London (24.8.09) – Further to the ‘Food Matters’ progress report (1) published recently, the Department for Environment, Food and Rural Affairs (Defra), together with the Food Standards Agency (FSA), has also issued an analysis of the potential impacts of global trends in GM production on the UK livestock sector and the current operation of the GM approval system in the UK (2). That analysis considers the extent to which changes in the market are putting a strain on the regulatory system for GM products (including animal feed) and the implications for consumers.

Analysis

Another report underlines the Government’s pro-science approach and its recognition that current regulation of GM crops will lead to a lack of GM feed for the meat industry and potentially impact on consumer prices. Importantly the report helps to re-frame the debate around the economic risks regulation poses to agriculture and the wider food industry. This ensures GM remains a key part of the ‘food security’ debate and not the ‘food safety’ debate.

It brings into sharp focus the need to address the issue of asynchronous approvals between the EU and the rest of the world. The report makes clear that the damaging effects of poor regulation must be addressed to ensure we have a system that is fit for purpose that poses no threat to our economy.

The report also provides a useful insight into the underlying supply-side issues facing retailers as they pay higher prices to maintain lines of non-GM food. It is clearly a more pressing issue than the retailers have been comfortable to express either in public or in meetings with abc. In all reality they could be seriously reviewing their position and how long they can maintain it, in the face of pressure from the livestock industry.

Recognising the need for consumers to be better informed about GM, within the report the FSA re-visits the question of the need for an information campaign on GM. Whilst this is a positive step forwards it is important to ensure that GM is not presented as a stand-alone technology but as part of the broad range of agricultural methods used in modern farming. There is also no indication of who, or which organization should be educating consumers.

Further, although consumer concerns have decreased, it is surprising to see that this is in part due to the belief that the ‘problem’ had been ‘dealt with’ and there was therefore nothing to be concerned about (i.e. retailers do not sell products containing GM food ingredients)

DEFRA on animal feed supplies and the regulation of GM products

This document provides an analysis of the potential impacts on the livestock sector that might arise from global trends in GM production as well as the current operation of the GM approval system in the EU.

The paper notes that the UK livestock sector is “effectively dependent” on imported soya feed, coming predominantly from Brazil and Argentina (90%+). It states that these countries mainly produce GM soya – around 94% of production in Argentina and 65% in Brazil.

It also states that of the total amount of soybean meal used for feed in the UK, most is used by the poultry sector (42%), followed by the pig sector (28%) and the cattle sector (19%).

The report reflects the concern within the UK feed and food sectors that “it is becoming increasingly difficult and costly to maintain a non-GM supply chain, and that it may become unsustainable at some point in the future”.

It goes on to discuss the likely impact on the UK livestock sector should feed imports be disrupted, stating that it would depend on “the extent of the shortfall”. It notes that a ‘medium impact’ scenario, where a complete loss of supply from Argentina is partially compensated by increased imports from Brazil, could have a “relatively limited or manageable impact”. However, it states that this would still involve “an increase in overall feed costs, with a possible range of 4-23%.

Under a ‘worst case’ scenario, where there are no soya imports from both Argentina and Brazil, the report notes that the impact would be “very significant”. It states that there would be a “major increase in feed costs”, of upwards of 300% and a marked increase in meat prices.

This could also lead to a significant reduction in UK livestock production which could “also have a range of consequential effects on land use and the environment”.

The report states that if soya product imports were reduced or halted, feed would have to be replaced with less effective and more costly materials which would have a negative impact on the productive capacity and profitability of the livestock sector.

It continues that if a non-EU approved GM feed crop is being grown in a supplier country at the same time as non-GM and/or EU-approved GM varieties, the use of strict segregation and Identity-Preservation systems “can reduce the risk of feed supplies being affected by findings of the non-approved material, but they cannot eliminate the risk completely.”

The paper then discussed the reality of the threat of a major feed supply problem, concluding that there are different perspectives on this issue, “and no clear answer”.

FSA on changes in the market and the GM regulatory system

This document provides an analysis of the extent to which changes in the market are putting a strain on the regulatory system for GM products and the implications for UK consumers. It is worth noting that Appendix 1 of this document lists the organisations that attended the FSA stakeholder meetings, many of which we are engaging with as part of our retailers programme.

