Brussels, 11 Jun 2004
European Community comments on Codex Circular Letter CL 2004/7-FBT:
Request for comments on the Draft Terms of Reference and Project Proposal for the New Ad Hoc Intergovernmental Task Force on Foods Derived from Biotechnology
The European Community would like to thank Japan for the submission of the Draft Terms of Reference and the Proposal for new Work contained in CL 2004/7-FBT.
The European Community, without prejudice of the budget availability, strongly supports the establishment of a new Task Force on Foods Derived from Biotechnology and welcomes the decision of the 26th Session of the Codex Alimentarius Commission to request Japan to submit a proposal on this new Task Force including Terms of Reference.
The European Community would like to make the following comments to assist to the development of the proposed Terms of Reference:
- Among the tasks assigned to the new Task Force, particular attention should be given to the development of guidance for the conduct of the food safety assessment of genetically modified animals (including fish) and derived food products. Work on this topic should be based on the outcome of the joint FAO/WHO Expert Consultation on the Safety Assessment of Foods Derived from Genetically Modified Animals, including Fish, held at the Headquarters of the Food and Agriculture Organization of the United Nations (FAO) in Rome from 17 to 21 November 2003. Due consideration should be given to environmental and ethical aspects in relation with this question.
- The European Community is of the view that for trade reasons high importance should be attached to the low level presence of unauthorized genetically modified material in food. An agreement, based on science, on this issue would help alleviate or prevent potential trade disputes caused by low levels of GMOs in food through adventitious contamination of non-GM products during production, transport or storage. It would thus serve one of the fundamental objectives of Codex Alimentarius, i.e. to promote fair practices in food trade.
It should however be stressed that this issue is unrelated to the question of labeling thresholds, which is dealt with in another Codex Committee. It is the experience of the European Community that there is an inherent risk of the two matters getting entangled. We would therefore strongly advise that proper consideration is given from the outset to the potential entwinement of the two matters.
- The European Community also strongly supports the work proposed on plants expressing bioactive substances. However, in the view of the European Community, the term of "bioactive substances" should be avoided since it is not clearly defined. Instead, the European Community would propose to use the wording "Plants expressing pharmaceutical or other non-food substances". Issues that could be dealt with under this topic are:
- what type of such substances could be allowed in crops used for food;
- how suitable crops could be contained;
- how the safety assessment with regard to food safety should be carried out and;
- possible actions in the case of accidental contamination of the food supply.
- what type of such substances could be allowed in crops used for food;
- avoidance of unnecessary DNA sequences such as marker genes that raise safety concerns;
- participatory deliberation by all stakeholders and the general public, starting at an early stage, including communication about the potential benefits, risks, and
- uncertainties posed by genetic modification;
These three set of issues have been raised in the Report of the FAO/WHO Expert
Consultation on the Safety Assessment of Foods Derived from Genetically Modified Animals, including Fish, but they appear to have general relevance for many applications of modern biotechnology. We suggest that consideration of these issues would not lead to a re-opening of the work of the first Task Force, to which the European Community remains firmly committed.