Consultation on the ‘New Breeding Technology Act’ in Switzerland

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New GE techniques
Bildquelle: Stephanie Bertot-Molion auf Pixabay

No scientific basis for a special law

Even 'new' genetic engineering is still genetic engineering; the term 'new breeding technologies' is misleading, as is the justification for a special law.

With the proposed 'Federal Act on Plants from New Breeding Technologies' (the Breeding Technology Act, or NZTG for short), the Federal Council is accommodating the genetic engineering lobby's wish to avoid regulating organisms modified by targeted genetic engineering techniques (such as CRISPR-Cas9) under the existing Genetic Engineering Act (GTG). However, this would be problematic both legally and scientifically.

Here's a summary of our arguments:

  • As the Federal Council itself stated, the technologies of concern are genetic engineering processes, and the resulting organisms are genetically modified organisms (GMOs), from both a technical and legal perspective. This is in line with the assessment of the European Court of Justice, which in a judgment of 25 July 2018 in Case C-528/1627. Since there is already a law governing GMOs in the form of the Genetic Engineering Act (GTG), the present proposal constitutes a duplication of legislation.
  • The designation of the proposed legislation as 'plants from new breeding technologies' is deceptive for a number of reasons. The term ‘breeding technologies’ obscures the fact that these are genetic engineering processes, and it potentially includes technologies that are not covered by the wording of the law. The misleading title of the law, coupled with a lack of conceptual precision in its text (e.g. how long are 'new' breeding technologies considered 'new'?), undermines both legal certainty and consumer freedom of choice. From a scientific and legal point of view, if something is genetically engineered, it must be labelled as such.
  • CSS rejects the envisaged harmonisation with EU legislation on this matter. NGT-1 plants must be regulated as genetic engineering in Switzerland. They must undergo an environmental risk assessment and be labelled along the entire value chain, regardless of EU regulatory developments. The NGT-1 to NGT-3 categories are primarily regulatory constructs — the arbitrary "up to 20 modifications" threshold is not scientifically justified. Risk and equivalence should be based on phenotype, ecological function and genomic context, not the number of base pairs altered.
  • The present draft regulation cannot guarantee GMO-free agriculture and production in Switzerland. Given the practical, economic and ecological obstacles, the coexistence of genetically modified and non-genetically modified plants is hardly feasible.
  • The explanatory report of the Federal Office for the Environment uncritically adopts the hype and the often untested and unsubstantiated promises surrounding targeted genetic engineering techniques. It is not clear on what basis the Federal Council assumes that their use will ‘make agriculture more sustainable and increase the resilience of crops to climate change’. The question of the added value of plants produced using targeted genetic engineering techniques must be viewed extremely critically from both an ecological and an economic perspective: it must be defined much more clearly, must not be based exclusively on laboratory data, and must be reviewed at regular intervals. In addition to the speculative added value, the risks associated with the technology must also be identified and reviewed periodically.
  • Overall, the NZGT draft, which was created under intense lobbying pressure and was not carefully thought through, is unacceptable in its current form. If the goal of a separate authorisation regulation for targeted genetic engineering procedures is to be pursued, it must be presented as part of a revision of the existing Genetic Engineering Act (GTG). Any such revision of the GTG must take into account the constitutional requirements (Art. 120 BV) and the legal requirements (Art. 37a para. 2 GTG). In accordance with the precautionary principle, it must place the general interest in an intact environment and human health above speculative hype (which also extends into science) and market forces, which regularly push for the deregulation of technologies for profit reasons and thus also evade their responsibility for possible damage, the risks of which are usually far greater than is commonly portrayed. 

CSS Consultation Response (German) | Stellungnahme (PDF)

CSS Consultation questionnaire (German) | Fragenkatalog Vernehmlassung (PDF)


Science and policy in times of multicrisis and dissent

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Events

Athens | 15–17 May 2025

Conference on "Science and policy in times of multicrisis and dissent"

What are the roles of scientific evidence and advice and of corporate and non-commercial societal interests in decision-making? In what ways do unaccountable economic actors, interests and assumptions shape policy and scientific considerations about what is possible and what is needed? Under what conditions can existing public problem-definitions, as well as just decisions on them, be made scientifically and democratically legitimate? How should scientific advisors and policy-makers respond to scientific disagreements? And what can responsible scientists do when governments adopt measures intended to shut down or at least control scientific dissent, when it challenges dominant official narratives? Questions like these will be at the heart of the three days of reflection at this conference. By promoting open debate and reflection, this conference aims to engage with a plurality of perspectives on the science–policy interface.

