Plants obtained by certain new genomic techniques and their food and feed

NATRUE aisbl is an international non-profit association representing pioneering producers from across the global natural and organic cosmetics (NOCs) sector, and welcomes this opportunity to provide feedback to the EU Commissions legislative proposal for plants produced by certain new genomic techniques (NGTs).

Norwegian Institute of Bioeconomy Research (NIBIO) is to contribute to food security and safety, sustainable resource management, innovation and value creation through research and knowledge production within food, forestry and other biobased industries.

Brussels, 24 October 2023 TE2317 TomatoEurope Position Paper on the New Genomic Techniques TomatoEurope represents the tomato processing industry, covering more than 95% of the European business. Active since 1979, it has acted as an umbrella organisation for national associations, indirectly representing more than 200 tomato processing entities in six European countries (France, Greece, Italy, Spain and Portugal).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Plant improvement is continuously needed to address the challenges and constrains faced by humankind. This is specially important given the need to minimize the use of agrochemicals. The crops we currently have available are the output of hard work from farmers, breeders and scientists, all equally important, but the challenges have increased and the work cannot stop!

APROSE (Professional Association of Selecta Seed Producers representing companies in the certified seed multiplier sector in Spain) is in favour of this Commission proposal as it is based on scientific evidence establishing different rules for plants and products derived from New Genetic Techniques (NTG) compared to genetically modified organisms (GMOs).

Filed in Spanish · English published by the European Commission

I would like to thank and support the legislative initiatives on innovation in genetic improvement, and I am in favour of the Commission’s proposal to regulate the breeding of plants produced using new genomic techniques. This contributes to the production of new varieties and improves the sustainability of agri-food production.

Filed in Spanish · English published by the European Commission

The adoption of new gene editing techniques allows us to move towards sustainability both economically and agronomically speaking. From the point of view of a young farmer, it allows us to improve the adaptation of crops to the soil than we have, again demonstrating the usefulness of scientific knowledge to help us become more sustainable and resilient to new changes in both climate and soil.

Filed in Spanish · English published by the European Commission

The Danish Agricultural and Food Council (DAFC) represent the whole value chain from plant breeders to farmers and producers of food, feed and nonfood products including organic producers. DAFC highly welcome the Commission proposal for future regulation of plants and products from these developed by new plant breeding methods within the NGT 1 category.

The current legislative proposal provides for a ban on all NGTs in organic production. We believe that this provision is essential. The use of these procedures does not comply with the principles of organic farming, as is also laid down in Article 5 of Regulation (EU) 2018/848.

Filed in German · English published by the European Commission

Neue Gentechnik würde nach Plan der EU-Kommission Sicherheitstests umgehen Luxemburg, den 20. Oktober 2023 - Am 5. Juli 2023 veröffentlichte die Europäische Kommission einen Plan zur Abschaffung der meisten Sicherheitsvorschriften für die Produktion und den Verkauf einer neuen Kategorie von gentechnisch veränderten Pflanzen, die mit Neuer Gentechnik (NGT) hergestellt wurden.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The 3 organisations behind the consultation response have a number of comments on the consultation. Please read in the attached file. NOAH, Foreningen for Biodynamisk Jordbrug (Danish Association for Biodynamic Agriculture), and Frøsamlerne (Danish Seed Collectors) recommend that the EU-Commissions proposal to change categories for new techniques to genetically modify plants should be dismissed (NGT1, NGT2), as…

Dear ladies and gentlemen, I cannot agree to an amendment to the Genetic Engineering Ordinance (NGT plants) as a bio/demeter of operation. The reasons are as follows. Crossing with other plants cannot be avoided in the small parcels in BaWü. Proof of contamication by the polluter cannot be traced by my holding if there is no declaration or registration of sowing/cultivation.

Filed in German · English published by the European Commission

The Commission, with the new NGT Regulation, proposes to establish two categories for NGT plants and their products. On the one hand, certain types of NGT plants are to be considered equivalent to conventionally bred plants, removing them from the scope of the EU GMO legislation and, on the other hand, adapting the risk assessment for other types of NGT plants based on their risk profile, remaining under the GMO…

The proposal for deregulation of the CMO as made by the EC, supplemented by an amendment to the effect that category 1 CMO is not prohibited in the organic sector is contrary to the right to freedom of choice. Deregulation of the CMO reinforces the discriminatory dominance of large companies. The UN report of 2017 states that agroecological farming should be promoted.

Filed in Dutch · English published by the European Commission

FEPEX, the Spanish Federation of Associations of Producers Exporters of Fruit, Vegetables, Flores and Live Plants, welcomes the Commission’s consultation and appreciates the opportunity to comment on the proposal for a Regulation of the European Parliament and of the Council on plants obtained by certain new genomic techniques and on derived food and feed.

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GeneSprout Initiative is an early-career researcher initiative dedicated to fostering an open dialogue on NGTs (New Genomic Techniques) and the EU policy surrounding them. GeneSprout Initiative welcomes the ECs proposal that will guarantee equal access of category 1 plants to the market as their conventionally bred counterparts.

We welcome the European Commission’s draft regulation of New Genomic Techniques (NGTs) in plant breeding. In times of climate change and related changes in environmental conditions, rapid adaptation of crops to new biotic and abiotic factors is essential to ensure food security.

Filed in German · English published by the European Commission

We are the German Association for Synthetic Biology (GASB), and we welcome the European Commission's proposal for the new regulation of New Genomic Techniques (NGTs). Climate change is one of the most important issues in our generation and we firmly believe that NGTs can play a role in promoting sustainable agriculture and achieving the sustainable development goals (SDGs) set by the United Nations.

Soy Canada is the national value-chain organization for the soybean sector, including seed developers, growers, exporters, and processors. Our membership is diverse, including small, medium and large businesses across the country. Innovation is at the heart of Canadas soybean growers, who have proudly produced soybeans for more than 70 years.

The EU is aware of the threat of climate crisis and food insecurity, and is, in some areas, supporting a transition to agroecology, supporting small farmers, biodiversity and local production. To even contemplate the use of genetically manipulated material goes against this current and paradoxically supports industrial agriculture and the giant multinationals who will profit.

Sow Diverse is a Heirloom and rare seeds company based in Ireland. Sow Diverse strongly opposes the adoption of the proposed regulation concerning plants and seeds obtained using NTGs. The proposed deregulation would allow a large part of these new GMOs to be cultivated and placed on the European Union market without prior global assessment, without product labeling, without traceability once released, without legal…

EPSO welcomes the move towards a more proportionate regulatory environment for NGT crops. EPSO acknowledges that the proposal is a balanced compromise and supports most of its content, especially the quasi-equivalence of NGT1 plants with conventionally bred ones and the omission of additional labelling requirements beyond the seed labelling.

GMO-Network Norway would like to emphasise that it is vital that all GMOs, including NGTs, undergo a thorough risk assessment and approval procedure before they can be marketed for food and/or feed use. Moreover, traceability and GMO-labelling of products produced using these techniques must guarantee consumers and food producers the right to know and freedom of choice.

November 3, 2023 European Commission Brussels, Belgium Subject: Government of Canada Comments on the European Commission Proposal for a Regulation of the European Parliament and of the Council on plants obtained by certain new genomic techniques and their food and feed, and amending Regulation (EU) 2017/625 To Whom It May Concern, The Government of Canada thanks the European Commission for the opportunity to submit…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Weingut Brüder Dr Becker Mainzer Str. 3-7 55278 Ludwigshöhe Germany’s comments on the Commission’s new legal framework for NGTs. We call on you to continue to maintain the labelling requirement for seeds and planting stock for NTGs. As organic wine products, we are obliged to use only GM-free seeds and plants.

Filed in German · English published by the European Commission

Supports the Commission proposal, supporting science-backed decisions. I consider that Category 1 NTG plants should be considered equivalent to those obtained by conventional improvement. I am in favour of innovation in genetic improvement to develop new varieties that boost food security and ensure sustainability in agri-food production and the growth of rural areas.

Filed in Spanish · English published by the European Commission

In 27 years (1996-2023) of GMOs in agriculture, the main results were (i) the increase in the use of herbicides, first glyphosate in herbicide-tolerant GM ‘Roundup Ready’ varieties and then dicamba when glyphosate lost its efficacy for herbs that became resistant, (ii) the disappearance of non-GMO standard or hybrid varieties, (iii) the same productivity for most GM varieties compared to equivalent conventional…

Filed in Portuguese · English published by the European Commission

In my capacity as Chair of the Board of Directors of the TERRES bocage Gatinais agricultural cooperative, with its registered office in Château-Landon, Seine-et-Marne, I would like to stress the chance our fellow citizens have of having diverse landscapes, local jobs, either direct jobs or agricultural activities. Climate change is in the process of moving back to the NBT Genomic Techniques.

Filed in French · English published by the European Commission

GMOs like many things developed by humans take the place of natural varieties and exterminate them. This therefore exterminates the genetic diversity present in nature and thus makes nature less resilient. As we are doing with Alliance Wood and our forests that are becoming monocultural forests, which makes them non-resilient and always brings us a bit more towards the end of our world.

Filed in French · English published by the European Commission

The proposal poses a disastrous threat to the EU. New GMOs/NGTs do not have a guarantee of safety and even functionality, health and RUs are at risk. There is no scientific evidence that they are less risky than transgenic crops. NGTs show inaccuracies, unwanted changes at non-target DNA locations.

Filed in Slovak · English published by the European Commission

I am in favor of the Commission's proposal; I support science-based decisions; in favor of innovation in genetic improvement that allows obtaining new varieties that contribute to food security and ensure the sustainability of agri-food production and the development of rural areas; It is necessary that farmers have tools that allow them to produce quality production and fight against the effects of climate change…

The proposal for deregulation of the CMO, as presented on 5 July, is a major interference with the freedom of choice of citizens and businesses and lacks a scientific, legal and statistical basis. We simply have no answer to the question of how we, as the only regional breeding company and seed producer in the Netherlands, can keep our seeds free from CMO and patents.

