EuropaBio position: Principles on ‘GM free’ labelling

GM-free labelling is more and more widely used in some EU Member States. In Germany alone, GM free labelled products worth 4.4 billion Euros are expected to be sold in 2017. According to the EU Commission, ‘such voluntary labels are possible provided that they are not misleading for the consumer’. This position paper outlines important principles which EuropaBio believes should guide future labelling discussions.

1. No need for ‘GM free’ labelling in the EU

Caution is recommended by most actors in the food supply chain when it comes to the introduction of additional labelling schemes. Labels rarely lead to a change in consumer behaviour, and they lose their intended informative value in the current inflation of competing and overlapping schemes. There is already a legal requirement to label GM content. If there is no such label (‘contains genetically modified organisms’) on a product, it means that the product contains no more than adventitious and unavoidable levels of EU approved GMOs below 0.9%. The presence, at the same time, of positive and negative GM labelling is not desirable. In addition, a prohibition of the use of GMOs is already a criterion for organic production, which also has its own label.

2. Against the spirit of existing legislation and standards

The harmonised EU rules for labelling of food and feed explicitly acknowledge that certain traces of GMOs in products may be adventitious or technically unavoidable and state that such presence of GMOs should therefore not trigger labelling requirements. Codex Alimentarius (the FAO/WHO food standards mechanism) clearly states that there is no intent “to suggest or imply that foods derived from modern biotechnology are necessarily different from other foods simply due to method of production”.

3. ’GM free’ labelling is a mere marketing tool

Priority should be given to the labelling of health related information (allergens, calories etc). The applicable tolerance threshold for the existing mandatory GM labelling scheme under EU law (0.9% both for conventional and organic produce) takes account of the fact that the presence or not of EU approved GMOs in food has no connection with food safety concerns. This is because the GM events in question have undergone rigorous safety assessments by public authorities in the EU and third countries before entering the food supply chain. Many private operators have put marketing labels in place on a variety of issues. The primary role of public administration should be to ensure that voluntary labelling schemes do not contradict existing legal requirements, for example in terms of misleading the consumer, and that they are accurate, verifiable and relevant.

4. ’GM free’ labelling adds to confusion

The declared intention of several existing schemes (whether private or publicly regulated) is to promote consumer choice. However, ‘GM free’ labels provide only limited additional information which could actually contribute to reaching this objective. The proposal submitted to the consumer by way of ‘GM free’ labelling is to actively avoid an entire technology, rather than a particular ingredient which carries an objective risk (for example information related to hazelnut or sugar content, which may be immediately relevant for persons with allergies or diabetics). Rather than a contribution towards informed choice, ‘GM free’ labelling runs the risk of adding to already existing confusion about the safety and sustainability of GMOs and biotechnology more widely.

5. ‘GM free’ labelling is often misleading

‘GM free’ schemes do not usually even keep the promise they postulate. For example, under the German legislation, meat and animal derived products (such as milk, eggs) can be labelled as ‘without gene technology’ (‘ohne Gentechnik’) even if the farm animals were fed GM feed during part of their lives. Feed additives and pharmaceuticals produced with genetically engineered micro-organisms are equally permitted under the scheme.

6. ‘GM free’ labelling is expensive and difficult to enforce

The global uptake of biotech crops is rapidly increasing. Around 13 % of global crop production and a much larger share of those agricultural commodities traded internationally are biotech today. Segregating commodities in complex and inter-connected supply chains always comes at a cost, and these costs are driven up when unrealistic thresholds for admixture are applied. Lowering the 0.9% threshold for certain product categories, even on a voluntary basis, would also create additional and needless costs and problems for the coexistence of organic, conventional and GM crops on the fields. Any labeling provisions should be supported by reliable, validated methodologies for detection of transgenic proteins or DNA. Complex process based criteria concerning meat and animal derived products are not measurable/ detectable in the labelled product. This kind of criteria – in addition to often being misleading – is another factor driving up costs for the supply chain and consumers, and making market surveillance much more challenging.

About EuropaBio

EuropaBio, the European Association for Bioindustries, promotes an innovative and dynamic European biotechnology industry. EuropaBio and its members are committed to the socially responsible use of biotechnology to improve quality of life, to prevent, diagnose, treat and cure diseases, to improve the quality and quantity of food and feedstuffs and to move towards a biobased and zero-waste economy. EuropaBio represents 79 corporate and associate members and bio regions, and 17 national biotechnology associations in turn representing over 1800 biotech SMEs.