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B4FA evidence to the House of Commons Select Committee inquiry on EU regulation of the life sciences

 In January 2016, the UK Parliament’s Science and Technology Committee launched an inquiry into the impact of European Union (EU) regulation and policy on the UK life sciences. The inquiry will look at how EU legislation and regulation can best facilitate, and avoid impeding, collaboration and innovation in life sciences with particular reference to the UK life sciences sector. The inquiries are important because they are carried out by a committee of MPs from all political parties, gather evidence from leading experts and are widely referred to. They have to be responded to by the UK Government. The B4FA submission focuses specifically on the issue of the influence of EU regulation on UK life science research on crops directed to Africa farmers. It concludes “It is imperative that the UK Government works to support research on GM and other recent genetic techniques and their application in the UK and internationally especially with the EU and its institutions and in Africa.” The submission was drafted by Dr David Bennett with the help of many B4FA and other experts in the UK and Africa.

House of Commons Select Committee inquiry on EU regulation of the life sciences
Written evidence submitted on behalf of Biosciences for Farming in Africa

Biosciences for Farming in Africa (B4FA) is an independent not-for-profit initiative with no commercial interests based in Cambridge which works to provide balanced, scientifically-based information on best practice, innovation and entrepreneurship to enable African farmers to unlock the continent’s agricultural potential. [*]

This submission will consequently focus specifically on the issue of the influence of EU regulation on UK life science research on crops directed to Africa farmers.

1. Both the House of Commons and the House of Lords Select Committees on Science and Technology have previously inquired into and published reports bearing on this issue as have other authoritative organisations including such as the European Academies Science Advisory Council and the Montpellier Panel:

  1. The House of Commons Select Committee report on “Advanced genetic techniques for crop improvement” was published on 15 February 2015. It received a response from the Government published on 21 October 2015 to which the Chair commented “GM generates polarised views, both in the UK and across Europe. The Government’s response to the Committee’s report acknowledges that the politics of GM are acting as a barrier to developing novel crop varieties. The Government commits to challenge ‘unjustifiable obstacles’ but in fact evidence based EU decisions in this area are hard to come by. The impact of the latest proposals from Europe to allow individual states to restrict GM, not just for cultivation but now also for use in feed and food, requires proper scrutiny. [†] The S&T Committee will be examining this area through a public ‘evidence-check’ over the next few months.” [2]
  2. The House of Lords Select Committee made extensive criticism in its report published on 17 December 2015 on the impact of EU regulations on research on genetically modified (GM) insects [‡] in the UK and the implications of these regulations for developing countries such as in Africa. [3] It concluded inter alia that “We are concerned that the application of GM insect technologies in the countries whose need is greatest may be affected by a lack of international guidance and leadership on the governance and regulation of these technologies. We recommend that the Government, in light of its strong commitment to international development, works through international organisations to help to address challenges of international guidance and leadership.”
  3. The European Academies Science Advisory Council (EASAC) in its 2013 report “warns of the grave scientific, economic and social consequences of current European Union policy towards GM crops. In the strongest terms, the report also argues that Europe must reassess the accumulated evidence and the new advances since EU policy affects not only Europe, but also the developing world and Africa in particular.” [4]
  4. The Montpellier Panel’s two reports, “Sustainable Intensification: A New Paradigm for African Agriculture” [5] in 2013 and “The Farms of Change: African Smallholders Responding to an Uncertain Climate Future” [6] in 2015, respond to “Today, the world is searching for solutions to a series of global challenges unprecedented in their scale and complexity: food insecurity, malnutrition, climate change, rural poverty, environmental protection all among them. Sub-Saharan Africa is particularly vulnerable, with both supply and demand challenges putting additional pressure on an already fragile food production system.”
  5. Other relevant authoritative reports include the Royal Society’s “Reaping the benefits: Science and the sustainable intensification of global agriculture” in 2009 [7] and the Council for Science and Technology’s 2014 “GM Science Update”. [8]