Filed in Dutch · English published by the European Commission

This comment is a modified excert made by the author from EMBO Reports (2023)e58109 "Mind the CRISPR gap" While the I welcome the EC proposal for the regulation of NGTs and consider that it provides a valuable entry point to enable their adoption in the EU, it is important to note that the proposal is merely an add-on to the 2001 Directive, and, as such, misses the opportunity to completely revise and update the…

About Fresh Produce Centre: Fresh Produce Centre / GroentenFruit Huis is an industry body from the Netherlands that represents the interests of vegetables and fruit producers/ growers, their Producer Organisations, traders and wholesalers export companies etc. The members of Fresh Produce Centre account for over 80% of total sales of vegetables and fruit within the Netherlands.

FERM (Federation of the European Rice Millers) appreciates the proposal for a regulation on plants ‎obtained by certain new genomic techniques (NGTs). We welcome the progress made towards a ‎product-based approach, which aligns with the long-standing proposal from academia and industries.‎ While we acknowledge the distinction made between conventional-like products and others, we have ‎concerns regarding the…

I am in favour of the new genomic techniques (NGT) and the Commission’s proposal to change the legislation on plants/plants produced with these techniques. Moreover, this proposal should also include “classical transgenic organisms”, unfairly legislated by the European Commission. Professor of Biotechnology (subject: Celular and transgenesis cultures), Faculty of Biology, Complutense University, Madrid, Spain.

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VIA EU WEB PORTAL November 3, 2023 On behalf of the Grain Farmers of Ontario, I am writing to share our interest and provide comments on the European Union’s efforts in developing a new legislative framework for the cultivation and trade of new genetic technologies (NGTs).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As an environmental association, we would like to draw your attention to the following opinions: A legal opinion by Dr Georg Buchholz concludes that the Commission’s proposal is contrary to the precautionary principle to such an extent that the regulatory discretion of the EU legislature would be exceeded if it were to adopt the proposal in this way: If the EU legislature were to adopt the regulation as proposed by…

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I agree with the proposal submitted by the Commission to NGTs, but only if a paragraph on the prohibition of patenting products obtained by NGTs is added directly to the Regulation. This is because NGT1 is diagnostically indistinguishable from conventional breeding and therefore cannot be covered by patents. Access to NGT plants, in particular NGT1, for small and medium-sized breeders must also not be restricted.

Filed in Czech · English published by the European Commission

It is appreciated that the Commission is finally implementing a product-based risk assessment for plants derived with NGT. This wants to be an important step to harmonise the regulatory approaches concerning NGTs world-wide. Additional harmonisation in NGT regulation, i.e.

Filed in German · English published by the European Commission

I am in favour of the Commission proposal. Support science-based decisions. I am in favour of innovation in genetic improvement to produce new varieties that contribute to food security and ensure the sustainability of agri-food production and rural development.

Filed in Spanish · English published by the European Commission

The American Seed Trade Association (ASTA) welcomes the July 2023 proposed amending regulation for plants obtained by new genomic techniques and their food and feed. The proposal is a positive move towards an enabling regulatory framework to incentivize commercialization of and to enhance farmer access to improved plants varieties developed using new genomic techniques (NGT plants).

As a farmer and nurse; I find it anomalous that genetically modified organisms can be authorised and used in the agri-food industry without informing the consumer (exemption from labelling of products) and without respecting the precautionary principle.

Filed in French · English published by the European Commission

Rijk Zwaan is a vegetable breeding company developing new vegetable varieties and selling the seeds produced from them all over the world. We welcome the proposal of the EU commission (EC) for a regulation on plants obtained by NGTs. It is important to create a global level playing field regarding this topic.

Pulse Canada is the national association representing growers, traders and processors of Canadian pulses (dry peas, lentils, dry beans, faba beans and chickpeas). Our mission is to lead a profitable and sustainable Canadian pulse industry through innovation that increases production efficiency and increases value for the sector.

From ASAJA Nacional, the most important agricultural organisation in Spain, by number of members and by number of CAP applications and number of hectares, we would like to state the following: We support the urgent need for farmers to have the tools of New Genomic Techniques (NGTs), which will provide us with an acceleration of the genetic improvement programme and better genetic material because European and…

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Ökofrost GmbH is a special wholesaler of organic refrigerated food and operates three separate organic deep-frozen brands: Biopolar, BioCool and Wildlife. Ökofrost supplies natural food retail, wholesale and conventional food retailers. We would be severely affected by the proposed rules, as all products with plant ingredients we are trading could be affected. Organic products are subject to a ban on GMOs.

Filed in German · English published by the European Commission

Comments from ALAS on the proposal for a regulation on plants obtained using new genomic techniques (NTG), the Alliance for Sustainable Agriculture (ALAS), a group of entities in the Spanish production sector to express its support for all models of sustainable productive agriculture, made up of professional agricultural organisations in Spain such as ASAJA, UPA and COAG, as well as Agro-Food Cooperatives in Spain…

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EU-SAGE is a network representing plant scientists at more than 150 European plant science institutes and societies that have joined forces to provide information about genome editing and promote the development of European and EU member state policies that enable the responsible use of genome editing for sustainable agriculture and food production. Detailed EU-SAGE comment to the EC proposal can be found in attach.

Considerations: - The EU requirements for new technologies should be aligned with globally adopted regulatory procedures to avoid potential risks for trade disruptions. Nowadays is focused on plants and could add more generalist (e.g., add microorganisms and others).

I reject the Commission’s proposal, which is contrary to the precautionary principle, endangers RUs, human health and the autonomy of our agriculture. The Commission’s proposal will lose freedom of choice, and we will not abandon new GMOs.

Filed in Slovak · English published by the European Commission

CEFS, the European Association of Sugar Manufacturers, supports the development of an adapted legislative framework that would allow the uptake of plants obtained by New Genomic Techniques (NGTs) in the EU. These new techniques are an important tool for farmers to face increasing challenges such as climate change adaptation and the loss of active substances, and may contribute to the achievement of the overall Green…

AEPLA (Business Association for Plant Protection) is grateful for the opportunity to participate in the consultation on the proposal for a regulation on plants obtained by certain new genomic techniques (NTG) launched by the European Commission.

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AISBL 0670.974.140 Plants for the Future ETP’s response to the public consultation on the EU Commission’s legislative proposal for NGT Plants for the Future ETP (Plant ETP), representing the plant sector from the seed and breeding sector, the farming community and academia, supports the EU Commission’s legislative proposal for certain New Genomic Techniques (NGTs), particularly the differentiation between…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Mme, Mr, COCERAL, the European association of trade in cereals, oilseeds, rice, pulses, olive oil, oils and fats, animal feed, and agrosupply, welcomes the opportunity to comment on the proposal on plants obtained by certain new genomic techniques and their food and feed.

Lidea is a multi-species seed company and one of the European leaders for the different species that it places on the market. It intervenes throughout the value chain: varietal selection, production and placing on the market of seeds. Lidea’s mission is to create and offer personalised and sustainable solutions to farmers throughout the year, enabling them to respond to food, environmental and climate challenges.

Filed in French · English published by the European Commission

EFFCA The European Food and Fermentation (EFFCA) Cultures Association welcomes the initiative ‎of the Commission services to modernise the European GMO legislation. We recognize certain ‎improvements from the current state of play and some progress made towards a product-based ‎approach, which aligns with the long-standing call from academia and industries.‎ Regarding the main text:‎ While we acknowledge the…

CropLife Europe welcomes the Commissions proposal on New Genomic Techniques (NGTs) which has the potential to enable all actors, including SMEs and public researchers, to bring more resilient and sustainable plants to the EU market. This supports investment in plant breeding innovation in the EU and enhances competitiveness and sustainability of European agriculture.

You will find attached the contribution from the French vegetable oil and protein sector. The French vegetable oil and protein sector, created in France decades ago, feeds people and animals every day. It works on a daily basis to improve Europe's food self-sufficiency, but also to defend jobs in the regions and its demand for quality.

My contribution discusses how environmental side-effects are managed, how sustainability goals are integrated, what socio-economic effects are to be expected, and whether higher rank law is respected. Several shortcomings are found suggesting that the proposal should thoroughly be revised. An alternative approach is submitted that combines an easening of control with better integration of sustainability goals.

As a company active in the seed sector, acting both as a producer as an improvement of organic seed varieties, Living Seeds Sementes Vivas S.A. is concerned about the proposal of the European Commission. As specialists in genetic improvement for climate proofing, in particular heat and drought, we believe that significant changes are needed to ensure the availability of NGT-free food production.

Filed in Portuguese · English published by the European Commission

As a supplier of organic seed of seed of seed-fixed varieties, we strongly oppose the proposal for deregulation for several reasons: 1. Disregard for the precautionary principle: Deregulation allows genetically modified organisms to come into the environment and the plates without risk assessment, whose long-term effects cannot be explored or even researched.

Filed in German · English published by the European Commission

The BGA welcomes the European Commission’s proposal of 5 July 2023 to re-regulate New Genomic Techniques (NGT). From a scientific point of view, it makes sense to assess new plant varieties on the basis of their characteristics, regardless of the way in which they are produced. This is particularly true where there is no distinction between conventionally bred plants.

Filed in German · English published by the European Commission

We do not agree with the Commission’s draft regulation on plants produced by certain new genomic techniques. The Commission’s legislative initiative appears to be aimed at reducing the level of consumer protection, who is deprived of the possibility of being informed and free to decide on the choice of preferred foods.

Filed in Slovak · English published by the European Commission

We welcome this Commission proposal, based on a scientific study which clearly highlights the fact that the current regulatory framework is not in line with the issues related to new genomic techniques. In addition, it is important to stress that the European Food Safety Authority (EFSA) concluded that, as regards risks to human and animal health and the environment, there are no specific hazards linked to targeted…

Filed in French · English published by the European Commission

25.10.2023 Sehr geehrte Damen und Herren, liebe Verbraucher*innen, liebe Branchenangehörige und Unternehmer*innen, in der Wertschöpfungskette vom Acker bis zum Teller sind wir nur ein kleines, aber wackeres Pflänzchen. Seit 1994 betreiben wir inzwischen unsere 30 Bio-Märkte in ganz Franken.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ladies and gentlemen of the European Commission, as the manager of a demeter vegetable grower, we have committed ourselves not to construct and market genetically modified plants on our holding. This applies in principle to all plants that have been bred using both ‘old’ and ‘new’ genetic engineering.

