Community l=
abelling
thresholds for the adventitious or technically unavoidable presence of
authorised genetically modified (GM) seeds in conventional seeds=
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The Commission has invited you to participate to the web survey on=
"Community
labelling thresholds for the adventitious or technically unavoidable
presence of authorised genetically modified (GM) seeds in conventional
seeds". Please use the field below to provide your
identification - organisation you represent.
Also note that personal data will not be published and they will be
used only for this survey purposes and for contacting you for further
information.
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Ms Susan Fowler Organic Centre Wales c/o Institute of Rural Sciences Unive=
rsity
of Wales
Aberystwyth SY23 3AL
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General Section - Profile of the Respondents<=
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Do you represent a ... :
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Public sector / administration
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Country where you OR your organisation/company is =
based:
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UK - United Kingdom
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Number of employees/members of your company/organi=
sation
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10 to 49
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I. General reflections on the concept and need for
specific thresholds for the labelling of authorised GM seeds in
conventional seed lots
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1. As it is recognised in Community seed legislati=
on and
OECD guidelines for the presence of non-GM impurities, experience with =
seed
production practices shows that 0% adventitious presence of any type in=
a
seed lot is impossible to achieve since seeds are grown in an open
environment and are subject to technically unavoidable presence of
impurities.
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I strongly disagree
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2. The concept of not labelling as “genetica=
lly
modified” food and feed that contains GM in a proportion lower th=
an
0.9% has been recognised in EU legislation. This concept of adventitiou=
s presence
should also be recognised in seed by setting thresholds that are feasib=
le
and proportionate.
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I strongly disagree
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3. In order to recognise the reality of seed impur=
ities
and facilitate the marketing of conventional and organic seed lots, it =
is
necessary to establish labelling thresholds, as low as feasible and
proportionate, below which the presence of traces of GM seeds does not =
have
to be labelled.
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I strongly disagree
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Please give briefly further comments, if any, on the concept and n=
eed
for specific thresholds for the labelling of approved GM seeds in
conventional seed lots.
The field is limited to 200 characters
In case that you wish to submit full size case studies or repor=
ts,
please see the instructions contained in the information tag below on=
how
to submit your material.
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Thresholds for seed must be near zero. Work by N=
IAB
indicates that contamination can be managed. Separation distances can
ensure that seed has near zero GM contamination.
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II. General impacts of the current situation of ab=
sence
of specific thresholds for the labelling of authorised GM seeds in
conventional seed lots
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4. In the current situation of absence of specific
thresholds for the labelling of authorised GM seeds in conventional see=
ds
there is legal uncertainty as to what level of GM presence to label.
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I somewhat agree
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/o:p>
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5. In the current situation of absence of specific
labelling thresholds for seeds, different thresholds are de facto being
applied across the European Union, leading to a disruption of the EU
internal market on seeds.
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I don’t know
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6. The fact that there is no clear understanding o=
f what
"level of detection" means and that the limit of detection (L=
OD)
varies amongst GMOs and detection methods l=
eads
to additional uncertainty
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I somewhat agree
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7. A freedom of choice for conventional, organic a=
nd GM
farmers may be maintained if the existing legislation is adhered to and
enforced and any detectable adventitious traces of authorised GM seeds =
are
labelled.
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I somewhat disagree
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8. A freedom of choice for conventional, organic a=
nd GM
farmers may be only achieved if a specific labelling threshold is
established.
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I strongly agree
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/o:p>
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9. Can you indicate other impacts that the absence of specific
labelling thresholds can provoke? Please be specific. If you are awar=
e of
specific research or studies in this area please provide us with the and references and additional information.
The field is limited to 250 characters
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Enforcement of labelling of any detectable level
backed up with legislation for lowest detectable presence in seed
production would provide information to the user.
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Please give further comments, if any, on the general impacts of the
current situation of absence of specific thresholds for the labelling=
of
authorised GM seeds in conventional seed lots.
The field is limited to 200 characters
In case that you wish to submit full size case studies or repor=
ts,
please see the instructions contained in the information tag below on=
how
to submit your material.
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Austrian seed purity rules are a useful model.&n=
bsp;
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III. Economic and social impacts for operators of =
the
current situation of absence of specific thresholds for the labelling of
authorised GM seeds in conventional seed lots
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10. In the current situation of absence of specific
labelling thresholds for seeds, the conventional seed industry will hav=
e to
increasingly incur additional costs for seed production and testing and
will pass the impact of an increased seed price further down the produc=
tion
chain to both conventional and organic farmers and consumers=
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I somewhat agree
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<=
/o:p>
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11. In the current situation of absence of specific
labelling thresholds for seeds, industry already incurs important testi=
ng
and segregation costs to ensure the absence of authorised and unauthori=
sed
GM seeds in conventional lots.
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I don’t know
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12. In the current situation of absence of specific
labelling thresholds for seeds and considering the increasing uptake of=
GM
crops in Europe, industry may not be=
able
to continue producing conventional seeds without traces of GMOs without undertaking important investments. T=
his
could mean that some companies, mostly SMEs=
, may
go out of business with a resultant loss of jobs.
