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Labelling is feasible, even for new genetic engineering

Photo: Concept Photography Berlin

This text by VLOG Managing Director Alexander Hissting first appeared as a guest article in Tagesspiegel Background.

Food and feed produced from genetically modified plants are not banned in the EU, regardless of whether they involve old or so-called new genetic engineering techniques. Almost 100 lines of genetically modified plants are approved for import into the EU and used as food or feed. Every year, millions of tonnes of genetically modified soy are imported into the EU. However, they are only used where the labelling requirement under current law ends in the middle of the supply chain, namely before the foodstuffs end up in the supermarket.

Concealing genetic engineering so that food is purchased?

Even though pig feed still carries a label indicating that it contains genetically modified soy, the pork cutlets on supermarket shelves reveal nothing about how they were produced. However, wherever the use of genetically modified products must be made transparent to consumers, there are virtually no goods on offer. Not because their use is prohibited, but because products with labelled genetically modified ingredients find no consumers. This is what is called a functioning market economy.

From the perspective of those who want to develop and market genetically modified plants, this results in the blunt demand to abolish the obligation to label genetically modified products. What consumers don't know won't hurt them – that is presumably the hope of Bayer, BASF and Co.

If NGT deregulation in the EU were implemented as planned by the EU Commission and the Council of Ministers, genetic engineering companies would come a big step closer to this goal. Gradually, plants with new, non-labelled genetic engineering would replace the “old”, labelled genetic engineering worldwide and would probably also be cultivated on Europe's previously GMO-free fields.

Abolishing mandatory labelling puts a burden on companies

Technical or economic reasons are repeatedly cited for rejecting GMO labelling. New genetic engineering is said to be impossible to analyse, and comprehensive labelling requirements are said to be too expensive. This is not only a flimsy and transparent strategy to prevent transparency and freedom of choice, but also a distortion of the facts. Without comprehensive genetic engineering labelling, companies that respect and want to fulfil customer demands for GMO-free food would be significantly more burdened.

In fact, maintaining comprehensive genetic engineering labelling requirements is entirely feasible. After all, the plans of the EU Commission and the Council of Ministers also provide for the labelling of NGT seeds and planting material. This labelling then simply has to be passed on throughout the supply chain.

Consistent labelling using delivery notes is not rocket science

The delivery note, which must be handed over when food is sold to the next processor or retailer, already provides information about the ingredients contained in a product. Whether an ingredient is genetically modified is simply another piece of information that is passed along the supply chain.

An example: The farm declares on its delivery note to the oil mill that NGT rapeseed was used. The oil mill declares to the margarine manufacturer on its delivery note that the rapeseed oil was produced with NGT rapeseed. The margarine manufacturer takes this information and, together with the information about the composition of the margarine, puts it on the list of ingredients on the food packaging. This is not rocket science, but rather the application of general rules of existing food law.

Passing on a special property of individual ingredients throughout the entire supply chain is also nothing new for the food industry. For example, according to EU allergen labelling regulations, certain ingredients with allergenic effects, such as celery, wheat or soy, must be declared on the accompanying documents and in the list of ingredients throughout the entire supply chain – regardless of the dosage in which they are contained in the product and regardless of whether they are detectable or not. Documentation throughout the entire supply chain is common practice also in organic production.

Closed, certified supply chains? An expensive alternative!

If NGT plants are not subject to mandatory labelling in future, those who wish to offer GMO-free food products would be significantly disadvantaged. This would particularly affect the vast majority of food manufacturers who already take care not to use genetically modified ingredients without explicitly stating this on the product. Manufacturers of tens of thousands of food items produced with soy, rapeseed or corn components – the plants most commonly genetically modified worldwide today – currently rely on the labelling of the ingredients used to exclude genetic engineering.

In order to be able to offer the same quality in the future, these companies would have to use ingredients that come from secure supply chains – from agricultural cultivation to the finished food product. This would involve significantly greater effort and would, of course, lead to higher costs.

In addition, there are further liability risks for the food industry because, according to the EU Commission, almost all NGT plants are not to undergo risk assessment. Furthermore, the responsibility for assessing whether NGT products fall under ‘novel food’ legislation and, if necessary, undergoing a complex approval process would be shifted from the genetic engineering manufacturers to the food industry.

If the use of NGT could no longer be reliably ruled out by means of mandatory labelling, this would affect not only those who wish to operate GMO-free, but literally all food companies, from production and processing to retail.

No new NGT regulations without labelling requirements

Transparent labelling of genetically modified products is only a problem for those who want to promote a technology that does not have sufficient acceptance among customers. Attempting to secretly foist genetically modified products on them is dishonest and undermines trust in politics and in industry.

Therefore, the comprehensive labelling requirement for genetically modified products must be retained in the upcoming NGT deregulation in the EU. The European Parliament shares this demand. Now, the German Federal Government, in particular, must advocate for this in the trilogue negotiations in Brussels. With everything that goes with it: reference material – i.e. samples of approved NGT plants, verification procedures and traceability rules for all genetically modified plants when they are approved for the market in the EU.

Tagesspiegel Background: Point of view - Labelling is feasible, even for new genetic engineering (German)