Filed in German · English published by the European Commission

BioChem Europe, representing the biochemical sector in Europe, acknowledges the Commission's initiative to address the legislation for plants produced by new genomic techniques. As a pivotal stakeholder in the biobased chemical sector, we emphasise the significance of biotechnologies as key enabling tools for our sector and for the chemical industry in general.

I am in favour of the Commission proposal; supports science-based decisions; in favour of innovation in genetic improvement for the production of new varieties that contribute to food security and ensure the sustainability of agri-food production and rural development; There is a need for farmers to have tools to enable them to produce quality and to combat the effects of climate change, protection from pests and…

Filed in Spanish · English published by the European Commission

The future of the EU depends on our competitiveness and I am therefore in favour of the Commission’s proposal; supports science-based decisions; in favour of innovation in genetic improvement for the production of new varieties that contribute to food security and ensure the sustainability of agri-food production and rural development; There is a need for farmers to have tools to enable them to produce quality and…

Filed in Spanish · English published by the European Commission

As a farmer, I can tell you that nothing of good will come from obvious rape of nature, it is its support that will allow us to apprivatise it. Enough misleading research that enriches only those who do not need it and gives them the right to life and death on peoples

Filed in French · English published by the European Commission

I am in favour of the Commission’s proposal to support science applied to agriculture. A proposal that will allow us to further improve our crops and compete with non-European regions under similar conditions. A proposal that allows us to improve quality production and combat the effects of climate change without the need to resort to products that increase these effects.

Filed in Spanish · English published by the European Commission

I am in favour of the Commission proposal; supports science-based decisions; promoting innovation in genetic improvement to produce new varieties that contribute to food security and ensure the sustainability of agri-food production and rural development

Filed in Spanish · English published by the European Commission

The Grain Club is an alliance of four German food and feed industry associations, whose members represent the different stages of the cereal, feed and oilseed industry. In the agri-food value chain, member companies are active in the processing, manufacturing and trade sectors upstream and downstream of agriculture. Therefore, we will not address biological/breeding-specific aspects.

Filed in German · English published by the European Commission

The German Association of Biotechnology Industries (DIB) is the biotechnology branch of the Association of the German Chemical Industry (VCI). DIB represents the political-economic interests from small and medium-sized enterprises up to multinationals active in all application fields of biotechnology - from agriculture to industrial and all the way to medical biotechnology.

We disagree with the criteria for establishing equivalence between plants obtained by NGTs and conventional bred plants. These criteria were chosen arbitrarily and have no sound scientific basis. Many scientists say this, such as ENSSER that there is no scientific basis for asserting that new genetically modified plants meeting the category 1 criteria are equivalent to conventional plants…

Filed in French · English published by the European Commission

I believe that in order to address all anxiety related to climate, global warming and biotic stressors, the way in which new varieties are obtained must be updated. It is much safer than having a new variety where it is known that only a gene has been modified/edited/improved than varieties that are randomly crossed products and it is not known in which other genes have been modified/edited/improved or worsened…

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ENSSER e.V. * Marienstr. 19/20 * 10117 Berlin * Germany P [phone removed] F [phone removed] E [email removed] W http://www.ensser.org ENSSER-Stellungnahme: Der Vorschlag der EU-Kommission zu neuen GV-Pflanzen ist unwissenschaftlich und verschleiert deren Risiken 19.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Collective for Varietal Innovation brings together 30 organisations in the agricultural and agri-food sector particularly concerned by this draft regulatory framework. These sectors will have to select, cultivate, use and integrate innovative genomic varieties into their production systems, in the context of the increasing need to adapt to climate change and the search for food sovereignty, in order to offer…

Filed in French · English published by the European Commission

Ladies and gentlemen, we are a long-standing organic farm with direct marketing. Our customers buy from us because they can be sure that we are organic and do not use genetically modified organisms at any level. The current Commission proposal is unacceptable because it would no longer provide for the precautionary principle and freedom of choice for consumers and farmers.

Filed in German · English published by the European Commission

GMOs are entirely acceptable, but under various conditions, starting from being genetically modified not to resist pesticides but to be able to do so, or to be more water-efficient, requiring less irrigation. Or even better, for example in medication, to produce insulin, or a pulse for biomass or building materials, with a proven objective of bio-based construction.

Filed in French · English published by the European Commission

At hollandbio, the Dutch biotech association, we are convinced that biotech makes life better. To capitalize on the opportunities of the global biorevolution for health, sustainability, and the economy, a paradigm shift is needed. Instead of amending the current outdated laws and regulations for genetic modification, hollandbio prefers a fresh start with a clean slate.

CIBE welcomes the Commissions proposal on NGTs, removing NGTs from the scope of the GMO legislation which is not fit to regulate plants from these NGTs, especially mutagenesis and cisgenesis. CIBE supports the principle that the authorization and marketing procedures of conventional-like plant varieties obtained by these techniques (category 1 NGT plants) fully align the status of category 1 NGT in terms of safety…

We are a biodynamic gardening plant with a 400 m² farm shop/café. We have seen a growing number of customers for years. A modernisation/increase of our car park has just been completed and the farm shop will be enlarged next year, construction work has started. As a result, more and more customers want GM products to be free.

Filed in German · English published by the European Commission

It is essential for the EU to provide the necessary regulations for the use of this plant material. Supply companies and the scientific community base their work on safety and health. EU agriculture, and more specifically, southern European countries need new effective tools to facilitate the maintenance of agricultural ecosystems and the fight against and mitigation of climate change.

Filed in Spanish · English published by the European Commission

AGPB represents French cereal farmers who will be interested in new varieties adapted to the current climate change and enabling them to respond to the main challenges for a more environmentally, economically and socially sustainable agriculture. The European Commission has put forward a proposal which should establish a clear framework for the use of NGTs in varietal selection by 2026.

Filed in French · English published by the European Commission

Contribution by Phyteis (French professional organisation of the plant protection industry, in its diversity)/Transparency Register (Union8813981475). Yes to a proposal on NGTs that promotes innovation for a resilient and economically viable agriculture. Agriculture faces unprecedented challenges.

Filed in French · English published by the European Commission

Deutsche Umwelthilfe e.V. (DUH) welcomes the opportunity to comment on the proposal for a regula-tion (COM(2023)411) on plants produced by certain new genomic techniques. As a recognized non-profit environmental and consumer protection organization in Germany, we ask that our position be taken into account in the further proceedings. Deutsche Umwelthilfe e.V. (DUH) rejects the EU Commission's proposal.

I have long advocated new genomic techniques (NGT’s), which I see as essential for the agricultural sector and for meeting the targets proposed by the Green Deal, the implementation of consistent regulation based on scientific criteria, anticipating technological advances, especially as regards the regulation of plant material obtained through NGT’s.

Filed in Portuguese · English published by the European Commission

Considering the interest of our organisation in the development and implementation of gene publishing techniques, we welcome the fact that the current proposal differentiates between NGTs and GMOs. The application of NTG would mean for businesses such as our very significant acceleration in obtaining new vegetable varieties which, on the one hand, would increase our company’s competitiveness and, on the other hand…

Filed in Spanish · English published by the European Commission

I support the adoption of new genomic techniques, as long as it is considered safe by EFSA in light of the current scientific knowledge. Rejecting this technology could jeopardize the future sustainability of the European agriculture, especially in a context where we are heavily dependent on the import of raw materials for animal feed from third countries.

New genomic techniques should be used as a key tool for the sustainability of agriculture in Portugal and the European Union and assessed according to the scientific opinions of EFSA. The European Union should not reject this technology, provided that it is considered safe in the light of current scientific knowledge, since it is dependent on feed materials, is not an island and without such approval, it will create…

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BASF welcomes the European Commissions proposal for a Regulation on plants obtained by certain new genomic techniques, which introduces a differentiated regulatory approach for NGT-derived plants. To address current challenges, it is important to have an adequate range of tools and solutions, including NGTs, which have the potential to improve breeding processes, reduce timelines, and contribute to agricultural…

As an organic farm that has been passionately committed to sustainable agriculture for many decades, we would like to express clearly our serious concerns about the current draft. This development poses a serious threat to the diversity essential to organic farming. Many disadvantages and risks are not taken into account here. Why do we see this?

Filed in German · English published by the European Commission

Stellungnahme DES AGRARHANDELS zum Regulierungsvorschlag der EU für Neue Genomische Techniken Berlin, 03. November 2023 Über DEN AGRARHANDEL DER AGRARHANDEL ist die Interessenvertretung des Agrarhandels in Deutschland. Seine Mitgliedsunternehmen beliefern die Landwirtschaft mit Saatgut, Pflanzenschutz- und Düngemitteln sowie Futtermitteln.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position des Lebemsmittelhandels zum EU-Verordnungsvorschlag über neue genomische Techniken COM (2023) 411 final Einleitung Mit Datum vom 5. Juli 2023 hat die EU-Kommission ihren Vorschlag für eine Verordnung über mit bestimmten neuen genomischen Techniken gewonnene Pflanzen und die aus ihnen gewonnenen Lebens- und Futtermittel sowie zur Änderung der Verordnung (EU) 2017/625 veröffentlicht.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CIA Agricoltori Italiani, one of the major agricultural organisations in Europe presenting Italian farmers and agricultural business owners, satisfying the unity to provide feedback on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on plants produced by certain new genomic techniques and their food and feed, and amending Regulation (EU) 2017/625.

Filed in Italian · English published by the European Commission

The Danish Seed Council welcomes the European Commission recent NGT proposal. We need access to ever better plant varieties to adjust to changing climate conditions, to produce seed with less use of input factors (water, fertilizers, pesticides), to produce seed in a more environmentally friendly way, and to remain globally competitive.