2. The forecasts for the inextricably linked scourges of food insecurity and poverty in Africa are bleakly familiar:

  1. According to the United Nations “The world population is projected to increase by more than one billion people within the next 15 years, reaching 8.5 billion in 2030, and to increase further to 9.7 billion in 2050 and 11.2 billion by 2100” and “More than half of global population growth between now and 2050 is expected to occur in Africa. Africa has the highest rate of population growth among major areas, growing at a pace of 2.55 per cent annually in 2010-2015. Consequently, of the additional 2.4 billion people projected to be added to the global population between 2015 and 2050, 1.3 billion will be added in Africa.” [9]
  2. The World Bank reported that “The latest data suggest that extreme poverty has continued its decades-long descent. Still, poverty remains unacceptably high, with an estimated 900 million people in 2012 living on less than $1.90 a day – the new international poverty line; the projected number for 2015 under the new line is 700 million people. Poverty also is becoming increasingly concentrated in Sub-Saharan Africa, where its depth and breadth remain an overriding challenge.” [10]
  3. The Food and Agricultural Organization of the United Nations (FAO) estimates for 2014 to 2016 the undernourishment of 232.5 million people (20.0%) in the African continent and of 220.0 million (23.2%) in Sub-Saharan Africa. [11]
  4. The FAO stated in 2012 that “Out of the 2.5 billion people in poor countries living directly from the food and agriculture sector, 1.5 billion people live in smallholder households.” and “Smallholders provide up to 80 percent of the food supply in Asian and sub-Saharan Africa.”

3. GM and other recently developed genetic approaches combined with marker assisted breeding [§]< [12]/a> have the potential for contributing significantly to the reduction of food insecurity and poverty in Africa by increasing crop yields, resisting viral, bacterial, fungal and weed infestations, reducing pesticide and fertiliser use, mitigating the effects of drought, climate change and soil salinity and increasing crop nutritional content. Yet the cultivation of GM crops has developed only slowly in the African continent compared with other parts of the world beyond the EU:

  1. According to the International Service for the Acquisition of Agri-biotech Applications (ISAAA) “in 2014 global biotech crop hectarage continued to grow for the 19th consecutive year of commercialization; 18 million farmers in 28 countries planted more than 181 million hectares in 2014, up from 175 million in 27 countries in 2013” and “Of the 28 countries which planted biotech crops in 2014, 20 were developing and only 8 were industrial countries.” [13]
  2. In Africa during 2014 South Africa grew 2.7 million hectares of GM maize, soybean and cotton, Burkina Faso 0.5 million hectares of GM cotton and Sudan 0.1 million hectares of GM cotton.13
  3. Other African countries such as Kenya, Tanzania, Uganda, Malawi, Mali, Zimbabwe, Nigeria and Ghana have allowed the importation of genetically modified food. [14]
  4. Eight African countries have conducted GM field trials: Burkina Faso, Cameroon, Egypt, Ghana, Kenya, Malawi, Nigeria and Uganda. [15]

4. Research carried out in the UK on crops directed to Africa farmers during recent years includes:

  1. The Department for International Development is a major funder as a member of the Harvest Plus programme together with other donors of both conventional and GM crop research to improve nutrition by developing and promoting biofortified staple food crops that provide higher amounts of vitamin A, iron or zinc. As of 2015, biofortified crops under the Harvest Plus programme have been officially released, or are being grown by farmers under other arrangements, in the eight target countries: Democratic Republic of Congo (iron in beans and vitamin A in cassava), Nigeria (vitamin A in cassava and in maize), Rwanda (iron in beans), Uganda (vitamin A in sweet potato and iron in beans), Zambia (vitamin A in maize), Bangladesh (zinc in rice) and India (iron in pearl millet). [16]
  2. The Department for International Development funded a project on developing GM cassava [17] and with the Royal Society funded the Royal Society-DFID Africa Capacity Building Initiative, currently closed, for water and sanitation, renewable energy and soil-related research. [18]
  3. The John Innes Centre received £6.4 million from the Gates Foundation for GM research on nitrogen fixation in maize so needing little or no fertiliser and benefiting African farmers who cannot afford fertiliser. [19] The Centre and the Biosciences east and central Africa (BecA) research hub in Nairobi have also formed an alliance working on collaborative research projects improving food crops using modern breeding techniques in eastern and central Africa. [20]
  4. The so-called “climate-smart push-pull technology” employing the conventional, not GM, approach of the intercropping of two crops and natural chemicals (pheromones) produced by one crop deterring pests of the other, is being carried out Rothamsted Research funded by the European Union, with additional funding from the Biovision Foundation, Bill and Melinda Gates Foundation and Department of International Development conducted in partnership with Rothamsted Research funded by the Biotechnology and Biological Sciences Research Council (BBSRC). [21] [22]

5. The two main funding bodies through which the UK Government contributes to research on crops directed towards African farmers are the UK Biotechnology and Biological Sciences Research Council (BBSRC) and the European Commission:

