SUMMARY OF RESPONSES TO GM CONSULTATION 2001

Table for Response to Consultation

Summary of responses to GM consultation 2001
Respondent	Comment	FSA Action	Other
SCOPE
Royal Welsh Agricultural Society	Proposals appear to be adequate response to average consumer demands – will not satisfy those who wish to keep GMO’s out of food chain. Satisfied that whilst Regs laid down by Europe there is latitude within Wales to interpret rules to meet individual needs. Labelling appears adequate but may need to be amended in light of experience.
Farmers Union of Wales	Fully support measures designed to improve present labelling requirements regardless of whether it is possible to measure differences in chemical composition between GM and non GM ingredients.
Meat & Livestock Commission	General objectives of proposed regulations are welcomed. Concern that draft regs do not refer to negative labelling such as "GM free" – to avoid misleading consumers consider negative labelling be defined in law. Requirements that presence of GMO’s in food and feed be indicated is welcomed.
Powys County Council	Fully support requirement for clear labelling of food to enable informed choice – do not consider the proposals provide for this. Labelling requirements misleading for consumers. Eg – "food from animals fed on GM feed no requiring labelling.
David Smith ACW	Do not consider proposals are adequate to meeting consumer demands – they do not add any value.
Bruce Cotterill, ADAS	Appears to be a degree of inconsistency in the labelling requirements. Products derived from GM ingredients but containing no GM material need to be labelled whilst food produced with the help of enzymes from GM sources do not - example quoted.
National Farmers Union of Wales	Concerned that labelling of products produced from a GMO but contain no GM in final product is unenforceable and open to abuse. welcome specific rules for approval and labelling of GM animal feed. if effectively implemented, proposals are adequate for consumer needs.
Thresholds
Royal Welsh Agricultural Society	No comment.
David Smith ACW	concept of a threshold is not practical. It should be set at 0%. do not feel there is a practical constraint on threshold levels -–depends who funds testing.
National Farmers Union of Wales	accept adventitious contamination cannot be avoided – welcome Commissions practical approval in setting threshold. difficult to see how thresholds can be enforced – need accreditated detection method.
Detection and Enforcement
Royal Welsh Agricultural Society	No comment.
Farmers Union of Wales	Believe responsibility for demonstrating whether a product is derived from GM source should be placed on manufacturers of food and feed including ingredients like flavouring. monitoring and enforcement provisions of the regulations for imported GM products should be properly addressed.
Meat & Livestock Commission	Welcome requirement to inform consumers where a GM food or feed is not equivalent to conventional counterpart or where modification may give rise to ethical or religious concerns. Concern that there is considerable risk of elements of both proposals being unenforceable. Desire to use unique code traceability measures is commendable. Concern as to whether traceability systems based on event codes can be made to work in practice. Definition of ‘unique code’ must allow for provision of unique codes to organisms with one or more modification events.
Powys County Council	Practical constraints on labelling and traceability the further you progress along chain of production. Procedure straightforward for manufacturers more onerous for cafes/restaurants etc.
David Smith ACW	Labelling should be full open and honest. Enforcement of requirements should include destruction of mislabelled product without compensation. Detection methods need to change with developing technologies and not set at today’s technology.
National Farmers Union	Consider Commission must be certain consistent testing is available before introducing a system for effective enforcement. Costs of testing will be extremely high. Current detection methods are difficult to apply in cases of highly refined processed material. Not aware of any detection methods for GM – derived oils other than protein or DNA analysis.
Authorisation and Applications
Farmers Union of Wales	Important to have same standard in assessing food safety – support proposals to make EFA assessment body within EU, including produce imported from Third World countries. Given speed of technological development suggest authorisation applications should be reviewed every five years rather than ten.
Meat & Livestock Commission	Welcome rationalisation of approvals procedure combining food and feed. Welcome fact that approvals are to be based on risk analysis. Wish to see provision of Article 29 in Chapter IV retained in any future versions of proposal. Detailed comments on Article 3(1), 4(1), 6(3), 14(2), 16(1), 17(1), 18(1)(b), 27(3)(b). Concern about the need for consistency in application
David Smith ACW	Do not consider summary document is adequate for inviting public comments. Authorisations should be renewed every five years – consider this is more effective.
David Smith ACW	Do not consider summary document is adequate for inviting public comments. Authorisations should be renewed every five years – consider this is more effective.
Bruce Cotterill, ADAS	If EFA responsible for approval process it will need rigorous protocols agreed by all member states to ensure level playing field in safety assessment.
National Farmers Union for Wales	Summary document may be adequate but full details should be made publicly available where possible. Requirement for renewal of applications provides opportunity to assess whether evidence of long term effects has com to light. Welcomes central system of assessment. Proposal that authorisations are for either both food and feed or neither should help to prevent x contamination.
Costs and Benefits
Royal Welsh Agricultural Society	Processes of establishing traceability of GMO’s and subsequent labelling for benefit of consumer must not be to detriment of smaller operator leading them to bypass testing/labelling products. Cost must not be so great to threaten business with closure.
Meat & Livestock Commission	Significant concerns as to the feasibility of potential costs of application of some of the proposed measures.
David Smith, ACW	Insufficient data to enable comments on impact and cost implications.
National Farmers Union of Wales	Concerned farmers relying on soya imported from outside EU will be penalised by additional testing costs. Official guidance on sampling and testing will be needed to avoid uncertainty.
Other
Farmers Union of Wales	Continue to hold view there is no justification for introduction and use of GM crops for food production – members are of the view they should still be able to claim that Wales is free of GM crops.
David Smith, ACW	No longer have effective customs control of imports – we need new legislation and more money to enforce existing controls.
National Farmers Union for Wales	Difficult to see how obligations on importers will operate in practice. Disappointing clear guidelines on use of terms such as "GM free" have not been included. NFU believes GMO’s and derived products must be segregated to allow meaningful labelling.
No substantive comment