FEDIOL, the EU vegetable oil and proteinmeal industry association, represents the interests of the European oilseed crushers, vegetable oil refiners and bottlers. We would like to thanks the Commission for the opportunity to provide comments on this initiative.

I strongly oppose a weakening of the legal genetic engineering system. Every consumer should have the choice to decide whether or not to consume modified foods using genetic engineering. As an organic beekeeper, if the legislation is weakened, I would no longer be able to understand whether my honey contains modified constituents.

Filed in German · English published by the European Commission

I believe that the Commission’s proposal for a GTN regulation is appropriate and science-based, provides the necessary guarantees for plant enhancers, farmers and consumers, allowing international trade and boosting sustainable growth in plant production, supporting research, innovation and investment. GTTs are essential for a sustainable EU agricultural transition

Filed in Portuguese · English published by the European Commission

ANOVE, an association that brings together companies and public centres dedicated to research, development and exploitation of new plant varieties, welcomes the fact that the proposal is in line with scientific consensus by establishing a regulatory framework for plants and products derived from New Genetic Techniques (NTGs) that is distinct from the legislation on genetically modified organisms (GMOs).

Filed in Spanish · English published by the European Commission

Europatat would like to thank the European Commission for the opportunity to provide our comments on the proposal for a Regulation on plants obtained by certain new genomic techniques (NGTs) and their food and feed. Please see our comments in the attached paper.

The Commission’s legislative initiative appears to be aimed at lowering the level of consumer protection: In its 2018 ruling, the European Court of Justice recognised that new genomic techniques (NGTs, also referred to as genome treatment techniques) produce and are GMOs, so they must be subject to the same safety, evaluation, control, traceability and labelling requirements.

Filed in Slovak · English published by the European Commission

Greenpeace EU Presse Briefing – Oktober 2023 Neue Gentechnik würde nach Plan der EU-Kommission Sicherheitstests umgehen - Greenpeace-Briefing Brüssel, Oktober 2023 - Am 5. Juli 2023 veröffentlichte die Europäische Kommission einen Plan zur Abschaffung der meisten Sicherheitsvorschriften für die Produktion und den Verkauf einer neuen Kategorie von gentechnisch veränderten Pflanzen, die mit Neuer Gentechnik (NGT)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

KWS welcomes the ECs proposal for a distinct regulation of plants from NGTs and its intention to relieve conventional-like plants from the regulation of genetically modified organisms. This legislative proposal will allow the EU agri-food sector to stay globally competitive and support the EUs green deal ambitions. However, KWS would like to comment on some aspects.

On 5 July 2023, the European Commission presented its proposal for a regulation to the European Parliament on plants obtained from certain NGTs. The banana sector in the French Antilles has historically produced an average of 250 000 tonnes of bananas. Bananas in the Antilles are indeed an area of structuring the economy of the ORs.

Filed in French · English published by the European Commission

As a regional wholesaler of more than 10.000 organic products and with more than 40 years of experience in the German organic market, we strongly oppose the deregulation of genetic engineering by Grell Naturkost. Deregulation of genetic engineering would cause massive uncertainty for consumers of organic products and simply limit their choice.

Filed in German · English published by the European Commission

As a farmer, this project seems to me to be an important opportunity to respond to the environmental challenges facing European agriculture in the 21st century. Genetic innovation is a major bias for reducing plant protection products in the future, while ensuring the productivity and competitiveness necessary for the survival of our farms, in the face of unfair competition imposed by non-EU countries.

Filed in French · English published by the European Commission

In 2020, the Nobel Prize for Chemistry was awarded to two scientists who developed genome editing technology. It is easy to understand the need to tackle the current lack of information and counter-information in public opinion on the topic of NGTs and the urgent need to avoid, at all costs, farmers being, as is almost always the case, the currency of exchange for imposing commercial policies and logic that only…

Filed in Portuguese · English published by the European Commission

The Union for the Promotion of Oel and Protein Plants (UFOP) represents the political interests of companies, associations and institutions involved in the production, processing and marketing of indigenous oil and protein crops in national and international bodies. UFOP promotes research to optimise agricultural production and product quality in order to develop new uses in the food, non-food and feed sectors.

Filed in German · English published by the European Commission

CEJA welcomes the proposal and willingness of the European Commission to create a new regulatory framework dedicated to targeted mutagenesis and cisgenesis for plants. Positive elements are: - A new regulatory framework - it would have many advantages for the environmental, social, and economic sustainability of farms.

It is essential for European food security and the sustainability of agriculture in Europe that this proposal is approved. New genomic techniques make it possible to quickly and accurately adapt cultivated varieties to ongoing climate and biotic changes, reducing production costs and using phytopharmaceuticals.

The German biotechnology industry association BIO Deutschland e.V. welcomes the Commission’s proposal to adapt EU genetic engineering legislation or the regulation of plants produced by certain new genomic techniques to the state of scientific knowledge. It is an important step in the right direction to enable Europe or its citizens to benefit from these innovative new technologies.

Filed in German · English published by the European Commission

We reject the Commission’s proposal, which runs counter to the precautionary principle, endangers RUs, human health and the autonomy of our agriculture. The Commission’s proposal will lose freedom of choice, and we will not abandon new GMOs.

Filed in Slovak · English published by the European Commission

Hello, NGTs are an indispensable solution for our farmers, we need access to varietal innovation in order to adapt tomorrow to climate change and new viruses and pests.

Filed in French · English published by the European Commission

I am fully in favour of this text, as the NGTs will create varieties (non-GMOs) that will meet societal expectations, the constraints of climate change (drought, diseases, etc.) and the cessation of many PPP molecules. It is a key lever for agroecology. The potato plant sector in France is strongly awaiting the outcome of this text. Improvements and clarifications can be made to this text, but the main thing is.

Filed in French · English published by the European Commission

CIOPORA Deutschland e.V. in principle welcomes the Commission’s proposal for a regulation on the regulation of new genomic techniques (NGT). The proposal shows that the current legal situation is no longer suited to the rapidly evolving global innovation landscape and that it must finally be discussed on a science-based basis.

Filed in German · English published by the European Commission

The new genetic engineering must be declared as such for seeds and seedlings. As a certified organic producer, it must be possible to avoid genetically modified organisms. My conviction does not permit the use of such seeds and plants. There must be freedom of choice and decision-making for me and my colleagues. Genetic engineering through the secret backdoor must not exist in a democratic society. Erhard Pfluger

Filed in German · English published by the European Commission

We manage a family farm in Saxony-Anhalt with a size of 450 hectares, as a pure conventional market fruit holding. Our particular crop is the ware potatoes, which cultivates around 50 hectares. Using this fruit as an example, I would like to explain why the new breeding methods for the farm are a step forward in arable farming.

Filed in German · English published by the European Commission

Genetic changes in the genome of a plant require strict labelling and traceability! As a biofarm, we stand for genetic engineering freedom. We want to be able to guarantee this to the consumer. Seeds are cultural goods. Spontaneous crossings and crossings in nature are possible. Co-existence in agricultural production of different cultivation practices must be ensured and the polluter pays principle must be ensured.

Filed in German · English published by the European Commission

We agree with the Commission’s proposal, but only on the assumption that a paragraph on the prohibition of patenting of products obtained by NGT1 is added directly to the Regulation. They are diagnostically indistinguishable from conventional breeding and must therefore not be covered by patents.

Filed in Czech · English published by the European Commission

Ladies and gentlemen, as the political umbrella of all cooperatives and cooperative businesses in the German agri-food sector, we call on the EU institutions to allow innovation and to use new genomic techniques. We support the draft regulation presented by the European Commission. Please also refer to the attached position paper of the Deutsche Raiffeisenverband e.V.

Filed in German · English published by the European Commission

Dear ladies and gentlemen, I would urge the European Commission to apply existing EU genetic engineering legislation to all genetically modified organisms (GMOs), whether using old or new genetic engineering techniques, such as: CRISPR/Cas. We are an agricultural company in Harsleben and we farm around 6 000 ha.

Filed in German · English published by the European Commission

The LRF welcomes the presentation by the European Commission of a new legislative proposal proposing to authorise the use of certain new genomic technologies in the EU. The proposal is long awaited and there is a strong need to develop more robust crops that are better adapted to a changing climate, such as more resistant to drought, wetting and plant diseases, and hence crops with less need for plant protection…

Filed in Swedish · English published by the European Commission

At this time, or the world’s population is constantly growing, concerns about food sovereignty for our people are growing, and social, societal and environmental demands for more respectful production are constantly increasing. NBT and all these new technologies are solutions to meet them. The world must continue to evolve and progress must not stop the progress that science continues to bring to us.

Filed in French · English published by the European Commission

In principle, we support the Commission’s proposal to regulate NGTs, despite some not insignificant shortcomings. The proposal follows the call made by many experts for independent rules for NGT plants. NGT plants are no different from conventionally bred plants and therefore need to be exempted from existing genetic engineering legislation.

Filed in German · English published by the European Commission

Ntg support is welcome for the search for new varieties. The lack of solutions to the ban on plant protection products leads us directly to the disappearance of producers of plants without resources. “No bans without solutions” what kind of promise is not held but the rest is “no seeds of food sovereignty”. There is an urgent need to: 2023 reduction of 13 % of potato sole 2024 between 40 and 60 %.

Filed in French · English published by the European Commission

Graminor Breeding Ltd. (www.graminor.no) is a pioneering plant breeding company dedicated to develop plant varieties tailored to the unique agricultural and horticultural conditions in Norway. With a social mission that revolves around developing and delivering plant varieties ideally suited for Norwegian farming environments, Graminor also extends its ambition to encompass the broader Nordic region.

Syngenta supports the Commission's proposal for a differentiated regulation of New Genomic Techniques (NGT) plants, which can lead to the development of resilient and sustainable crops, fostering innovation and competitiveness in the European Union.

