceutical production

    —  Novel foods

  Improved marketability of existing products, such as:

    —  Improved taste, texture and keeping properties

    —  Increased uniformity of products

    —  More desirable processing qualities, less waste for the food manufacturer

  Efficacy of disease control through:

    —  Reduction in pest damage

    —  Diagnostic tests

  Improved animal health and welfare through:

    —  In-built disease and parasite resistance

    —  Novel vaccines

    —  Diagnostic kits

Biotechnology may also offer environmental benefits through:

  "Cleaner" raw materials for industrial processes

  Energy recycling through biofuel production

  Bioremediation of contaminated land

  More targeted pest/disease control reducing the amount of chemical inputs

And offer benefits to the developing world through:

  Improved stress tolerance in crops

  More effective disease and pest control

  More efficient genetic improvement of local crops and livestock

10.2 The contribution of biotechnology to the competitiveness of UK agriculture and associated industries could be limited by:

  lack of harmonisation of regulatory controls between Europe, North America and the rest of the world

    —  patent law, in particular, scope of patents

    —  Food and environmental safety controls

  Public perception of biotechnology

    —  Fear of unknown

    —  Perceived benefits and risks

    —  Possible rejection of technology

  Farmers, growers and the food industry failing to adopt new products

10.3 The NFU has a number of concerns relating to some users of biotechnology:

  Commercial competitiveness of UK agriculture could be damaged if biotechnology developments were to be taken up by competitor countries but not by the UK.

  Implications for the wider environment

    —  Incomplete understanding of natural ecosystems

    —  Insufficient requirement for monitoring after consent to market

    —  Potential reduction in natural biodiversity

    —  Unclear liability for any environmental harm

  Practical concerns for farmers

    —  Herbicide tolerant volunteers

    —  Reduced efficacy and availability of agrochemicals

    —  Cross contamination of industrial and edible oil crops

    —  Lack of a system to ensure responsible use of the technology

    —  Insufficient mechanism for withdrawal of approval

    —  Animal welfare implications

    —  Possible affect on public perception of conventional products

    —  International marketing problems


Mission Statement

  The Biotechnology Working Party aims to develop an understanding of the issues surrounding biotechnology, their implications to agriculture and horticulture and to make recommendations to the Council of the NFU on biotechnology policy.

Terms of Reference

  The Biotechnology Working Party will consult with and co-ordinate the views of interested committees, groups and relevant organisations.


  Tim Bennett, NFU Deputy President, and Welsh dairy and livestock farms.

  Ben Boot, OBE, Chairman of the NFU Biotechnology Working Party, member of the NFU Milk Committee and a Shropshire dairy farmer.

  Dr David Carmichael, member of the NFU Sugar Beet Committee and Lincolnshire arable farmer.

  Dr Oliver Doubleday, Member of the BBSRC Strategy Board, and Chairman of the NFU Parliamentary, Land Use and Environment Committee, and a Kent horticultural, sheep and arable farmer.

  Bob Fiddaman, member of the NFU Oilseeds Committee and a Hertfordshire arable farmer.

  Ross Kenyon, representing the poultry industry.

  John Lampitt, former Chairman of the NFU Public Affairs Committee and a Warwickshire arable farmer.

  Archie Montgomery, member of the NFU Cereals Committee and a Somerset arable farmer.

  Dr Graham Plastow of Dalgety plc and PIC Group.

  Bob Uglow, a Buckinghamshire dairy farmer.

  Piers Verey, member of the NFU Glasshouse Produce Committee and a Hampshire horticulturist.

2   Genetically modified organisms are regulated by the European Directives 90/219 (Contained Use) and 90/220 (Deliberate Release) which is implemented in the UK by the Genetically Modified Organisms (Deliberate Release) Regulations 1995, under the Environmental Protection Act 1990.  Back

3   Zoning is the registering of a known locality where, for example, only one type of "designer" oil may be grown.  Back

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