  1. The Biotechnology and Biological Sciences Research Council (BBSRC) spends around £445 million per year on research in biotechnology and the biological sciences and supports some 1,600 scientists and 2,000 research students in universities and institutes in the UK. It has set out its position on new and emerging genetic techniques including GM that have the potential to contribute to producing crops with improved performance. As it later stated “Over the coming months BBSRC will be considering ways to engage with the public, civil society, NGOs and businesses to fully understand areas of agreement and concern and BBSRC’s role in moving discussions forward. As part of this process BBSRC’s Chief Executive Professor Jackie Hunter [**] and Executive Director Corporate Policy and Strategy Dr Paul Burrows met with sponsors of the All Party Parliamentary Group for Science and Technology in Agriculture and members of the Supply Chain Initiative on Modified Agricultural Crops (SCIMAC) on Friday 7 August 2015.” [23]
  2. The European Commission published its report “A decade of EU-funded GMO research (2001-2010)”. [24] It later funded the GRACE (GMO Risk Assessment and Communication of Evidence) [25] and AMIGA (Assessing and Monitoring the Impacts of Genetically modified plants on Agro-ecosystems) [26] projects but has not funded research on the development of GM crops themselves for many years.

6. There are undue delays in the authorisation procedure for genetically modified organisms (GMOs) for human food and animal feed in EU Member States (such as the UK):

  1. As of 1 June 2014, 21 safety tested GM crops were reported as being delayed illegally in the EU for a total of 44 years. [27] The European Ombudsman consequently decided that the failure by the European Commission to authorise genetically modified products for food and feed within a reasonable time constituted maladministration because the Commission failed to meet the three months legally binding deadline in the authorisation process required by law. [28]
  2. The European Parliament voted overwhelming on 28 October 2015 by 577 votes to 75 with 38 abstentions to reject a draft EU law enabling any EU member state to restrict or prohibit the sale and use of EU-approved GMO food or feed on its territory because of concern that the law might prove unworkable or that it could lead to the reintroduction of border checks between pro- and anti-GMO countries, and called on the Commission to table a new proposal which it has currently yet to do. [29]
  3. The World Trade Organisation (WTO) reported 10 years ago in 2006 that the European Communities had applied a general de facto moratorium on the approval of biotechnology products which had caused undue delays in the completion of EC approval procedures. [30] [31]
  4. The Fresh Start Group published a report [32]
  5. The Agricultural Biotechnology Council issued a report “Going against the Grain” in 2015 saying “UK farmers are being prevented from accessing global feed markets, jeopardising our world-leading food industry and threatening to push up prices for UK consumers” [33]

7. The hostile political and consumer environment existing in the EU over the last 20 years has had several important consequences for Africa:

  1. The negative and inhibiting effects on research in the EU on crops directed to Africa farmers with potential benefit for significantly improving food insecurity and poverty in the region. There is however no means of monitoring and ascertaining research which has not been undertaken, put on hold or abandoned.
  2. Peer reviewed analysis of the consequences of delaying the introduction of GM Golden Rice (producing pro-Vitamin A to reduce widespread vitamin A deficiency causing blindness) and GM corn, wheat and rice showed that “precaution is very costly” both in human health and to local economies. [34]
  3. Because of the disincentive for research in this area in the EU many leading biotechnology researchers, their research groups and students have long left the EU including the UK for other parts of the world where it is encouraged and supported. [35]
  4. Global agricultural biotechnology companies such as Monsanto and BASF have progressively withdrawn their investment from Europe with consequent loss of jobs and economic revenue in the EU. [36] & [37] It has recently been announced that Syngenta, a Swiss-based multinational agribusiness company with its largest site for R&D at the Jealott’s Hill International Research Centre in Brachnell, Berkshire, is being taken over by the China National Chemical Corp. [38]
  5. Most UK food retailers maintain a non-GM policy although imported GM animal feed is widely used throughout the EU for the production of meat, eggs and other animal products which are sold and consumed. [39]
  6. The activities of anti-GM campaigning groups in Africa creating widespread public, media and political apprehension, misinformation and indeed frequent strong opposition about the safety of GM foods and about the acceptability of their export adversely influencing trade to Europe even though almost all African crops are consumed locally and not exported. [40]

Consequently it is imperative that the UK Government works to support research on GM and other recent genetic techniques and their application in the UK and internationally especially with the EU and its institutions and in Africa.


[*] For information about the Biosciences for Farming in Africa (B4FA) programme and its various activities and publications please see http://b4fa.org/.

