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Consultation on the ‘New Breeding Technology Act’ in Switzerland
- Details
- New GE techniques
No scientific basis for a special law
Even 'new' genetic engineering is still genetic engineering; the term 'new breeding technologies' is misleading, as is the justification for a special law.
With the proposed 'Federal Act on Plants from New Breeding Technologies' (the Breeding Technology Act, or NZTG for short), the Federal Council is accommodating the genetic engineering lobby's wish to avoid regulating organisms modified by targeted genetic engineering techniques (such as CRISPR-Cas9) under the existing Genetic Engineering Act (GTG). However, this would be problematic both legally and scientifically.
Here's a summary of our arguments:
- As the Federal Council itself stated, the technologies of concern are genetic engineering processes, and the resulting organisms are genetically modified organisms (GMOs), from both a technical and legal perspective. This is in line with the assessment of the European Court of Justice, which in a judgment of 25 July 2018 in Case C-528/1627. Since there is already a law governing GMOs in the form of the Genetic Engineering Act (GTG), the present proposal constitutes a duplication of legislation.
- The designation of the proposed legislation as 'plants from new breeding technologies' is deceptive for a number of reasons. The term ‘breeding technologies’ obscures the fact that these are genetic engineering processes, and it potentially includes technologies that are not covered by the wording of the law. The misleading title of the law, coupled with a lack of conceptual precision in its text (e.g. how long are 'new' breeding technologies considered 'new'?), undermines both legal certainty and consumer freedom of choice. From a scientific and legal point of view, if something is genetically engineered, it must be labelled as such.
- CSS rejects the envisaged harmonisation with EU legislation on this matter. NGT-1 plants must be regulated as genetic engineering in Switzerland. They must undergo an environmental risk assessment and be labelled along the entire value chain, regardless of EU regulatory developments. The NGT-1 to NGT-3 categories are primarily regulatory constructs — the arbitrary "up to 20 modifications" threshold is not scientifically justified. Risk and equivalence should be based on phenotype, ecological function and genomic context, not the number of base pairs altered.
- The present draft regulation cannot guarantee GMO-free agriculture and production in Switzerland. Given the practical, economic and ecological obstacles, the coexistence of genetically modified and non-genetically modified plants is hardly feasible.
- The explanatory report of the Federal Office for the Environment uncritically adopts the hype and the often untested and unsubstantiated promises surrounding targeted genetic engineering techniques. It is not clear on what basis the Federal Council assumes that their use will ‘make agriculture more sustainable and increase the resilience of crops to climate change’. The question of the added value of plants produced using targeted genetic engineering techniques must be viewed extremely critically from both an ecological and an economic perspective: it must be defined much more clearly, must not be based exclusively on laboratory data, and must be reviewed at regular intervals. In addition to the speculative added value, the risks associated with the technology must also be identified and reviewed periodically.
- Overall, the NZGT draft, which was created under intense lobbying pressure and was not carefully thought through, is unacceptable in its current form. If the goal of a separate authorisation regulation for targeted genetic engineering procedures is to be pursued, it must be presented as part of a revision of the existing Genetic Engineering Act (GTG). Any such revision of the GTG must take into account the constitutional requirements (Art. 120 BV) and the legal requirements (Art. 37a para. 2 GTG). In accordance with the precautionary principle, it must place the general interest in an intact environment and human health above speculative hype (which also extends into science) and market forces, which regularly push for the deregulation of technologies for profit reasons and thus also evade their responsibility for possible damage, the risks of which are usually far greater than is commonly portrayed.
CSS Consultation Response (German) | Stellungnahme (PDF)
CSS Consultation questionnaire (German) | Fragenkatalog Vernehmlassung (PDF)
ENSSER reaction to GM proposal by EC
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- New GE techniques
Analysis statement of ENSSER on the European Commission’s leaked new GM proposal
ENSSER states: "The EU Commission’s proposal is scientifically unacceptable, removes the provisions of the precautionary principle and puts the public and environment at risk. Critical scientific expertise and its supporting scientific evidence was completely ignored. The proposal follows exclusively the guidance and assertions of the public and private biotechnology sector – and is therefore to be classified as one-sided. In our analysis statement, we briefly explain why this is so – with scientific reasoning and evidence. We focus on the Annex I only for now."
This statement was sent to members of the European Parliament and competent authorities in several EU member states on July 4, 2023.