FoodDrinkEurope represents the food and drink manufacturing industry, made up of 294,000 businesses, of which 99% are SMEs, with 4.6 million employees. Innovation in plant breeding is a key driver in delivering more sustainable and resilient crops, more secure harvests, and safe ingredients and food products.

I welcome the work carried out by the Committee, it is important to take account of new technologies capable of responding to climate challenges. If we cannot have access to them, distortions of competition would be such that food sovereignty would be seriously undermined, benefiting the exporting country, which is far from having our production standards.

Filed in French · English published by the European Commission

The Fédération Nationale des Syndicats d’Exploitants Agricole (FNSEA) represents French farmers who will be the first users of new varieties adapted to the current climate change and to the main challenges for more environmentally, economically and socially sustainable agriculture. The European Commission (EC) presented its proposal for a regulation on NGTs (new genomic techniques) on 5 July.

Filed in French · English published by the European Commission

Dear Sir/Madam, The DVT welcomes the Commission’s proposal for a Regulation establishing a new set of rules for the use of new genomic breeding techniques (NGT) and the resulting products. The Commission proposal takes into account the need for differentiated regulation of NGTs, taking into account current scientific knowledge.

Filed in German · English published by the European Commission

The Commission’s proposal on new genomic techniques (NGTs) allows breeders of all sizes and public research institutions to develop and approve more resilient and sustainable plants. This is a key to maintaining our agriculture and food security, especially in view of the ongoing change in climate conditions.

Filed in German · English published by the European Commission

The European Commissions proposal for plants produced by certain new genomic techniques (NGT legislation) is a sign of its commitment to timely and relevant policymaking to ensure food security and tackle environmental challenges such as climate change and biodiversity loss.

It seems to me that it is important to continue research on genetics in order to address future environmental and climate issues. Moreover, technologies used today in agriculture allow us to grow plants such as sunflower, in places or it would be impossible without casual, cutting this technological lead would still lag behind us globally and catch up for the lost time will be impossible.

Filed in French · English published by the European Commission

Humanity should leave it up to nature to manage genomes. We are attacking biodiversity and therefore all these extraordinary forms of life. We forget the essence of our rules on overconsumption, financial and political power. This company is to be vomir. It has a human name only. Thank you to all those who fight for all forms of life. Pick up a vamp for others and wrap up!

Filed in French · English published by the European Commission

Legislation must be able to develop and implement new genomic techniques to ensure our food sovereignty. This is one of the few alternatives to the ban on certain plant protection products and most certainly a solution to adaptation to climate change.

Filed in French · English published by the European Commission

The Hungarian Biokultura Organisation, which is the umbrella organization for organic movements in Hungary and Biokontroll Hungaria Nonprofit Kft. which is the contracted CB for the vast majority of the organic producers in Hungary would like to share all concerns and statements IFOAM Organics Europe expresses in its document on NGTs dated in October 2023.

The Novo Nordisk Foundation and its investment company Novo Holdings welcome the proposal for a regulation from the European Commission for plants produced by certain new genomic techniques (NGTs). The proposal is a chance to create a forward-looking regulatory framework that promotes innovation and adapts to the scientific progress.

FEFAC representing the manufacturers of feed for food producing animals welcomes a rather well-balanced proposal that acknowledges the potential of NGTs to contribute to the transition to more sustainable food systems. We welcome in particular the dual approach, with 2 categories of NGTs depending, the criteria for distinction between the two categories and the level of regulatory requirements.

Feedback of Fairtrade International on the EU Proposal on New Genomic Techniques: The EU is equipped with an effective GMO legislation, based on transparency, labelling, and safety checks including a proven authorisation procedure.

The German sugar industry welcomes the fact that, with the legislative proposal on NGTs, the Commission has put forward a legal framework which, in contrast to outdated genetic engineering legislation, takes account of the scientific progress and knowledge that has been achieved in the meantime.

Filed in German · English published by the European Commission

I am in favour of this legislation, we need to work on its new techniques, it is vital to feed the world tomorrow in an environment where droughts are increasingly important. If we have to produce fewer phytos and fewer fertilisers, use less water resources and continue to eat, this will require research. Stop the diabolishment of new techniques, we cannot afford to live as 100 years ago, the world is changing...

Filed in French · English published by the European Commission

Plant breeders and Saagut Producers of the IG Seeds reject the Commission’s fundamentally missed deregulation proposal. This is because it runs counter to the precautionary principle as a central principle of European environmental law, abolishes freedom of choice and jeopardises small and medium-sized breeding companies through a flood of patents.

Filed in German · English published by the European Commission

Dear ladies and gentlemen, I am opposed to a weakening of existing EU law with regard to certain categories of NGTs for several important reasons: New genetic engineering processes will not make our planet fit for the future. Changing individual genes does not lead to increased tolerance compared to numerous environmental impacts (drought, heavy precipitation, storm, etc.) that are associated with climate change.

Filed in German · English published by the European Commission

The attached document presents the comments on the standard prepared by the Brazilian Ministry of Agriculture and Livestock. The comments made in this document are intended to contribute to the improvement, however, point to the need for changes to the proposed standard. Thank you for your opportunity to contribute with this public consultation process.

Filed in Portuguese · English published by the European Commission

From Bioland’s point of view, there is no need to amend the existing genetic engineering legislation. Deregulation is likely to have a far-reaching impact on the European agri-food sector. In addition, many issues, including the issue of patenting, remain unresolved. A change in the regulation of the use of genetic engineering in food and feed is not a decision that should be overturned or lightly shouldered.

Filed in German · English published by the European Commission

26 October 2023 Komm2023/00637/LI 2023:02-1 Ministry of Rural Affairs and infrastructure [name removed] ([email removed]) [name removed] [email removed] European Commission Feedback on the NGT-proposal We represent an official Swedish investigation “Forest tree breeding for increased resilience, LI 2023:02” at the Ministry of Rural Affairs and Infrastructure in Sweden.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear ladies and gentlemen, I would like to ask you and expressly ask you not to weaken existing EU legislation on genetic engineering. New genetic engineering techniques also pose an uncontrollable risk to nature and, above all, to consumers. The provision that genetically modified plants or products with genetically modified content must be clearly labelled and that is good.

Filed in German · English published by the European Commission

Ladies and gentlemen, we are very concerned about the planned deregulation of genetic engineering law and see our existence threatened by this! We are a small-scale family farm in the altitudes of the Black Forest and have been operating in the second generation since 1988 in accordance with Demeter guidelines. We are a multi-layered farm with different stand legs.

Filed in German · English published by the European Commission

Every day we still experience harmony between earth – plants – animals – humans – cosmos and we feel responsible for maintaining it for future generations. We, as humans, can only live well with and on the organism Earth if we live with the earth in the way we live with the Earth’s well-being – in the sense of animal or child welfare, or a life that is fulfilled for us.

Filed in German · English published by the European Commission

Durch die Definition als technischer Eingriff wären die Produkte aus Züchtung mit neuer Gentechnik patentierbar. Das würde zu weiteren Abhängigkeiten der Landwirtschaft von Saatgutkonzernen führen und unabhängige Züchtung unmöglich machen.

After a detailed analysis of the Commission’s proposal for a regulation, the Working Group on Farmers (AbL) e.V. concludes that the legislative proposal is incorrect and must therefore be withdrawn. If the proposal for a regulation were adopted, almost all new genetic engineering (94 %!) would in future enter our seeds, our food production chain and our environment unchecked, non-transparent and uncontrollable.

Filed in German · English published by the European Commission

The Glastuine Region welcomes the fact that the Commission is reflecting on the use of Genetic Technology. The basic principle should be that the modification facilitates and accelerates normal processing. It is desirable that only species-specific properties are added (cisgenic). The aim should be to improve the crop, for example pest resistance, and never resistance to plant protection pesticides.

Filed in Dutch · English published by the European Commission

Cereals Canada has several comments for consideration by the European Commission regarding the proposal on plants obtained by certain new genomic techniques (NGTs) and their food and feed, amending Regulation (EU) 2017/625 (thereafter referred to as the proposal).

General statements: Limagrain welcomes the NGT proposal which exempts some conventional-like NGT-derived plants (NGT1) from the OGM legislation. The conventional regulatory status of the NGT1 plants will enable the resulting varieties to reach the European market to support the "Farm to Fork" strategy and provide some benefits to the European agriculture and value-chain notably by tackling climate change and…

AssoBio, the Italian national association of processing and distribution companies for organic products, is strongly against the changes concerning organic in the rapporteurs draft report on New Genetic Techniques (NGTs). Crucially, the responsible rapporteur in the ENVI committee proposed to remove the ban of Category 1 NGTs in organic (Article 5(2)).

Plantum welcomes the proposal published by the Commission outlining an approach to regulate certain NGT-products that are conventional-like differently from the current GMO legislation. The European Union should seize this opportunity to regulate NGT proportionately, to fully unlock the potential these technologies have to contribute to solutions for various global challenges.

The EU Commission proposal lacks of any evidence for assumptions made from alleged safety of NGT that isn't based on EFSA opinions, is abolishing the precautionary principle and does not reflect any element that was raised by civil society since beginning of 2020 and should be rejected.

Kungl. The Forest and Agriculture Academy (KSLA) seeks to contribute to debate on plant biotechnology and its applications. The Växtnoden project was established for the end of 2020/21 for information and up-to-date knowledge for policy makers and the food chain. The KSLA welcomes the Commission’s proposal for a lighter regulation of NGT plants than for GMOs.

Filed in Swedish · English published by the European Commission

Best, plant genetics and plant breeding are extremely important. Over time, plants adapt to new circumstances. Genetic plant material is constantly evolving. In Europe, we were also at the forefront of the development of new safe plant breeding, but the overly strict European legislation shows that knowledge developed here is being used elsewhere in all continents. This creates unfair competition.