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I don’t know
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/o:p>
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13. The current situation of absence of specific
labelling thresholds for seeds weakens particularly the competitiveness=
of
agricultural sectors in regions with a high concentration of the produc=
tion
of GM crops.
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I somewhat agree
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14. In the absence of thresholds, no GMO presence =
is
tolerated without labelling, encouraging conventional and organic seed =
to
be as "non-GM" as possible. Establishing thresholds may have =
an
impact on organic and conventional producers.
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I strongly agree
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/o:p>
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15. If you are aware of specific research or studies about the
economic and social impacts for operators of the current situation of
absence of specific thresholds, please provide us with additional
information. Please be specific.
The field is limited to 250 characters
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Questions states this should be completed if we =
are
aware of specific studies.
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Please give briefly further comments, if any, on the economic and
social impacts for operators of the current situation of absence of
specific thresholds for the labelling of approved GM seeds in
conventional seed lots.
The field is limited to 200 characters
In case that you wish to submit full size case studies or repor=
ts,
please see the instructions contained in the information tag below on=
how
to submit your material.
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All stakeholders benefit from stringent seed pur=
ity
provisions, particularly when they produce GM free produce and
products.
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/o:p>
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IV. Economic and social impacts for operators of t=
he
establishment of specific thresholds for the labelling of authorised GM
seeds in conventional seed lots
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16. Costs for seed industry will be higher as the
threshold level approaches the level of detection.
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I somewhat agree
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/o:p>
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17. Costs for farmers in meeting the 0.9% threshol=
d for
GM food and feed will be lower as the threshold level approaches the le=
vel
of detection.
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I somewhat disagree
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18. If you have any data on the social and economic impacts for
operators of the establishment of specific labelling thresholds, plea=
se
provide us with additional information. Please be specific.
The field is limited to 300 characters
In case that you wish to submit full size case studies or repor=
ts,
please see the instructions contained in the information tag below on=
how
to submit your material.
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The 0.9% labelling is a maximum not a target and=
it
should not be used with regard to seed. The presence of GM in seed is
technically avoidable.
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Question 19: Considering maize as a case study, pl=
ease
indicate your level of agreement with the possible specific labelling
thresholds below:
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Threshold of 0.1%
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I somewhat agree
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Threshold of 0.3%
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I strongly disagree
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Threshold of 0.5%
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I strongly disagree
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/o:p>
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Please give further comments, if any, on the economic and social
impacts for operators of the establishment of specific thresholds for=
the
labelling of authorised GM seeds in conventional seed lots.
The field is limited to 200 characters
In case that you wish to submit full size case studies or repor=
ts,
please see the instructions contained in the information tag below on=
how
to submit your material.
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The meaning of these thresholds is not clear -
procedures are vital in making judgements.
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V. Other impacts of establishing specific threshol=
ds for
the labelling of authorised GM seeds in conventional seed lots
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20. Establishing specific thresholds for the label=
ling
of authorised GM seeds in conventional seed lots would result in an
increasing uptake of GM crops in Europe.
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I neither agree nor disagree
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21. If a threshold is established well above the
analytical detection limit, a greater number of GM plants will fall out=
side
the mandatory monitoring, labelling and traceability requirements and m=
ay
lead to increased dissemination and persistance
of GM plants in the environment with the possibility of effects on
biodiversity and long-term effects on human and animal health and the
environment.
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I strongly agree
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22. If you are a representative from a national
competent authority, could you please appreciate/evaluate the impact of=
the
establishment of thresholds in your administration in terms of necessary
additional capacities and administrative costs?
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I don’t know
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23. Can you indicate other impacts that the establishment of
thresholds may have? If you are aware of related studies or research,
please provide us with additional information.
The field is limited to 300 characters
In case that you wish to submit full size case studies or repor=
ts,
please see the instructions contained in the information tag below on=
how
to submit your material.
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Non-GM producers and stakeholders, would be adve=
rsely
affected by the use of any ‘detectable level’
threshold.
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Please give briefly further comments, if any, on other impacts of
establishing specific thresholds for the labelling of authorised GM s=
eeds
in conventional seed lots.
The field is limited to 200 characters
In case that you wish to submit full size case studies or reports,
please see the instructions contained in the information tag below on=
how
to submit your material
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There appears to be a disregard for non-GM produ=
cers
and stakeholders, many of whom would be adversely affected by the use=
of
any ‘detectable level’ threshold.
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Feedback to this Consultation
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Have you found this questionnaire satisfactory? Pl=
ease
tick the appropriate button below.
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No – other
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If you have answered ‘No – otherR=
17; to
the Question above, please specify your reasons, using the box below.=
The field is limited to 150 characters
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Ambiguous statements. In some questions, the same
intention could be represented by the diametrically opposite
response.
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Case Number
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175501854151715507
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