Rothamsted submission to Food Standards Agency consultation on precision bred organisms

The Genetic Technology (Precision Breeding) Act (2023) is a ground-breaking law, the first time in more than 20 years that legislation has been brought forward which seeks to enable the use of genetic innovation in agriculture. It opens up major opportunities to deliver on the Government’s policy objectives for a healthier, safer and more sustainable food supply.  Rothamsted Research has previously made public its support for this seismic shift in regulation and is pleased to contribute evidence to advance this change. Rothamsted Research is now equally happy to provide its input into the Food Standard Agency’s consultation on how best to implement the Act with respect to food and feed marketing. 

Rothamsted Research believes that precision bred organisms (PBOs), as defined by the Act, (such as the gene-edited wheat and camelina being trialled on Rothamsted Research's farm) are not GMOs and as such, should not be subject to the same over-burdensome regulation that has hindered the deployment of GM crops. The overwhelming scientific consensus is that the products of precision breeding pose no greater risks than products obtained through conventional breeding methods. Globally, PBOs are poised to become a significant part of the feed and food chain.

Rothamsted Research believes that PBOs will play a key role in helping the planet face the multiple challenges confronting us all, including resilience to ever-increasingly volatile climate change and food security (including improved nutrition and safer food).  However, this will only be possible if the regulatory pathway for the implementation of the Genetic Technology Act is appropriately enabling. In that respect, Rothamsted Research broadly welcomes the approach proposed by the FSA, which builds on the two-tier approach adopted by Defra in their certification of PBO status. 

Rothamsted Research would emphasise the importance of ensuring clarity for developers, to ensure that useful innovations advance from prototype to product in a timely and economically viable fashion. Vague and open-ended requirements for regulatory dossiers represent significant impediments to commercialisation and should be avoided, not least of all given the scientific consensus on the safety of PBOs. 

It is critical that the FSA’s implementation of the Genetic Technology Act embraces the spirit of this legislation to enable both innovation and economic development.