The SAG also published a reaction here and started a campaign to respect the consumers' choice. Our board member Angelika Hilbeck was interviewed on Swiss national television about the latest push to deregularise NGTs. And the Corporate Europe Observatory reacted here.
Extension of Gene-Tech Moratorium
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- New GE techniques
Critical Scientists Switzerland published a statement in response to the Federal consultation process on the extension of the Swiss gene technology moratorium.
The Critical Scienstists Switzerland welcome the planned extension of the moratorium. We fully agree with the Federal report on the planned extension that organisms produced with new gene editing technologies are subject to the current legislation on gene technologies (Gene Technology Act) and are regulated accordingly (precautionary principle, risk assessment, step-by-step procedure, labelling, and monitoring). Despite some inconsistencies of the Federal report highlighted in our statement, Critical Scientists Switzerland generally support the current government policy.
Phenotypic abnormalities and poor agronomic performance of Golden Rice
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- Golden Rice
Introgression of the provitamin A trait from transgenic Golden Rice into a commercial, high yielding Indian rice variety leads to an array of unintended effects, a new study finds.
Golden Rice is genetically engineered to produce beta-carotene, a precursors of vitamin A, aiming to combat vitamin A deficiency. A new study now finds, that backcrossing of the genetically engineered Golden Rice, with the Indian mega rice variety Swarna, leads to morphological changes such as pale green leaves, a reduced plant height and a drastic reduction in yield.
The researches found that the transgene was inserted into an active region of the genome, thereby disrupting the coding sequence and ultimately the function of the plants own OsAux1 gene. The OsAux1 gene is involved in the transport of the hormon auxin, which is important for virtually every aspect of plant growth and development. The researchers also report a lower Chlorophyll content in the backcrossed plants, which probably causes the pale green leaves.
As a result the Golden Swarna lines are unifit for commercial cultivation the study concludes. These findings are on the one hand relevant for the risk assessment of the transgenic plants: once released, these plants could spread to other rice varieties and endanger rice harvest. On the other hand they show yet again that despite many years of research & development (R&D), the Golden Rice project has not yet produced a commercially viable rice line rich in provitamin A. Instead of investing in R&D that favors industrialised agriculture and corporate control over seeds, the root causes for hunger and malnourishment, such as rural poverty and access to markets, should be tackled.
Read more at:
- Bollinedi et al. (2017). Molecular and Functional Characterization of GR2-R1 Event Based Backcross Derived Lines of Golden Rice in the Genetic Background of a Mega Rice Variety Swarna. PLOS ONE 12(1). http://dx.doi.org/10.1371/journal.pone.0169600
- Testbiotech: ‚Golden Rice’: Unexpected genomic effects. https://www.testbiotech.org/en/node/1859
The Union of Latin American Scientists Committed to Society and Nature (UCCSN-AL) criticises a letter from Nobel laureates in support of Golden Rice
- Details
- Golden Rice
UCCSN-AL questions the neutrality and objectivity of the letter from Nobel laureates that urges Greenpeace to end its opposition against genetically modified crops, especially golden rice. They also point out the lack of robust and well founded arguments.
In their statement, UCSSN-AL confutes the claims that GM crops have higher yields and can contribute to the goal of ending world hunger. Instead, the main GM crops marketed today are mainly used for the production of biofuel and animal feed.
Golden rice, which is not commercialised today, is intended to synthesize beta-carotene - a precursor of vitamin A - and help the fight against vitamin A deficiency. However, UCCSN-AL says, malnourishment is related to poverty and loss of food sovereignty and not to the lack of a specific nutrient. On the contrary, this rice would contribute to the undermining of traditional food systems and increase large-scale monocultural production, corporate control over seeds and genetic uniformity.
They further point out the great importance of genetic diversity and traditional varieties to combat hunger and negative effects of climate change. Rather than investing in the promotion and implementation of golden rice, this money could be used to promote crop diversity and strengthen local and regional nutrition and food sovereignty.
- Read more at: La UCCSN-AL Frente a la carta de un grupo de premios Nobel en apoyo a los cultivos transgénicos
Subcategories
New GE techniques
In the past decade, various new GM techniques have been developed. These include Oligonucleotide Directed Mutagenesis (ODM), Zinc Finger Nuclease Technology (ZFN) types -1, -2 and -3, TALENs, CRISPR-Cas9, Meganucleases, Cisgenesis & Intragenesis, Grafting, Agro-infiltration, RNA-dependent DNA methylation (RdDM), Reverse breeding, and more recently base editing and prime editing.
