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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.
Analysis statement of ENSSER on the European Commission’s leaked new GM proposal
ENSSER states: "The EU Commission’s proposal is scientifically unacceptable, removes the provisions of the precautionary principle and puts the public and environment at risk. Critical scientific expertise and its supporting scientific evidence was completely ignored. The proposal follows exclusively the guidance and assertions of the public and private biotechnology sector – and is therefore to be classified as one-sided. In our analysis statement, we briefly explain why this is so – with scientific reasoning and evidence. We focus on the Annex I only for now."
This statement was sent to members of the European Parliament and competent authorities in several EU member states on July 4, 2023.
The SAG also published a reaction here and started a campaign to respect the consumers' choice. Our board member Angelika Hilbeck was interviewed on Swiss national television about the latest push to deregularise NGTs. And the Corporate Europe Observatory reacted here.
Critical Scientists Switzerland published a statement in response to the Federal consultation process on the extension of the Swiss gene technology moratorium.
The Critical Scienstists Switzerland welcome the planned extension of the moratorium. We fully agree with the Federal report on the planned extension that organisms produced with new gene editing technologies are subject to the current legislation on gene technologies (Gene Technology Act) and are regulated accordingly (precautionary principle, risk assessment, step-by-step procedure, labelling, and monitoring). Despite some inconsistencies of the Federal report highlighted in our statement, Critical Scientists Switzerland generally support the current government policy.
In their letter, UCCSNAL question the safety of CRISPR/Cas9 and other new biotechnologies as well as the influence of science in the decision-making process regarding the adoption of the new technologies. They fear that these technologies will further increase monopolistic powers over seeds, land grabbing and migration from the land and also have other, unanticipated impacts.
"The new technologies facilitate faster, more extensive changes in the genetic material of more organisms, and at lower cost", they argue.
UCCSNAL demands a halt of all experimentation in this field. Rather, science should be based on acroecological techniques and local knowledges.
Open letter (English)
Open letter (Spanish)
Subcategories
New GE techniques
In the past decade, various new GM techniques have been developed. These include Oligonucleotide Directed Mutagenesis (ODM), Zinc Finger Nuclease Technology (ZFN) types -1, -2 and -3, TALENs, CRISPR-Cas9, Meganucleases, Cisgenesis & Intragenesis, Grafting, Agro-infiltration, RNA-dependent DNA methylation (RdDM), Reverse breeding, and more recently base editing and prime editing.
It is often claimed by the industry, some public-private research institutes and in the media, that genome editing techniques are more precise and hence safer than common transgenesis and that the products resulting from these techniques contain no foreign DNA and are thus not to be considered GMOs. What has become more precise with genome editing techniques such as CRISPR-Cas is where in the genome a double-strand break is inserted. What happens after the cut, how the cell repairs the double-strand break, and how a gene of interest is inserted, remains, however, still inadequately understood.
Hence, the process has been prone to errors, including the insertion of unwanted DNA-fragments and large DNA deletions or rearrangements, which can ultimately lead to proteins that are altered in their structure as reported in the scientific literature (so called on-target effects). Moreover, a growing number of studies have reported additional DNA cuts at further unintended places (off-target effects), although only a fragment of studies looks for such off-target effects. Furthermore, rarely discussed is that while the techniques have changed, the process of plant transformation has remained largely the same – a gene construct is introduced into a cell using a vector (commonly agrobacterium tumefaciens) or by particle bombardment – the risks basically remain the same as well. (See summary of arguments in "How does 'new genetic engineering' work – and why is it failing to deliver on its promises (in German) or major publication by CSS and others on the issue)
Roundup Ready Crops
Roundup Ready (RR) crops, developed by Monsanto, are crops genetically modified to confer resistance to glyphosate, the declared active ingredient in the herbicide Roundup. That means that farmers can spray their fields with a single herbicide – Roundup, or any other glyphosate-based herbicide, throughout the whole growing season in order to eradicate troublesome weeds and without risking to harm their crops.
The industry claims that this farming system requires less skills and knowledge than the conventional farming system because farmers do not have to select among a range of herbicide active ingredients, carefully time their herbicide application and apply other non-chemical control practices such as plowing, deep tillage or manual weeding. Further promoted advantages and promises by the industry include that RR crops create more yield than conventional crops, decrease farmers input costs by reducing the amount of herbicides sprayed and are safe for humans, animals and the environment.
Upon their commercialisation in the mid-1990s, Roundup ready crops were adopted very quickly and reach saturation today in countries with large-scale industrial agricultural production such as the U.S., Argentina and Brazil. Europe, where family farms prevail, is until today still free from RR crop cultivation and Switzerland has a moratorium on the use of genetically modified organism in agriculture that is valid until the end of 2021. Worldwide, herbicide resistant crops, of which the vast majority are resistant to glyphosate, account for about 84%, of all cultivated genetically modified (GM) crops.
Despite the extensive adoption of RR crops in some countries, the claims made by the industry proved to be short lived or false during the past 20 years.
Bt crops
Bt crops are genetically modified to confer resistance against certain insect pests. The inserted genes were originally identified in the bacterial species Bacillus Thuringiensis (Bt). These bacteria exhibit insecticidal activity by producing different δ-endotoxins (Cry and Cyt toxins). For that reason, Bacillus thuringiensis spp. have long been used in biopesticides. In Bt crops, the insecticides are produced inside the plant and can, unlike traditional insecticides, kill insect pests feeding inside of plant tissues. Moreover, the toxins are not washed off or degrade by UV radiation. This caused concern that eating the crops may have adverse health effects.
The first Bt crop commercially available was Bt potato, resistant against the Colorado potato beetle, in 1995. Commercialisation of Bt cotton and maize followed in 1996. Bt maize is mainly cultivated in the USA, Brazil, Argentina and South Africa. A small quantity is also grown in Europe, mainly in Spain. Bt cotton is most common in India and China where it is the only GM crop authorised for cultivation.
Today, insect resistance is the second most common trait used in genetically modified (GM) crops, after herbicide tolerance, with 43% of all cultivated GM-crops being insect resistant.
The industry promised that Bt crops would result in higher yields and decrease insecticide applications. However, pests with resistance against certain Bt toxins have become a huge problem today. Low crop yield, high seed prices and crop loss due to resistant insect pests have been associated with farmers’ suicides in India.
Golden Rice
Rice (Oryza sativa) has been genetically modified to produce beta-carotene in order to improve the supply of vitamin A. Carotenoids are a precursor of vitamin A and give the rice its yellowish color and the name Golden Rice. Naturally, peeled rice grains contain no carotenoids.
With rice as a staple food for over half the world's population, the so-called Golden Rice should help combat vitamin A deficiency, a serious problem in different developing countries.
The International Rice Research Institute (IRRI) is currently reviewing the characteristics of the genetically modified rice, including its safety and suitability for human nutrition.
Despite 25 years of research and development, no Golden Rice-varieties are available today that are suitable for commercial cultivation.