Changes in the market

The paper observes that there is no legislative requirement in the EU to label products from animals fed GM feed and added that some retailers stipulate that non-GM feed should be used for certain livestock. In addition, it was noted by some stakeholders that products from animals imported from third countries where non-EU authorised GM varieties were used would “undercut EU producers, distorting competition.”

It states that food manufacturers have said that the cost of sourcing non-GM food ingredients is increasing with the prices for non-GM sources being estimated as 10-20% higher than those for GM. From the perspective of a retailer, there is concern that they may not be able to maintain their current non-GM sources of supply as producers increasingly adopt GM technology around the world.

With regard to animal feed, the report states that the industry’s research has shown that UK protein production could only replace 10-20% of the protein supplied by imported soya. It concludes that “it is clear soya remains the most important source of protein in animal feed at present.”

On the supply of commodity crops, the paper concludes that the current situation with asynchronous authorisations “increases the potential for adventitious presence of non-EU-authorised GMOs.” It adds that such consignments “would be illegal in the EU.”

The regulatory system

The FSA notes that there is widespread support for a “robust and rigorous safety assessment” and agreed that if this process were speeded up to address problems associated with asynchronous approvals, “there should not be a reduction in the standard of assessment”.

The paper notes that new GM events are being developed “at a faster rate than applications are being processed in the EU.” It states that as of November 2008, 42 events were being considered for authorisation in the EU, adding that over the past two years, 15 events have received favourable opinions from EFSA with eight of these subsequently authorised for use in food and feed. In addition, it notes that the remaining seven applications are awaiting authorisation.

The report states that the cost of routine testing for GMOs is prohibitive, and noted that this “can lead to only small numbers of samples being collected”. It explains that therefore laboratories are “unable to justify the cost of maintaining staff expertise and the investment of capital in equipment and laboratory consumables” and noted that this can lead to a lack of provision in public analyst laboratories capable of providing GM analysis and the turnaround time for analysing samples due to other competing work priorities. It states that this can be “problematical for enforcement authorities waiting for results and operators waiting for samples to be verified, leading to additional costs.”

It explains that some stakeholders felt that a ‘technical solution’ was necessary in order to maintain the current supply of animal feed into the EU and notes that “it was suggested that a positive opinion from EFSA should be sufficient to allow low level adventitious presence of a non-authorised GMO.” It adds that EC Regulation 1829/2003 on GM food and feed does not allow for this.

Implications for consumers

The report refers to consumer concerns regarding GM technology, stating that they “tend to fluctuate with time, and may increase particularly in response to increased media coverage.” The FSA refers to its own research that tracks public attitudes, stating that it “shows GM technology is not a pressing concern for consumers.” It reiterates that the tracker has shown a steady decline in concern but notes that this “should be contextualised with consumer belief that the ‘problem’ had been ‘dealt with’ and there was therefore nothing to be concerned about”.

In addition, the report states that many consumers are “unaware of the extent to which GM feed is used” and notes that there is no legal requirement to label products from animals fed on GM feed. It adds that retailers have differing stated policies regarding the use of the terms ‘GM’, ‘non-GM’ and ‘GM-free’. The FSA suggests that this can lead to confusion for consumers.

The costs of maintaining non-GM supply chains are “currently absorbed by farmers and feed compounders rather than being passed on to consumers.” However it adds that in the longer term these costs may result in increases in the price of products from animals for consumers.

It "may be timely to inform consumers of the issues surrounding GM and non-GM supply chains so that they have a clear understanding of current science, the status of the non-GM market being reliant on only a few exporting countries, and the steady increase in GM production.” This leads to the question of who should have responsibility for informing consumers and whether this should be the role of the Government or if retailers should play a part.

Sources:

1. Food Matters: One year on. DEFRA (August 2009) (http://www.defra.gov.uk/foodrin/pdf/food-matters-oneyearon090806.pdf)

2. GM Crops and Foods: Follow-up to the Food Matters Report by Defra and the FSA. DEFRA and Food Standards Agency (August 2009) (http://www.defra.gov.uk/environment/gm/crops/pdf/foodmatters-defra-fsa-1308.pdf)

<<<back