Genetic Technologies (Precision Breeding Techniques) Bill: a call for sector support
Soil Association Certification are calling on our clients and other trade partners to help us raise awareness of the potential impacts of the Genetic Technologies (Precision Breeding Techniques) Bill on both the organic sector and wider UK agri-food.
Updated 12th October 2022
We now ask for your help in taking action to prevent the Bill being passed in its current form.
The Bill seeks to change regulation of genetic technologies for England and will remove some of the current regulatory oversight and safeguards. This will be a risk to all regions of the UK.
The full economic impact of the Bill has not been considered and the UK Government have indicated that their preferred route is to undertake risk assessment only after the Bill has passed and during implementation. The Bill, in its current form, has the potential to significantly impact the organic sector and beyond. As such, we do not believe it is acceptable that the risk assessment will be made available for scrutiny only after the Bill has passed and during regulatory implementation.
Download our letter template and write to your MP
How the Bill needlessly threatens UK businesses.
The Bill aims to exempt new genetically engineered organisms, defined under the Bill as ‘Precision Bred’, from the current Genetically Modified Organism regulations.
No provision is currently made for mandatory end-to-end auditing of these newly defined organisms which has long been a requirement for Genetically Modified Organisms (GMOs).
This creates a high uncertainty as to whether the EU will use this difference to block trade with the UK. But a future block to trade is a significant risk for the organic sector, worth over £3 billion, where international standards are likely to continue to exclude these new organisms.
Voluntary supply chain tracking will not solve this. Yet a solution is simple and elegant: a mandated requirement for traceability of these products to enable end-to-end auditing. There are already systems in place for farm to fork product traceability in many sectors, including those already in place for Genetically Modified Organisms. These could be quickly and painlessly adapted to accommodate this new category of organisms for trading purposes.
What is end-to-end auditing?
It allows something to be tracked from farm to fork, through-out supply chains. It is used for transparency, trade and to trace back any emerging issues when necessary. Thanks to the age of big data, it is seen as an increasingly useful and necessary tool, even to track which farm an ingredient came from.
What if the EU also deregulates similar genetically engineered organisms?
Even if our main trading partner, the EU, takes forward GMO deregulatory proposals, the definition as to what GMOs are exempt is likely to differ from that in the Bill. Legal uncertainty surrounding the current definition in the current version of the Bill only increases the possibility of this outcome.
Furthermore, it is likely that end-to-end auditing of any new category of organisms will still be required. For the organic sector, international standards will continue to exclude the organisms.
What organisms fall into the scope of this bill?
It would apply to plants, and later, to animals. This is not limited to agriculture, so could include ornamental plants, trees and pets. Organisms exempt would be identified by a committee of genetic experts to have met the term “could have resulted from” “natural transformation” or other “traditional processes”. This includes the use of chemicals or radiation to induce desirable mutations (mutagenesis) These organisms would be redefined into a new category, termed by the Bill as ‘precision bred’.
If the EU does deregulate gene editing, it may not follow the definition within the Bill. The definition in the Bill will allow for any genetic change that could have happened with traditional breeding methods over any amount of time. Considering the incredible evolutionary diversity present on the earth, almost any genetic change is possible, given enough time. Therefore, this definition has been argued to have high amounts of legal uncertainty[1] and may let through novel changes that go above and beyond the Bill’s intended meaning.
[1] Evidence from QC Dr. Edenborough at the committee stage.
What are we asking the government to do?
We are shocked that the Government has failed to appropriately assess the economic impact of this Bill, which is a huge risk to British businesses. As a minimum, we are now calling for the UK Government to progress amendment 7 to the Bill which would ensure provision for traceability of these precision bred organisms.
What can I do?
We are asking our clients to share our concerns with their MP and ask that their MP press the government make the appropriate amendments to the Bill.
We have attached a template letter to use when writing to your MP, the content of which is based on a communication recently sent to the Secretary of State for Environment and Rural Affairs on behalf of the organic sector.