Filed in Dutch · English published by the European Commission

1. Inari, the SEEDesign company, pioneers innovative seed technology aligning with the European Green Deals objectives for innovation and sustainability. Leveraging new genomic techniques (NGT), our goal is to amplify yield of soybeans, maize, and wheat by 10-20% without requiring additional land or inputs. We also aim to curtail water and nitrogen fertilizer requirements for maize cultivation by 40%. 2.

Naturkost Ernst Weber GmbH imports and trades only foodstuffs from controlled organic crops since 1990. We are convinced that climate resilience and sustainability in (eco) agriculture can only be produced through biodiversity, meaningful crop rotation and sustainable water use and soil management systems. NGT plants do not have the potential to contribute decisively to this.

Filed in German · English published by the European Commission

The European Landowners Organization (ELO) welcomes the publication of the Proposal for a Regulation of the European Parliament and the Council on plants obtained by certain new genomic techniques and their food and feed, and amending Directives 68/193/EEC, 1999/105/EC, 2002/53/EC, 2002/55/EC, and Regulation (EU) 2017/625 ELO recognizes the potential of NGTs in offering precise and efficient breeding techniques…

Dear ladies and gentlemen of the relevant EU police bodies, as the operator of a biologically dynamic vegetable gardening with a customer base between Berlin and Hamburg, I am jointly responsible for the production of healthy, natural food for our population.

Filed in German · English published by the European Commission

The Biodynamic Federation Demeter International, representing the biodynamic farming movement worldwide as part of the organic sector, welcomes the possibility to provide feedback on the legislative proposal on plants obtained by certain new genomic techniques (NGTs) and would like to share our utmost concerns regarding the proposal.

Since 1981, as organic wholesalers, we have supplied the north-east of Germany. In short distances, we buy organic products (Regulation (EU) 2018/848) from regional organic farmers, gardeners, dairies and many other producers. In addition to the seasonal/regional range, we offer a full supra-regional ecological range.

Filed in German · English published by the European Commission

Member of the External Advisory Board of the HORIZON InnOBreed project (2022-2026) Innovative Organic Fruit Breeding and uses, I believe that researchers who are going to engage in hybridisation work should be able to use NTG-1 plants as broodstock and thus offer new, climate-resilient AB varieties labelled NTG-1 on the markets. Yves Lespinasse INRAE

Filed in French · English published by the European Commission

Innovation in the plant breeding sector is among the levers that will enable European agriculture to successfully make the transition to a more resilient and sustainable form of farming. This legal proposal is, thus, key in contributing to the Farm to Fork and Biodiversity Strategy objectives such as improved pest-resilience, tolerance to climate change and environmental stress as well as enhanced nutrient and…

The French Union of Seminers (UFS) welcomes the proposal for a regulation on NGTs and believes that there is a good basis for work. Indeed, the use of NGT1 plants (equivalent to conventional plants) from the GMO legislation is the major point for enabling seed companies established in the territories to use these techniques if they so wish.

Filed in French · English published by the European Commission

Committee of the European Starch Potato Producers' Unions (CESPU) The farmers representing seven European countries generally welcome the European Commissions proposal on NGTs (COM(2023)411 final). Farmers growing starch potatoes want to contribute to the European Green Deals Farm to Fork Strategy and support tools making it possible to reduce the use of pesticides, energy and other inputs in production of starch…

IFOAM Organics Europe, the European umbrella organization for organic food and farming, welcomes this opportunity to provide feedback to the Commissions' published legislative proposal for plants produced by certain new genomic techniques. The European organic movement has significant concerns with this initiative as it will have far-reaching impact on the European agriculture and food sector.

Plant breeding went too far. Let’s stop the frightened development of our food. NBT exists only for the ever-increasing enrichment of giants who privatise seeds, our common good. Let’s forbid and refuse these new GMOs hidden in our crops and plates.

Filed in French · English published by the European Commission

We are welcoming the Commissions proposal for a modern NGT-legislation. Our view is that the conventional-like plants, as defined in the proposal, should be treated as such and have a smooth, efficient and science-based verification process.

Dear ladies and gentlemen, I am a farmer and farm a larger conventional arable farm in Saxony-Anhalt Germany. For many years, we have been growing wheat, barley, triticale, sugar beet, maize, rapeseed, peas and potatoes. As a result of this variety of cultivation, good seeds are extremely important to me. We collect seeds from many breeders and I am therefore against patents for breeding or breeding methods.

Filed in German · English published by the European Commission

Dear Commission, I am accompanying 60 companies in Northern Germany who trade in organic products specifically with Demeter products. Among you are both conventional food retailers (EDEKA, REWE, Kaufland, Batels-Langness) and natural food retailers (dennree, Weiling, the regional ones).

Filed in German · English published by the European Commission

As the oldest organic farming association in Germany, we ask you to take account of the freedom of choice of increasingly bioaffinous citizens in Germany and Europe when drawing up the legislative proposal on new genetic engineering. The organic sector has provided basic impetus for future food security in all areas.

Filed in German · English published by the European Commission

Organic farming is only possible without genetic engineering. This is demanded not only by organic farmers and many conventional colleagues, but also by a large part of the population in Germany. Full traceability and labelling of genetically modified organisms is essential. There are not only many farms, but entire regions that want to remain GM-free. This decision SHALL be respected. Best regards, [name removed]

Filed in German · English published by the European Commission

PFP answer to the Commission consultation on the NGT legislative proposal The Primary Food Processors (PFP) welcome the European Commission proposal for a Regulation on plants obtained by certain new genomic techniques and their food and feed and in particular welcome the differentiation between plants deriving from targeted mutagenesis and cisgenesis from transgenic GMO products.

France Nature Environnement (FNE), representing 6209 affiliated associations, i.e. 900.000 citizens, strongly opposes the adoption of the proposal for a Regulation on plants obtained through NGTs. If these rules were to be adopted, these new GMOs would be cultivated to ensure that citizens do not pose an environmental risk and are marketed without a final study guaranteeing and ensuring that consumers do not pose a…

Filed in French · English published by the European Commission

Ladies and gentlemen, organic farming is endangered by the proposal to authorise the new genetic engineering. How can one distinguish between cultivation in practice? If the responsibility lies with organic farms and processors, it will be impossible for us to carry out organic farming. The polluter pays principle is reversed.

Filed in German · English published by the European Commission

Any new proteins can induce direct or cross immunoallergic reactions, with health consequences. Precautionary principle should be applied as side effects are poorly assessed, especially for NGT plants. NGOs have no need other than a productivist vision in the long term. This can be done, therefore, neither urgent nor a valid justification for overlooking precautionary measures.

Filed in French · English published by the European Commission

French Plant Biotechnologies Association (AFBV) and its German partner, the Wissenschaftskreis Genomik und Gentechnik (WGG) are pleased with the important step represented by the EC's proposal to adapt the regulation of genetically modified plants dating from 2001.

The COORDINATION GEGEN BAYER FOUNDS (CBG) rejects the Commission’s proposal for a regulation on plants obtained by certain new genomic techniques. Although the groups do not transfer genes of extraneous organisms to the plants and the number of interventions remains below 20, the risks posed by the technologies do not allow arable crops to be treated in the same way as conventional crops and to avoid a risk…

Filed in German · English published by the European Commission

The German Farmers’ Association (DBV) welcomes the Commission’s initiative to bring about separate regulation of the so-called New Genomic Techniques (NGT) and New Breeding Techniques (hereinafter referred to as NBTs).

Filed in German · English published by the European Commission

Nature is wonderful enough not to be obliged to play sorcient apprentices with it without knowing the impact on our survival. We have seen side effects just shortly after the injection on the health of COVID-19 vaccinates, and we do not know what this will be over several years. Since I am not aware of the impact of ingestion of modified products, I refer to the precautionary principle.

Filed in French · English published by the European Commission

Dear ladies and gentlemen, we are building potatoes on our farm and have to treat them as a preventive measure against herbaceous rot with plant protection products up to 10 times. The breeding of new resistant varieties using the new breeding methods could significantly reduce our use of plant protection products.

Filed in German · English published by the European Commission

Corteva Agriscience welcomes the Commission proposal on NGTs and the depth in which the impact assessment was conducted. Like many countries around the globe, the proposal acknowledges that plants developed using NGTs are fundamentally different from use of the established GM methods resulting in transgenic plants and that the final products are similar and often indistinguishable from conventionally bred plants.

Dear Ladies and Gentlemen, Enclosed we are sending the statement of the German Consumer Organisations (Verbraucherzentrale Bundesverband vzbv) on the EU Commission's proposal on new genetic engineering as well as the summary of the opinion in the text below. Best regards [name removed] want freedom of choice and a high degree of safety when it comes to both traditional and new genomic techniques (NGTs).

Seeds Canada is the leading voice of the seed sector in Canada and develops and advocates for policies that help its members stay competitive in domestic and international markets and encourage collaboration, innovation, equal opportunity, and continued investment in the seed sector for the betterment of the seed sector, consumers, and the environment.

- The proposal sets a Category 1 (conventional-like) whereby NGT products undergo a verification process to confirm if they have met the required criteria listed in Annex I. Yet, even if meeting the specified criteria, and being deemed conventional-like, these products be subject to a different regulatory framework as conventional breeding products, that create unjustified complexities and barriers, including: being…

Hjelle Consulting Group, LLC is a global company with regulatory expertise, active in the development of agricultural products using new biotechnology techniques, assisting small to medium-sized companies. We appreciate the opportunity to submit comments on the European Commission proposal 2023/0226 (COD) on the regulation of plants obtained through certain new genomics techniques. 1.

The Senior Expert Chemists (SEC) are a section of the Deutscher Chemiker Gesellschaft (GDCh). In principle, the SEC supports the Commission’s proposal as it will make it possible to translate scientific knowledge and innovation into practical applications in the European Union itself. With self-developed crops, the EU would be able to solve urgent problems in agriculture and make farming sustainable.

Filed in German · English published by the European Commission

It is absolutely unthinkable to authorise GMOs on European soil. At a time when heart disease is polluted, it is essential to consume locally and only locally, with 100 % natural agriculture. GMOs are not the nature I want to eat, nor the nature I want for our offspring. The EU is dying by decisions that are still being made despite common sense.