It is often claimed by the industry, some public-private research institutes and in the media, that genome editing techniques are more precise and hence safer than common transgenesis and that the products resulting from these techniques contain no foreign DNA and are thus not to be considered GMOs. What has become more precise with genome editing techniques such as CRISPR-Cas is where in the genome a double-strand break is inserted. What happens after the cut, how the cell repairs the double-strand break, and how a gene of interest is inserted, remains, however, still inadequately understood.
Hence, the process has been prone to errors, including the insertion of unwanted DNA-fragments and large DNA deletions or rearrangements, which can ultimately lead to proteins that are altered in their structure as reported in the scientific literature (so called on-target effects). Moreover, a growing number of studies have reported additional DNA cuts at further unintended places (off-target effects), although only a fragment of studies looks for such off-target effects. Furthermore, rarely discussed is that while the techniques have changed, the process of plant transformation has remained largely the same – a gene construct is introduced into a cell using a vector (commonly agrobacterium tumefaciens) or by particle bombardment – the risks basically remain the same as well. (See major publication by CSS and others on the issue)
Roundup Ready Crops
Roundup Ready (RR) crops, developed by Monsanto, are crops genetically modified to confer resistance to glyphosate, the declared active ingredient in the herbicide Roundup. That means that farmers can spray their fields with a single herbicide – Roundup, or any other glyphosate-based herbicide, throughout the whole growing season in order to eradicate troublesome weeds and without risking to harm their crops.
The industry claims that this farming system requires less skills and knowledge than the conventional farming system because farmers do not have to select among a range of herbicide active ingredients, carefully time their herbicide application and apply other non-chemical control practices such as plowing, deep tillage or manual weeding. Further promoted advantages and promises by the industry include that RR crops create more yield than conventional crops, decrease farmers input costs by reducing the amount of herbicides sprayed and are safe for humans, animals and the environment.
Upon their commercialisation in the mid-1990s, Roundup ready crops were adopted very quickly and reach saturation today in countries with large-scale industrial agricultural production such as the U.S., Argentina and Brazil. Europe, where family farms prevail, is until today still free from RR crop cultivation and Switzerland has a moratorium on the use of genetically modified organism in agriculture that is valid until the end of 2021. Worldwide, herbicide resistant crops, of which the vast majority are resistant to glyphosate, account for about 84%, of all cultivated genetically modified (GM) crops.
Despite the extensive adoption of RR crops in some countries, the claims made by the industry proved to be short lived or false during the past 20 years.
Bt crops
Bt crops are genetically modified to confer resistance against certain insect pests. The inserted genes were originally identified in the bacterial species Bacillus Thuringiensis (Bt). These bacteria exhibit insecticidal activity by producing different δ-endotoxins (Cry and Cyt toxins). For that reason, Bacillus thuringiensis spp. have long been used in biopesticides. In Bt crops, the insecticides are produced inside the plant and can, unlike traditional insecticides, kill insect pests feeding inside of plant tissues. Moreover, the toxins are not washed off or degrade by UV radiation. This caused concern that eating the crops may have adverse health effects.
The first Bt crop commercially available was Bt potato, resistant against the Colorado potato beetle, in 1995. Commercialisation of Bt cotton and maize followed in 1996. Bt maize is mainly cultivated in the USA, Brazil, Argentina and South Africa. A small quantity is also grown in Europe, mainly in Spain. Bt cotton is most common in India and China where it is the only GM crop authorised for cultivation.
Today, insect resistance is the second most common trait used in genetically modified (GM) crops, after herbicide tolerance, with 43% of all cultivated GM-crops being insect resistant.
The industry promised that Bt crops would result in higher yields and decrease insecticide applications. However, pests with resistance against certain Bt toxins have become a huge problem today. Low crop yield, high seed prices and crop loss due to resistant insect pests have been associated with farmers’ suicides in India.
Golden Rice
Rice (Oryza sativa) has been genetically modified to produce beta-carotene in order to improve the supply of vitamin A. Carotenoids are a precursor of vitamin A and give the rice its yellowish color and the name Golden Rice. Naturally, peeled rice grains contain no carotenoids.
With rice as a staple food for over half the world's population, the so-called Golden Rice should help combat vitamin A deficiency, a serious problem in different developing countries.
The International Rice Research Institute (IRRI) is currently reviewing the characteristics of the genetically modified rice, including its safety and suitability for human nutrition.
Despite 25 years of research and development, no Golden Rice-varieties are available today that are suitable for commercial cultivation.