Currently, organisms developed using genetic technologies such as GE are regulated as genetically modified organisms (GMOs) even if their genetic change(s) could have been produced through traditional breeding. Do you agree with this?

Answer: No – they should not continue to be regulated a GMO

Please explain your answer, providing specific evidence where appropriate. This may include suggestions for an alternative regulatory approach.

The United Kingdom should strive to be in line with the Cartagena Protocol, and not treat organism developed using GE as GMOs, if they could have been produced through traditional breeding. An accurate risk-assessment should be based on the individual organism, not on the technology that produced it. In that sense, the UK should diverge from existing EU legislation, and the associated ECJ ruling of 2018.

Do organisms produced by GE or other genetic technologies pose a similar, lesser or greater risk of harm to human health or the environment compared with their traditionally bred counterparts as a result of how they were produced?

Please provide evidence to support your response including details of the genetic technology, the specific risks and why they do or do not differ. Please also state which applications/areas your answer relates to (for example: does it apply to the cultivation of crop plants, breeding of farmed animals, human food, animal feed, human and veterinary medicines, other applications/ areas).

The question does not do the complexity of the issue justice. Making general statements of safety for all products derived through genetic engineering is not possible, nor desirable. In fact, the perspective of regulating by technology, not by organism, is a failure of EU policy, which should be revisited. The technology of genetic engineering is a means to an end, of which we cannot make blanket statements.

Are there any non-safety issues to consider (e.g. impacts on trade, consumer choice, intellectual property, regulatory, animal welfare or others), if organisms produced by GE or other genetic technologies, which could have been produced naturally or through traditional breeding methods, were not regulated as GMOs?

 Yes

Please provide evidence to support your response and expand on what these non-safety issues are.

Non-safety issues that are to consider is the legality of GMOs restrictions in the jurisdictions of trading partners. If the European Union does not allow for the import of gene-edited organisms because of its GMO Directive, then this has trade implications that can activate international dispute mechanisms.

There are a number of existing, non-GM regulations that control the use of organisms and/or products derived from them. The GMO legislation applies additional controls when the organism or product has been developed using particular technologies. Do you think existing, non-GM legislation is sufficient to deal with all organisms irrespective of the way that they were produced or is additional legislation needed? Please indicate in the table whether, yes, the existing non-GMO legislation is sufficient, or no, existing non-GMO legislation is insufficient and additional governance measures (regulatory or non-regulatory) are needed. Please answer Y/N for each of the following sectors/activities:

Cultivation of crop plants: Yes
Breeding farmed animals: Yes
Human food: Yes
Animal food: Yes
Human and veterinary medicines: Yes
Other sectors/activities: Yes

Source: https://consult.defra.gov.uk/agri-food-chain-directorate/the-regulation-of-genetic-technologies/