When: Thursday 15 May – Saturday 17 May 2025

Where: Academy of Athens, Athens, Greece

Co-organisers: European Network of Scientists for Social and Environmental Responsibility, Critical Scientists Switzerland & Academy of Athens

Funders: Mariolopoulos-Kanaginis Foundation for the Environmental Sciences , Fondation Charles Léopold Mayer pour le progrès humain, Triodos Foundation & Zukunftsstiftung Landwirtschaft – GLS Treuhand

For more information, see here: https://ensser.org/events/2025/conference-programme-science-and-policy-in-times-of-multicrisis-and-dissent/

06/WIM CARTON on Carbon Dioxide Removal and Climate Overshoot

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BEYOND THE FIX Podcast
Wim Carton Portrait

 

 
This episode focuses on 'negative emission' technologies, which aim to remove carbon dioxide from the atmosphere, either indirectly by influencing natural processes or directly through technology.
 
Our guest, Dr Wim Carton, points out how carbon removal is closely linked to the idea of 'overshoot': an actively advocated agenda for dealing with the current rush to climate catastrophe. Overshoot basically means that we accept to temporarily cross critical temperature limits and then these technologies will solve the problem of excess carbon dioxide in the atmosphere at some point in the future. It's part of the IPCC scenarios and the Paris Agreement, and it is implicitly justifying the continued use of fossil fuels. Wim also introduces us to IAMs, Integrated Assessment Models, whose underlying economic assumptions reinforce the logic of postponing fossil fuel cuts by making them seem more expensive than fixing them later through negative emissions.
 
Wim Carton has just written a book on the subject (with Andreas Malm) called "Overshoot: How the World Surrendered to Climate Collapse". He is a human geographer at the Centre for Sustainability Studies at Lund University and has been studying the political economy of climate change mitigation for the past decade. His research has examined the impact of 'market-based mechanisms' on climate policy.
 
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05/ANGELIKA HILBECK on The Politics and Promises of Genetic Engineering

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BEYOND THE FIX Podcast
Rony Emmenegger Portrait

 

 
In this episode we focus on genetic engineering, which is often presented as a necessity for climate-resilient agriculture.
 
Our guest, Dr. Angelika Hilbeck, takes us on a fascinating journey through the early stages of genetic engineering in agriculture, highlighting the flaws in the very essence of the approach – its reductionism of ecological relationships – which has not changed with CRISPR/Cas and new genomic engineering techniques. She explains how the promises of genetic engineering have been consistently exaggerated, and despite vast investments in the development of GM crops for agriculture, they have fallen short of expectations. She asks whether it is not only the considerable ecological risks of the technologies that make them a questionable bet for the future of agriculture, but the poor ratio of investment to results of the whole biotech endeavour.
 
Angelika Hilbeck is an agro-ecologist and entomologist with over 30 years experience in the study of genetically modified crops and their impact on the environment. She has done pioneering work on the ecology of GM crops and, more recently, alternative agro-ecological approaches in Eastern Africa. In 2024, she retired from 25 years of research and teaching at the Institute of Integrative Biology at ETH Zurich.
 
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04/RONY EMMENEGGER on Deep Geological Repositories for Solving the Nuclear Waste Problem?

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BEYOND THE FIX Podcast
Rony Emmenegger Portrait

 

In this episode, we focus on one of the most challenging problems generated by human technology: where can highly radioactive waste from nuclear energy production be safely disposed for the next one million years?
 
Our guest, Dr. Rony Emmenegger, is a political geographer with a keen interest in the governance of human-environment relations. His work focuses on how knowledge of the deep geological underground is produced in the case of nuclear waste governance and how it is articulated and contested in the public sphere.
 
Through the lens of political geology, Rony tells the story of the long search for a deep geological repository in Switzerland (and beyond) and its crucial socio-political implications. He introduces us to the concept of passive safety, which builds on the idea that responsibility for radioactive waste can be delegated to geological formations underground to ensure safety in the long term. Given the widespread social and political attitude to rely on techno-scientific expertise, he urges us to move away from asking whether or not a problem can be solved – in this case by deep geological repositories – and to focus on what kind of science is actually involved.
 
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03/CHRISTINE VON WEIZSÄCKER on Why Technofixes Won’t Save Us

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BEYOND THE FIX Podcast
Christine von Weizsäcker Portrait

 

In this episode we look at the technofix narrative, its relationship to innovation and precaution, and ask why it has become so prevalent when it comes to addressing (socio-)ecological problems. We also discuss alternatives and why the complexity of living systems requires different approaches.
 
Our guest, Christine von Weizsäcker, is a biologist and President of Ecoropa – the European Network for Ecological Reflection and Action. She has been involved in the negotiations of the UN Convention on Biological Diversity, its Protocols and in the follow up to the Earth Summit in Rio for many years. She is a vocal advocate of the Rio principles of precaution, polluter-pays and public participation.
 
Christine introduces us to the important role that technofixes have played in environmental policy, which is linked to a narrow understanding of innovation. She calls for critical, i.e. differentiating, and multidisciplinary approaches. She also points to importance of considering long-term and far-reaching impacts of scientific and technological proposals that promise to solve singled out aspects of the multiple and interlinked current crises. Christine also shares valuable insights into the power of framing in public perception and politics.
 
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