Seed purity
Latest update: 12.10.05

On 8 th September 2004, the European Commission withdrew a proposal which would have allowed GMO contamination of conventional seeds of maize and oilseed rape. It is expected that the new Commission, which took office in November 2004, will present a different proposal.

Below is a summary of Friends of the Earth Europe's views on seed purity and the associated problems.

• The importance of seed purity

The proposal of the previous Commission to allow a 0.3% -0.7% GMO threshold for seed would restrict the agricultural options for future generations. It is essential that seed lots are free of all GMO contamination and that pure lines are maintained in perpetuity.

Breeding out GMO contamination in seed stocks would be very difficult, if not impossible. To allow seed from many of the main agricultural and horticultural crops to become contaminated with GMOs would be folly in the extreme.

Moreover, to comply with Directive 2001/18/EC, which foresees the monitoring of the release of GMOs in the environment and the withdrawal of GMOs in case new risks for human health and the environment are identified, it is necessary to set a threshold as low as possible, the technical 0.1%. Monitoring and withdrawal of approved GMOs will become impossible unless farmers and national authorities know exactly where GMOs are present.

• Thresholds for GM seed

FoE Europe does not accept that GMO varieties should be allowed anywhere in the food chain. It is therefore essential that seed crops destined for the EU market are not grown in areas where the GM crops are potentially being grown or tested.

In FoE Europe 's view, it should be neither necessary nor justified to establish thresholds for GMO contamination of seeds. In this regard, FoE Europe followed with interest developments in the EU's Standing Committee on Seeds and Propagating Material for Agriculture, Horticulture and Forestry (SCOP) under which the "Adventitious Presence of GM Seeds in Seeds of Conventional Plant Varieties" was addressed by Member States. From the information published in the reports of the SCOP, it appears that there is actually very little evidence of seed contamination even approaching the thresholds previously proposed by the Commission in the draft directive, for example:

• Contamination levels of "either negative or in a few cases below 0.1%" (SCOP meeting, May 2001);

• "in a large number of samples no GM was detected, or that the level of contamination found was very low. Very few samples presented a level above 0.5%" (SCOP meeting, July 2001);

• "Several Member States have negative results on the seeds tested" (SCOP meeting, 13-14 September 2001).

In FoE Europe's view, this rather begs the question as to why the Commission should press for higher levels of seed contamination by GMOs than actually exist at present, instead of addressing the problem of ensuring that GMOs are not allowed to jeopardise seed production.

• A 0.1% detection limit threshold is possible!

Seed testing conducted by national authorities since some years clearly proves that a purity level of 0.1% has been achieved both in Europe and in seeds coming from countries where GMOs are grown commercially. The Austrian Seed Law, which prohibits the use of any seeds contaminated with GMOs, also shows that this purity level can be achieved without problems. Any threshold above the realistic detection limit of 0.1% would, in effect, unnecessarily lower the standards presently observed by the seed industry.

• Labelling of GM seeds

The previous Commission dropped the idea to forbid the marketing of seeds with the "adventitious" or "technically unavoidable" presence of GMOs above a certain threshold. Instead, these seeds would have to be labelled but could still be sold. Obviously for the consumer to have real freedom to choose whether to eat GM food or not, labelling of food products alone will not be enough. In order to achieve freedom of choice, sufficient supply of GM-free food is another prerequisite. This GM-free supply was threatened, however, by the last proposal from the Commission allowing genetic contamination of seeds without even informing farmers and consumers.

• Gene-stacking

Seeds containing GMOs could also be contaminated with other GMO transformations (which may be approved or unapproved), leading to the "stacking" of genes. The problems that this could cause for farmers if, for instance, a seed lot were to contain two different herbicide-tolerant genes, in order to control volunteer plants in subsequent crops would be more complex and could lead to farmers using older and more toxic herbicides to destroy so-called "superweeds". English Nature, the UK government's wildlife advisors, has already reported on this happening in Canada where GM oilseed rape is grown extensively.

The need to keep certified seed free of all GMO contamination also means that seed crops should not be grown in regions where EU-approved GM crops are potentially being grown or tested. The increasing evidence of widespread genetic contamination in western Canada from GM oilseed rape supports the view that conventional separation distances are failing to prevent contamination of all types of crops.

• Financial implications

FoE Europe is astonished that the Commission made no attempt to assess the cost of its proposals for farmers and for conventional seed companies. It is clear that if inadequate legislation is adopted, the process of ensuring that separation distance are respected will fall heavily on farmers growing the non-GM seed crop and on the seed company they are working with. This will inevitably lead to increased costs that will be passed on to the customer. This may harm the market for conventional seed.

There may also be financial implications for farmers saving their own seed. To meet the demand from the food industry for raw materials free of GMO contamination, they may need to pay for their saved seeds to be analysed before sowing. Likewise, farmers using varietal associations could incur similar costs.

Crucial questions to ask are thus:

• Why is the burden to take necessary measures to avoid GMO pollution placed entirely on the breeders and seed multipliers who do not propagate GM seeds?

• Who will be liable if seeds cannot be sold because they exceed the thresholds and have to be labelled? (The EU has no liability legislation covering damage to farmers, including seed producers, caused by GMOs.)

Conclusion:

In FoE Europe's view, it is essential that seed stocks are not allowed to be contaminated by GMOs. Should anything unforeseen arise in GMO technology, then it will be too late - there will be no possibility for recall. For this reason alone, Friends of the Earth Europe calls on the European Commission to ensure that seeds remain protected from GMO contamination.

To find out more, see: http://saveourseeds.org/