[†] Individual EU states are allowed to grow GM crops even if other states decide not to do so as long as the European Food Safety Authority (EFSA) has approved the crop as safe.No GM crops are currently grown commercially in the UK while Scotland, Wales and Northern Ireland have GM-free policies although it is not clear how they would operate in practice. Spain, Portugal, Romania, the Czech Republic and Slovakia grow small quantities of Monsanto's MON810 maize (resistant to some pests) for use in animal feed. GM crops enter Britain mainly as animal feed and there have been experimental field trials of GM potatoes, wheat and Camila sativa (false flax) in recent years. The European Commission proposal to extend the cultivation ban to import and trade referred to in this quotation was subsequently rejected by the European Parliament as noted in point 6.2 below. Current UK Government policy on GM crops is set out in the Department for Environment, Food and Rural Affairs (Defra) website at https://www.gov.uk/government/publications/2010-to-2015-government-policy-food-and-farming-industry/2010-to-2015-government-policy-food-and-farming-industry#appendix-7-genetic-modification.

[‡] GM insects potentially offer a more targeted and less environmentally harmful approach to controlling insect-borne diseases than insecticides and other techniques. Malaria and Dengue Fever each affects 350-500 million people every year causing many deaths and enormous economic cost. Malaria alone causes 438,000 deaths globally with 90% occurring in Sub-Saharan Africa. Other serious insect-borne illnesses include Chikungunya, Yellow Fever, Zika and Eastern Equine Encephalitis, and all are increasing in prevalence.

[§] Marker assisted breeding or selection (MAB or MAS) is a process whereby a marker (morphological, biochemical or based on DNA/RNA variation) is used for indirect selection of a genetic determinant (or determinants) of a desired characteristic.

[**] Professor Hunter has since left the BBSRC.


[1] House of Commons Select Committee On Science and Technology (2015) Advanced genetic techniques for crop improvement: Regulation, risk and precaution http://www.parliament.uk/business/committees/committees-a-z/commons-select/science-and-technology-committee/news-parliament-2015/gm-government-response-publsihed-15-16/

[2]House of Commons Select Committee On Science and Technology (2015) Advanced genetic techniques for crop improvement: Regulation, risk and precaution: Government Response published
http://www.parliament.uk/business/committees/committees-a-z/commons-select/science-and-technology-committee/news-parliament-2015/gm-government-response-publsihed-15-16/

[3] House of Lords Select Committee On Science and Technology (2015) Genetically Modified Insects
http://www.publications.parliament.uk/pa/ld201516/ldselect/ldsctech/68/6802.htm

[4]European Academies Science Advisory Council (2013) EASAC warns EU policy on GM crops threatens the future of
our agriculture
http://www.easac.eu/home/press-releases/detail-view/article/easac-warns.html

[5]Montpellier Panel (2013) Sustainable Intensification: A New Paradigm for African
Agriculture http://ag4impact.org/publications/montpellier-panel-report2013/

[6] Montpellier Panel (2015) The Farms of Change: African Smallholders Responding to an Uncertain Climate Future
http://ag4impact.org/news/the-farms-of-change-african-smallholders-responding-to-an-uncertain-climate-future-2015/

[7] The Royal Society (2009) Reaping the benefits: Science and the sustainable intensification of global agriculturehttps://royalsociety.org/topics-policy/publications/2009/reaping-benefits/

[8] Council for Science and Technology (2014) GM Science Update https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/292174/cst-14-634a-gm-science-update.pdf

[9] United Nations (2015) World Population Prospects http://esa.un.org/unpd/wpp/publications/files/key_findings_wpp_2015.pdf

[10] The World Bank (2016) Global Monitoring Report 2015/2016 http://pubdocs.worldbank.org/pubdocs/publicdoc/2015/10/503001444058224597/Global-Monitoring-Report-2015.pdf

[11] Food and Agricultural Organization of the United Nations (2015) Undernourishment around the world in 2015
http://www.fao.org/3/a-i4646e/i4646e01.pdf

[12] Food and Agricultural Organization of the United Nations (2012) Small Holders and Family Farmers
http://www.fao.org/fileadmin/templates/nr/sustainability_pathways/docs/Factsheet_SMALLHOLDERS.pdf

[13] International for the Acquisition of Agri-biotech Applications (2015) ISAAA Brief 49-2014: Executive Summary: Global Status of Commercialized Biotech/GM Crops:
2014 http://www.isaaa.org/resources/publications/briefs/49/executivesummary/default.asp

[14] AFK Insider (2015) Why Are More African Countries Accepting Genetically Modified Food? http://afkinsider.com/92428/why-are-more-african-countries-joining-the-gmo-bandwagon/

[15] COGEM (2014) Survey of Field Trials with Genetically Modified Plantshttp://www.cogem.net/index.cfm/en/publications/publicatie/research-report-survey-of-field-trials-with-genetically-modified-plants-global-trends-and-developments

[16] Harvest Plus (2004-2015) About HarvestPlus
http://www.harvestplus.org/content/about-harvestplus

[17] Department for International Development (2012) Developing GM super cassava for improved health and food
security: future challenges in Africa
http://r4d.dfid.gov.uk/Output/191691/