Filed in French · English published by the European Commission

NGT plants (or ‘new genomic techniques’) have been classified as GMOs since 2018 and their cultivation is therefore prohibited in the European Union. In my view, it is impossible to relax the rules in force, given the consequences that this would have on public health in general. I am strongly against this proposal to relax NGT plant legislation.

Filed in French · English published by the European Commission

GMOs are subject to strict and largely justified EU regulation, NBT or NGTs must not escape it either. The arguments of industrialists as to why they, by their different method, are not GMOs are unfounded. European Directive 2001/18 defines a ‘genetically modified organism (GMO)’ on the basis of the technique by which it was created.

Filed in French · English published by the European Commission

Neither GMOs nor plants handled. In the Naturel, we see a variety of varieties, the number of which has been dramatically reduced for consumers. Who would benefit from these NGT plants? Certainly not to the fans of fruit and vegetables to whom the agri-food industry is seeking to remove the fruit and vegetables, and the qualities that nature produces.

Filed in French · English published by the European Commission

Genetic manipulation, whether using genetic editing techniques such as Crisper-Cas 9, Talen, zinc finger nucleotides, and others, has an extremely high rate of errors, and the rate of failure and mutations over several generations is not unknown. It is a privatisation of seeds. It is generally intervention on unpatented seeds that then becomes patented.

Filed in French · English published by the European Commission

Hello I really do not want the European Union to relax the rules on NGT plants. Our children do not deserve to be subjected to plants classified as GMOs. I think it is important to bear in mind the pressure of agro-industrial lobbyists: biodiversity must be preserved at all costs before it is too late. We see too much of the damage caused by those who are primarily looking for their personal benefit!

Filed in French · English published by the European Commission

Wernsing Feinkost GmbH is a well-known producer of high-quality foodstuffs, mainly potato products, in the north-west of Germany. As such, providing consumers with healthy and safe food is an absolute priority. Recent years have shown that reliable production of agricultural raw materials is becoming increasingly difficult due to extreme weather events.

Filed in German · English published by the European Commission

Hello, Man plays on Sorcid apprentices by continuing genetic manipulation. We need to learn how to consume less and responsibly to avoid GMO products, NGT plants. We should feed ourselves that what TERRE can produce naturally, everything that is not natural is due to man’s desire to make a profit at the expense of health and the precautions we have to take with the new technilogies.

Filed in French · English published by the European Commission

Confagricoltura welcomes the Commissions proposal for a regulation on plants obtained through some new genomic techniques (NGTs). The initiative defines rules adapted to new genomic techniques, simplifying the authorisation procedures and risk assessment requirements for GMOs, while at the same time overcoming legislation on transgenic organisms, which is not adequate for the varieties of plants and products…

I do not want to approve things for which I have no guarantee in terms of genetic safety: what about contamination to unmodified species? Are there also guarantees on the nutritional potential of the organisms in question? Are there any details of the overall and specific immune level?

Filed in French · English published by the European Commission

Kokopelli strongly opposes the authorisation of the use of NGT plants. These plants, obtained by agronomic methods suitable for the creation of genetically modified organisms, do not differ in any way from the same GMOs currently banned in the European Union.

Filed in French · English published by the European Commission

There is an urgent need to stop handling and processing plants and their genomes. It is hard to want to play sorry apprentices in all areas, we no longer understand what the Next LOIS means and demands. It’s time to listen to “natural” nature and stop all traffic of any kind! Hubris, who wants ever more, causes disasters and we are already there...

Filed in French · English published by the European Commission

It seems to me to be dangerous to talk about food safety when new genomic techniques propose nothing other than introducing Genetically Modified Organisms. Its consequences are serious for both human health and a direct attack on biodiversity. In addition, we must not overlook the danger of putting the food of society as a whole in the hands of a few companies.

Filed in Spanish · English published by the European Commission

Would it not be useful to ask us whether the capitalist finance dict does not reach its limit? Would it not be more appropriate to take the time to think calmly together to remedy our eco-system by keeping ourselves more humanely and collectively to try to save what remains to leave a viable world for our children?

Filed in French · English published by the European Commission

I firmly believe that all plants and GMO products should be excluded from French territory. The French deserve a healthy diet in order to preserve the capital health they have at their disposal. The government should know that too many modified foods are damaging to the health of French people. Thanks

Filed in French · English published by the European Commission

Hello, this deregulation project is ideal. It shows that the Commission is closer to industrialists or faith in Progress than citizens. One of our criticisms is that it undermines the credibility of the Commission, but also of all the European institutions, including EFSA.

Filed in French · English published by the European Commission

You are said to be a committee serving Europeans, not multinationals. Play your role in defending consumer health by banning any substance that we have no control or backsliding... I am not talking about the vaccine, as you have already allowed a major experience to be carried out on European citizens. Do not start again with our food and nature... You will be held responsible for your choices when you arrive.

Filed in French · English published by the European Commission

We should remain faithful to our beliefs and focus on a long-term vision of our society. Otherwise, our speeches will remain speeches. Call for a return to more natural methods, otherwise we will never be able to repair the damage we have caused to the environment and the health of our people.

Filed in French · English published by the European Commission

NGT plants are prohibited, lobby pressure to lift this ban should not be accepted at the risk of providing companies specialising in these projects with reducing biodiversity to seeds produced by themselves by limiting farmers’ action to healthy diversity and allowing bees to promote pollination Cordially Olivier Laurent.

Filed in French · English published by the European Commission

I am OPPOSEE to accept the introduction into Europe of plants handled with new genomic techniques. It is high time to regain the rationale and not to become smarter than nature by introducing plants that will destroy biodiversity in the long term. It is also high time to take a clear setback on the pressure of companies, which is trying to gain ever more without measuring the consequences.

Filed in French · English published by the European Commission

I am absolutely against a return to GMO farming that favours organic farming or permaculture that protects much the environment in which we live. I am not talking about protecting the planet, as it does human and the damage it causes, she has already experienced 5 major fire extinguishments and she can live a sixth without problems.

Filed in French · English published by the European Commission

It is another scandal that will push people out of the EU! The French Frexit is 2 fingers! Germany votes overwhelmingly AFF... Be realistic and Stoppez now. And because I am there, urgently reform the article on the free movement of goods, people and capital between Member States and third countries! Yours sincerely,

Filed in French · English published by the European Commission

I am completely opposed to the use of gene techniques in plants intended for human consumption, both directly and indirectly through animal feed. We do not control all the consequences of this gene manipulation. Pseudo RNA vaccines for covid 19 are an indication of these uncontrolled manipulations.

Filed in French · English published by the European Commission

Hello, EU legislation has been clear and has applied the precautionary principle to GMOs for several years. Why would this change? These new plant technologies are of the same type, legislation must not change. There are already too many sanitary problems with plant health, but this is not a question of adding.

Filed in French · English published by the European Commission

NGT PLANTS (OR ‘NEW GENOMIC TECHNIQUES’) SINCE 2018 HAVE BEEN CLASSIFIED AS GMOS AND THEIR CULTIVATION IS THEREFORE PROHIBITED IN THE EUROPEAN UNION. TODAY, UNDER PRESSURE FROM AGRO-INDUSTRIAL LOBBYISTS, THE EUROPEAN COMMISSION IS CALLING FOR THESE RULES TO BE RELAXED AND, ONCE IT IS NOT CUSTOMARY, IS TRYING TO FORCE GMOS! I DISAGREE WITH THIS. IT IS QUITE FORBIDDEN TO DO SO. IT IS GOOD FOR YOU.

Filed in French · English published by the European Commission

These new plant products run counter to the natural evolution and adaptability of the plant rule to remain in symbiosis with its environment. Once again, these technologies, driven by agro-food lobbyists, are once again promoted in order to take advantage of the weaknesses of European laws when it comes to the protection of life.

Filed in French · English published by the European Commission

Hello, while there are undeniable advantages in producing GMOs, the fact remains that not all doubts about possible adverse consequences have been fully removed. The first of these risks is the threat posed by GMOs to human health. Studies have shown that toxins produced by GMO crops kill insects that are harmful or harmless for cultivation. For those reasons I am against the use of those genomic products. Cordially

Filed in French · English published by the European Commission

I am against genetically modified organisms. Precautionary principles and because there are other non-intrusive methods for making healthy farming for public health. Agricultural lobbyists want to force the EU to introduce GMOs simply for profit and not to feed the planet. The European Union has already decided to prohibit them from doing so.

Filed in French · English published by the European Commission

Hello, I am a physiotherapist, a holistic therapist and energetic therapist. I reject these new farming practices, which are an aberration. The problems we face today are the result of our behaviour and the lack of respect for nature laws. Continuing to do so is irrelevant.

Filed in French · English published by the European Commission

“Technologies” are by no means future-proof solutions. They move away from living processes, they are the private property of people whose interest is not the common good. No transgenic plants must leave the laboratories. Any modified plant (GMOs, CMS, NGT, etc.) is a waiver of life, the common good, the general interest. The seeds must be produced by the peasants and farmers who use them.

Filed in French · English published by the European Commission

I am opposed to any relaxation linked to plans for the marketing of GMOs in the European Union. Let us not give the pressure of agricultural lobby and let’s keep our species and farming areas intelligently alive. Let’s think more about farming practices that are more respectful of our ecosystems on the one hand and that on the other hand can create a virtuous economy.

Filed in French · English published by the European Commission

Hello, as a mere citizen, committed to preserving life, and a member of the Abeillement Our Association for educational purposes, I am not for mass agriculture but for a mass of farmers with sensible and reasonable practices. And it is high time to change our direction for good and respect for as many people as possible. So I am against the development of NTG plants. Reasonably yours, Charlotte Baron

Filed in French · English published by the European Commission

I am against the development of genomic techniques on living. I am a vegetable and very concerned about the consequences of these production methods. The threat of disappearance of old varieties, from natural varieties to non-reproducible plants.

