Koexistenz Gentechnik in der Land- Und Ernährungswirtschaft Stellungnahme Mai 2010

93. The EU has formulated a coexistence target in order to be able to take advantage of the opportunities offered by "green biotechnology" whilst also maintaining GM-free farming on the market. Hardly any experience with this is available since only one GM plant species, maize (MON 810), has so far been grown in Europe in a few Member States and since no comparable coexistence strategy exists in the main countries where GMPs are grown (USA, Brazil, Argentina). 94. The Scientific Advisory Board on Agriculture developed the following recommendations based on the latest findings: I. The decision to authorise the marketing of GM constructs should continue to be taken exclusively according to scientific criteria and based on the EFSA decision. However, the decision to authorise cultivation should be taken separately from that and based on socio-economic criteria at Member State level. II. In order to lower the costs incurred due to coexistence and to avoid coexistence conflicts, the rules of good farming practice (GFP) for other crop species or constructs should also be formulated with the aim of virtually ruling out any impurities above the labelling threshold by accordingly allowing for extensive safety margins. In order to reduce mixes to a minimum, GM varieties must be grown, harvested, transported and stored completely separately from NGM varieties. This is particularly important for seed and planting stock. The obligation to provide information in the event of a change of farmer should be extended beyond the 5-year period, as appropriate, depending on the crop species (e.g., in the case of rape). A schedule of penalties for non-compliance with good farming practice should be drawn up and implemented. III. The GFP rules that have so far applied only to maize should be regularly reviewed after two to three years of practical experience and revised, as appropriate. IV. Suitable agronomic measures should be prescribed for rape in the autumn in order to ensure that the highest possible proportion of shed seeds germinate and do not become dormant. In addition, volunteers should be rigorously controlled in the successor crops in order to counteract the development of GM weed rape. In accordance with the latest findings, stipulating a distance of 50 m is deemed sufficient. GM rape grains should only be transported in closed containers. Due to the dormancy characteristics of rape, the obligation to document and retain data should be extended to twelve years. A duty of farmers who have grown GM rape on their land within the last twelve years to provide information to their customers should be introduced. V. In order to prevent contaminations of GM-free potato stands with GM volunteer plants, the careful control of volunteer potatoes should be supplemented by stipulating that the growing of GM potatoes should be followed by a two-year potato-free period. The control of volunteer plants should also be provided for so that the cropping intervals may be extended as appropriate if, due to particular weather situations or crop rotations, weed potatoes occur in the second succeeding crop after the GM potatoes. VI. In the case of sugar-beet, good farming practice should ensure the complete removal of sugarbeet bolters in order to prevent a gene transfer from GM sugar-beets to non-GM beets or related species. VII. The existing rule of joint and strict liability should be maintained and the strict liability should by means of suitable wording in the law, be more clearly limited to the marketing damage that arises in the agricultural sector and to the 0.9% threshold. In order to cover the consequential damage in the agricultural sector that occurs despite compliance with GFP, a liability fund should be established that covers relevant liability claims against NGM farmers. The State and industry could provide the financial resources for the fund. An effective cost-participation regulation should be provided for as an incentive for damage limitation. VIII. The current de facto ban on mixing should be repealed by an amendment to Community law. It should, at the same time, be laid down by law that State controls of the threshold should only be conducted at the last stage of the food chain where GM is still detectable. IX. A 0.3 % labelling threshold should be set for seeds and, in addition to that, voluntary labelling of GM concentrations of under 0.1% should be allowed. Crop-specific GM-free growing areas should be designated around the nurseries and breeding stations of breeders in order to protect the GM-free seed-breeding establishments. X. After an adequate transitional period the GM labelling requirement should be extended to cover animal products in the production of which genetically modified feed has been used. The "GM-free" label that has already been introduced should be made available to NGM producers or marketers taking part in certification schemes. The inspection tasks should, as far as possible, be performed with the aid of the private sector, e.g., by charging a private-sector organisation to perform state functions. XI. After positive labelling of "green biotechnology" has been introduced throughout the country and following a transitional period, labelling should also be introduced for "white biotechnology". XII. Temporary subsidies towards the costs of analysis should be granted to NGM farmers in the initial phase of GM cultivation. Provision should be made for the analytical findings to be made available to public bodies for evaluation. The Advisory Board recommends that government funds should be provided for research activities in order to lower the costs of analysis and to improve the sampling strategies. 95. Man is a crucial factor in the coexistence approach. Whether an increasing contamination of NGM products occurs over time is heavily dependent on how consistently we handle the GFP rules and on whether we succeed in adapting these rules to new findings.