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Policy Update

Concerns about the Food Standards Agency’s framework for regulating gene-edited foods

Last year the Genetic Technology (Precision Breeding) Act 2023 was passed in Westminster, which represents a dramatic de-regulation of genetically engineered organisms.  CSA Network UK recently responded to a consultation seeking views on Food Standards Agency (FSA) proposals on how to regulate what are now classed as ‘Precision Bred Organisms’ (PBOs, which are now removed from the requirements of GMOs).

In the proposed framework, there are two tiers that a PBO could fit into, one for lower-risk varieties that allow the developer to self-certify for approval and one for higher-risk ones that require further information to be submitted to the Food Standards Agency.  This is concerning as it offers little oversight of the industry, especially as the consultation document suggests only a proportion of PBO applications will be audited.   Additionally, developers of self-identified Tier 1 PBOs won’t have to specify information about the altered genome sequence or submit reference materials that would enable foods to be tested for the genetically altered ingredients, which could be essential in tracing these foods if adverse health or environmental impacts are discovered once they’re already on the market.  The justification given is that detection methods are still being developed and that there may be issues with distinguishing altered genome sequences from those that could occur naturally, in spite of the conclusions of the review commissioned by the FSA that detection methods do exist and are key to traceability and enforcement.

Even more concerning is the Act removing any requirement for labelling PBOs in foods sold.  As well as completely undermining consumer choice, not labelling GMOs is likely to make them more difficult to trace through a complex food system and places the extra costs of ensuring separation on the organic sector and any businesses that don’t want these ingredients in their foods.  It may also make it more difficult to identify the cause if there are issues such as sensitivity, toxicity or allergic reactions, meaning more people could become ill before any implicated foods are recalled.  It could also pose challenges to studying the health impacts of foods containing them.  The FSA say they will require safety labelling for PBOs where it’s appropriate for particular consumer groups, but without saying what they are or how they’ll be assessed.

The FSA proposes having a public register of the PBOs on the market, as is also a requirement of the act.  This is welcome, but if foods aren’t labelled as containing PBOs, people are unlikely to refer to an online register (as the FSA’s own consumer surveys have shown), and if they do, it won’t be very informative without knowing which PBOs are in the foods they are buying.

The government and the FSA make the argument that the Act and the framework proposed for regulating it are ‘more proportionate’ on the grounds that there is no evidence that ‘Precision Bred Organisms’ pose greater risks than traditionally bred ones, yet the FSAs own paper on the proposed framework submitted to their board in September says about the risks, “it is recognised that a range of outcomes is possible from this rapidly developing technology”.  The fact that there is an absence of evidence and the scope of genetic technologies is changing means more research is needed, not that we can make the generalised assumption that PBOs are safe.

Unfortunately, the government seem determined to see this short-sighted policy through, while the Food Standards Agency’s framework for carrying it out in practice seems directly at odds with its fundamental mission of “Food you can trust”.

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