Until 17 March 2021, the UK Government is hosting an online consultation on the regulation of genetic technologies and, notably, the technique of ‘gene editing’. Speaking at the Oxford Farming Conference, Environment Secretary George Eustice put forward the government’s position that “gene editing has the ability to harness the genetic resources that mother nature has provided, in order to tackle the challenges of our age”.
The Landworkers’ Alliance urges its members to provide an alternative perspective to this important consultation, to allow for a more balanced debate on the pros and cons of gene editing and the use of genetically modified organisms (GMOs) in food, feed and farming.
We invite our members to familiarise themselves with the consultation that is available here. We are looking to submit a response to the consultation in the week of the 15th of February, which will be published on our website and can be used as a template for individual responses. We will also make available a draft letter that can be send to your MP.
For now, here’s a background briefing on the issues.
GMOs, Gene Editing and the UK’s Post-Brexit Regulations
A GMO is a plant, animal or microbe whose genetic material has been altered in a laboratory to include desirable traits. First generation GMOs have had foreign genetic material inserted from genetically similar or different species, whereas newer gene editing techniques, such as CRISPR, allow for targeted changes to the organism’s own DNA (mutagenesis).
The current legislation for authorising the use of GMOs in the UK’s nations consists primarily of retained EU law, which outlines rules for the assessment and management of potential risks. Although the EU legislation itself does not include any specifics on gene editing, a case before the Court of Justice of the EU in 2018 (C-528/16) – with the French sister-organisation to the Landworkers’ Alliance as one of the main parties – clarified that the strict procedures should, in principle, also apply to gene editing. The UK government has characterised this ruling as being “flawed and stifling to scientific progress” and sees the public consultation as a first step for the design of a radically different post-Brexit regime.
Scientific, Economic and Social Questions
Although the UK government has presented the consultation as an opportunity for the sharing of all views on gene editing and GMOs, regrettably the option of deregulation seems to be at the top of its agenda. Yet, whilst DEFRA is looking for a “robust, science-based approach”, the science on the advantages and disadvantages of gene-editing is not straightforward. Practical experiences with these novel techniques are limited and alterations of DNA can have unexpected environmental and health effects. These include impacts on wildlife and notably non-targeted organisms, and reductions in agricultural biodiversity.
The topic also raises many economic, societal and trade-related issues. As explained by Dr Antonio Onorati from the European Coordination Via Campesina, these include financial impacts related to contamination, which affect the ability of farmers to sell under organic or GM-free logos. And “biotechnology also threatens international farmers’ rights which give farmers the freedom to select, cultivate, harvest and exchange uncontaminated seeds.”
Furthermore, the EU is still debating the regulation of gene editing and the UK may lose access to the high-margin EU agricultural market if it takes a vastly different approach. This would also likely mean that the UK’s focus would shift to different markets (like the US or China) which are dominated by large scale producers, putting further pressures on British family farms and smallholders. Moreover, the topic of GMO is a key area of divergence in policy between Westminster and the devolved nations and Scotland and Wales traditionally support a cautious approach. Deregulation may therefore cause significant disruption of business within the UK market and may put stress on internal relationships due to the workings of the Internal Market ACt.
A cautious approach that seeks to protect the public and the environment against the potential risks of genetic technologies and which does not only consider economic gains but also environmental and social impacts, is in line with fundamental principles of environmental law (e.g. precautionary principle, prevention principle, principles of sustainable development).
An Alternative Vision for Our Food System
As a union representing small-and medium-sized farms, we are very disappointed to see that the UK government has started what could and should have been an open debate on gene editing and GMOs with a strong bias in favour of deregulation. Regulation provides important safeguards against potential environmental and health risks and we feel strongly about keeping those checks in place.
The LWA believes that the government is deliberately downplaying the nature of gene-editing by using flawed comparisons with traditional breeding. We do not see gene-editing as being substantially different from GMOs and both pose dangers to organic and agroecological farming, due to potential impacts on biodiversity, risks of cross-contamination and pressures on local and organic markets.
Recently, the Council of the EU considered that “industrial agriculture […] and other types of environmental degradation increase the risk of future pandemics and need to be tackled”. A focus on genetic technologies, as an element of industrial agriculture, is not what we want for the UK’s food system as it will further concentrate power with agri-businesses. Instead, we believe that resources and efforts should be targeted to strengthen the agroecological movement in the UK, which seeks to empower farmers and communities.
Miranda Geelhoed, Policy and Campaigns Coordinator for Scotland at the Landworkers’ Alliance, said:
“Ultimately, we believe that the consultation should not just be a technical discussion. There is a bigger question whether gene-editing and GMOs more broadly are compatible with a sustainable vision for our food system. A comprehensive answer to that question would greatly benefit from the input of our members, small- and medium-scale farmers, who are the stewards of the land. And although DEFRA’s proposals will only cover England, the impacts will be felt across the UK. It is important for farmers and other actors in Scotland, Wales and Northern Ireland to also have their voices heard”.
- ‘The regulation of genetic technologies. A public consultation on the regulation of genetic technologies’ (DEFRA, January 2021)
- ‘How to respond to the UK consultation on the deregulation of gene editing’ (Beyond GM, 22 January 2021)
- ‘Public consultation on genome editing is launched’ (Beyond GM, 7 January 2021)
- ‘GeneWatch UK’s response to Defra’s consultation on deregulation of gene edited organisms’ (GM Watch, January 2021)
- ‘Why Genome Edited Organisms are not Excluded from the Cartagena Protocol on Biosafety’ (Third World Network, 11 December 2020)
- ‘Stakeholder consultation on new genomic techniques to contribute to a Commission study requested by the Council’ (European Coordination Via Campesina)
- ‘A Bigger Conversation. Opening up the dialogue on food, farming & genetic engineering’, website
- ‘Organisms obtained by mutagenesis are GMOs and are, in principle, subject to the obligations laid down by the GMO Directive’ (CURIA, 25 July 2018)