[18] Royal Society (2016) Royal Society-DFID Africa Capacity Building
Initiative
https://royalsociety.org/grants-schemes-awards/grants/africa-capacity-building/

[19] BBC (2012) British GM crop scientists win $10m grant from Gates
http://www.bbc.co.uk/news/science-environment-18845282

[20] John Innes Centre (2015) BecA-JIC Alliance strengthened
https://www.jic.ac.uk/news/2015/11/becajic-alliance-science/

[21] Rothamsted Research (2015) A new climate-smart companion cropping system allows African farmers to substantially increase their yields
http://www.rothamsted.ac.uk/news-views/new-climate-smart-companion-cropping-system-allows-african-farmers-substantially-increase

[22] International Centre of Insect Physiology and Ecology Climate-smart push-pull: resilient, adaptable conservation agriculture for the futurehttp://www.push-pull.net/Climate-smart_Push-Pull.pdf

[23] Biotechnology and Biological Sciences Research Council (2015) New Techniques for Genetic Crop Improvement
http://www.bbsrc.ac.uk/research/briefings/gm-synthetic-biology-genome-editing/new-techniques-crop-improvement/

[24] European Commission (2010) A decade of EU-funded GMO research (2001-2010)
https://ec.europa.eu/research/biosociety/pdf/a_decade_of_eu-funded_gmo_research.pdf

[25] Cordis (2015) GRACE GMO Risk Assessment and Communication of Evidence
http://cordis.europa.eu/project/rcn/104334_en.html

[26] Cordis (2015 ) AMIGA Assessing and Monitoring the Impacts of Genetically modified plants on Agro-ecosystems
http://cordis.europa.eu/project/rcn/101406_en.html

[27] EuropaBio (2015) Undue delays in EU authorisation of safe GM cropshttp://www.europabio.org/sites/default/files/position/europabio_undue_delays_update_june_2014_0.pdf

[28] European Ombudsman (2016) Decision of the European Ombudsman closing the inquiry into complaint 1582/2014/PHP on the European Commission’s handling of authorisation applications for genetically modified food and feed
http://www.ombudsman.europa.eu/cases/decision.faces/en/63025/html.bookmark

[29] European Parliament (2015) Parliament rejects national GMO bans proposalhttp://www.europarl.europa.eu/news/en/news-room/20151022IPR98805/Parliament-rejects-national-GMO-bans-proposal

[30] World Trade Organisation (2005) U.S. versus EC Biotech Products Case WTO Dispute
Backgrounder
http://www.iatp.org/files/451_2_76644.pdf

[31] World Trade Organisation (2006) European Communities – Measures Affecting the Approval and
Marketing of Biotech Products
https://www.wto.org/english/tratop_e/dispu_e/cases_e/ds291_e.htm

[32] Agricultural Biotechnology Council (2014) The EU impact on the UK Life Science sectorhttp://www.eufreshstart.org/downloads/lifesciences2.pdf

[33] Agricultural Biotechnology Council (2015) Going against the Grainhttps://www.nfuonline.com/going-against-the-grain-report/

[34] Zilberman D, Kaplan S and Wesseler J (2015) The Loss from Underutilizing GM Technologies. AgBioForum 18(3): 312-319
http://www.agbioforum.org/v18n3/v18n3a09-zilberman.htm

[35] The Guardian (2003) Brain drain threatens GM crop research
https://www.theguardian.com/science/2003/sep/25/gm.science

[36] The Telegraph (2013) Major GM food company Monsanto 'pulls out of
Europe'.
http://www.telegraph.co.uk/news/earth/environment/10186932/Major-GM-food-company-Monsanto-pulls-out-of-Europe.html

[37] Kellogg Insight (2012) BASF plant-science leaves Europe for US
http://insight.kellogg.northwestern.edu/blogs/entry/basf_plant-science_leaves_europe_for_us

[38] Financial Times (2016) ChemChina closes in on $43 bn Syngenta deal
http://www.ft.com/cms/s/0/1525ea0c-c9aa-11e5-be0b-b7ece4e953a0.html#axzz41qBFiapb

[39] The Grocer (2013) UK food retailers maintain a non-GM policy http://www.thegrocer.co.uk/buying-and-supplying/categories/fresh/sainsburys-ms-and-the-co-op-follow-tescos-lead-on-gm-feed/238400.article

[40] Information Technology & Innovation Foundation (2016) Suppressing Growth: How GMO Opposition Hurts Developing Nations
https://itif.org/publications/2016/02/08/suppressing-growth-how-gmo-opposition-hurts-developing-nations