Commission Report on the implementation of Regulation 1830/2003 concerning the traceability and labelling of GMOs and food and feed products produced from them (link)

May 11, 2006

Brussels, 10 May 2006

on the implementation of Regulation (EC) No 1830/2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC
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The majority of stakeholders have pointed to the fact that the Regulation has only been operational for a limited period of time and that experience in terms of its implementation is extremely limited. This has been exacerbated by the limited number of GM products currently being marketed in the European Union. Consequently, this report realistically can only be viewed as preliminary and further experience and reporting will be required to gain a true picture of implementation of the Regulation.

In spite of the above, it appears that the provisions of the Regulation are being correctly applied. Whilst some early 'teething' problems have been reported, they appear to have been, in the main, largely resolved.

Many stakeholders have pointed to a need to specifically address the adventitious presence of 'non-approved' GM material, notably in terms of available detection methodology. It should, however, be made clear that the Regulation covers only GM products that have received Community authorisation for their placing on the market. The Commission, via its Joint Research Centre (JRC), continues to address this issue and information pertaining to GMOs approved in other countries, where available, will be placed on a Community register in accordance with Article 9(3) of the Regulation.

Whilst certain stakeholders, have highlighted that the sampling and detection guidelines in the Commission Recommendation are useful, others consider that they are complicated and difficult to apply. The bottom line is that sampling and detection are complex issues and only a limited number of methodologies were available prior to on the entry into force of this Regulation.

The JRC and the European Network of GMO Laboratories (ENGL) subsequently developed a methodology for sampling bulk shipments of grain and this has since been accepted as an international standard. The JRC and ENGL continue to validate specific detection methods for individual GMOs but this work is time-consuming (and costly) given the precision and accuracy required for validation. It is, however, clear that continued efforts in this area must and will have to continue.

Certain trading partners continue to allege that the Regulation introduces an excessive administrative burden. Imports of soybean and maize, including their derived products such as soy-meal or corn gluten feed do not appear to have been affected by the Regulation. In practice, consumer and market demand for foodstuffs in particular has certainly had a far greater effect than the provisions of the Regulation in terms of trade in products containing GM material.

The asynchronous approval regime for GMOs between countries remains the major obstacle to trade. Whilst some trading partners have been able to successfully manage this issue to avoid trade disruption, others seem either unable or unwilling to address it.

However, it remains clear that only a limited amount of information and experience concerning the implementation of the Regulation is available at the current time. Therefore, the Commission will draw up a second report, following a further period of 24 months to enable a more complete picture of implementation to be obtained.


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Brussels, 10.5.2006 COM(2006) 197 final

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