Filed in French · English published by the European Commission

There is no ecological interest, it is bad for health and proven that the more scientific changes occur, the more health problems are experienced by consumers. Plants that are natural adapted are much more productive, have a more taste in the plate and are more nutrient rich. I am against this legislation.

Filed in French · English published by the European Commission

I do not want GMOs or any other name of a genetically modified plant, there are already a lot of vegetable varieties rather than wanting to cultivate more for yield and waste may limit waste (especially in schools).

Filed in French · English published by the European Commission

Genome modification techniques should be reserved for scientific work to develop medicinal products. With regard to agriculture, the diversity of seeds exchanged between farmers must be encouraged and this diversity should not be entrusted to laboratories which will seek to create monopoly situations.

Filed in French · English published by the European Commission

At a time of global warming, these new techniques for changing the genome seem to be welcome, but the abuses linked to their widespread use are well present. Unfortunately, this welcome citizens’ consultation via this survey will not give us democratic respect for the decisions voted on by the European Parliament, our representatives.

Filed in French · English published by the European Commission

it is my opinion that plants and plants around which do not create, plant, distort or play with nature, since 3 billion years, nature has not needed humans to enrich themselves, but humans have recently needed to enrich themselves with nature, lobby and us, for us to be dangerous...

Filed in French · English published by the European Commission

Hello, it has been known since 2014 after 4 years of testing that another agriculture is possible. The Bec Hellouin farm – followed by INRA, and many others in permaculture are examples of productive intelligence!). So why is there a lot of partisan politics for big firms and lobbyists that we still have to swallow us with poison? 10 Hect. produces as much as 100 permaculture. .

Filed in French · English published by the European Commission

Hello, the endocrine disruption of processed and domesticated industrial food is the main cause of the epidemic of overpoid-obesite-diabetes in the world. It is now a scientific matter and its corolar, the health benefits of organic farming which, in the face of its success, are suffering an unprecedented attack on the states, as if states did not want the well-being of their citizens.

Filed in French · English published by the European Commission

As a plant breeder and farmer, I welcome the Commission’s compromise on the regulation of new genomic techniques (NGTs). It takes into account scientific evidence and recognises the need for a differentiated regulatory approach for organisms from NGTs. In particular, for plants that do not differ from conventionally bred, the current GMO regulation does not constitute an adequate legal framework.

Filed in German · English published by the European Commission

The BDP welcomes the Commission’s proposal for a regulation on the regulation of NGTs. It takes into account scientific evidence and recognises the need for a differentiated regulatory approach for organisms from NGTs. In particular, for plants that do not differ from conventionally bred, the current GMO regulation does not constitute an adequate legal framework.

Filed in German · English published by the European Commission

The Bundesverband Naturkost Naturwaren e.V. (BNN) represents manufacturing, wholesale and retail companies in the natural food and natural goods sector in Germany. The Association adopts specific quality guidelines for the trade in natural foods that go beyond the legal requirements for organic products. Organic products are subject to a ban on GMOs.

Filed in German · English published by the European Commission

Dear Reader. I lived in the countryside where industrial agriculture is upsetting on a daily living basis. Regulatory capture is also a problem Regulatory capture is extortive and unhealthy for populations. When regulators are obsessed with marketing, its a dereliction of duties. An array of chemical products should gain little favour.

we live in complex systems (ecosystems, societies, etc.), however, no assessment has been made and is not foreseen as to whether these biotechnologies interfere with the dynamics of these systems. These are just fewer living systems on which we depend entirely! Traditional analytical assessments do not in any way address these fundamental issues.

Filed in French · English published by the European Commission

Novozymes welcomes and supports the Commissions initiative to modernize the GMO Directive, starting with plants produced by targeted mutagenesis and cisgenesis. We indeed agree with the conclusions in the Commissions study on the status of new genomic techniques, confirming that the current regulatory system involves implementation and enforcement challenges in the EU.

The new draft legislation on genetic engineering is not acceptable to us at all. Why should we amend a well-functioning law on genetically modified plants and animals in the EU and refrain from approval, traceability and labelling? To date, there is safety for all those who want to be free from GM without being able to work in Europe.

Filed in German · English published by the European Commission

The Federal Chamber of Labour (BAK) is the legal representative of the interests of around 3.7 million workers in Austria. It represents its members in all social, educational, economic and consumer policy matters, both at national and at the EU level in Brussels. The BAK criticises the Commission’s proposal, which has the clear aim of facilitating the cultivation of new genetic engineering in the EU.

Filed in German · English published by the European Commission

We oppose a deregulation of GMO for several reasons. One of them being that the proposal does not address the EU citizens lack of trust of corporations in this sector. If there was trust there would be no issue buying with food that is GMO labeled. See the attached file for the feedback.

The Basic EU Organic Regulation prohibits the use of GMOs as genetic engineering is not compatible with the principles of organic farming. NGTs also actively intervene in the genetic heritage and cannot therefore be exempted from a labelling requirement.

Filed in German · English published by the European Commission

OPTA Europe - www.opta-eu.org - is the membership organization representing the interest of EU organic processing and trade companies, as officially recognized by EU institutions. Its membership encompasses 12 EU Member States plus 2 non-EU countries. Taken together, the companies represented by OPTA Europe account for a large share of total EU import & export and processing of organic products.

Argentina welcomes and supports the publication of the EU proposal on the regulation of some New Improvement Techniques (NBT). We believe that the EU’s decision to advance the treatment of NBTs is a commitment for the future of these products and for the coordination and synchronisation of their analysis in the world.

Filed in Spanish · English published by the European Commission

So nicht! Aber anders? Bemerkungen zum Kommissionsvorschlag über NGT-Pflanzen von Gerd Winter1 I. Einführung Die Europäische Kommission hat einen Vorschlag zur Reform des Gentechnikrechts veröffentlicht2, der für Pflanzen aus bestimmten neuen Gentechniken (NGT) gewisse Erleichterungen des Kontrollregimes des geltenden Gentechnikrechts vorsieht.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Euroseeds welcomes that the Commission proposal finally recognizes the need for a differentiated regulatory approach to certain conventional-like NGT-derived plants and products from the GMO legislation. The proposal establishes a verification process to confirm if a NGT plant is meeting the equivalence criteria of Category 1 (conventional-like).

GM-free conventional and organic food production is a major competitive advantage for European farmers. These valuable markets should now be easily sacrificed to the benefit of hypothetical industrial promises. It is clear to us that farmers: With the new genetic engineering plants, we will not be able to solve the climate, biodiversity and hunger crises, which are more fundamental.

Filed in German · English published by the European Commission

Genetic technology is not necessary for plants. Through skilful selection breeding, similar results can be obtained naturally. The benefits of genetic technology are already imposive, but we are never aware of the effects of such changes in switches; perhaps irreversible. At present, genetic technology is needed to a greater or lesser extent for economic success.

Filed in German · English published by the European Commission

Using the new breeding methods, as a farmer, I would be able to plant varieties that are better adapted to changing environmental conditions. Without a higher or more intensive use of inputs, it is a challenge to secure returns on a sustainable basis.

Filed in German · English published by the European Commission

The scientific community genomics and genetic engineering (WGG) generally welcomes the Commission’s proposal to regulate plants resulting from the new genomic techniques (NGTs). This new regulation is long overdue and will bring some of the rules on genetically modified organisms (GMOs) to the current state of science and technology.

Filed in German · English published by the European Commission

Good day, freedom of choice is a great asset and must not be jeopardised by a change in genetic engineering law. The way food and consumer products are produced is important to us, not just the final result. The genetic heritage of an organism is a complex system. In our view, the impact of interventions in this system cannot be predicted, whatever their nature and to what extent.

Filed in German · English published by the European Commission

Ladies and gentlemen, as a gardener of SoLaWi Diefenbach e.V., a small solidarity-based agriculture in southern Germany, I have a lot to do with seed orders and varietal decisions for my own cultivation. In recent years, in the context of hybrid breeding, I have been able to determine the market power of the large seed groups and how the breeding priorities are increasingly shifting towards short-term maximum yields…

Filed in German · English published by the European Commission

Ladies and gentlemen of the European Commission, Lampert is a consultancy firm on sustainable organic food. From a scientific point of view, NGT plants do not pose a greater risk than other breeds when genes have been transferred. However, we strongly oppose deregulation because it is counterproductive for the EU from an economic and environmental point of view. 1.

Filed in German · English published by the European Commission

Currently, all organisms derived from genetic engineering processes must undergo risk assessment before they can be released, cultivated or consumed as food. The Commission now wants to abandon this basic principle of EU legislation. Testbiotech is warning against such far-reaching deregulation.

Position of LTO Nederland on EC proposal genomic techniques LTO Nederland takes the position that new breeding techniques (NBTs) can make a substantial contribution to making plant production more sustainable. Deregulation of NBTs is therefore desirable. When using NBTs, the following preconditions must be ensured: 1.

Ensure the right to GM-free food production! For farmers and gardeners, we have serious concerns about the amendments to the EU Gene Technology Act planned by the European Commission. We fear that in the future we will no longer be able to sow, harvest, feed, process and market ourselves. And that we will be deprived of the opportunities to produce GM-free.

Filed in German · English published by the European Commission

The FORUM GRÜNE Vernlichkeit e.V. warmly welcomes the Commission’s proposals to modernise European genetic engineering law. This reform is overdue! When, 40 years ago, research at the Max Planck Institute Cologne and the University of Ghent opened a new era of plant breeding with the use of the natural horizontal gene transfer, scepticism was entirely appropriate.

Filed in German · English published by the European Commission

Publieke consultatie Verordening betreffende planten verkregen met bepaalde nieuwe veredelingstechnieken en hun levensmiddelen en diervoeders, en wijzigend Verordening (EU) 2017/625 Nieuwe veredelingstechnieken (NBTs) vormen een essentieel bestandsdeel in de gereedschapskist van veredelaars om weerbaardere en resistentere gewassen te kweken.

Filed in Dutch · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear, I have worked for a long time in genetic engineering/research. None of the genetic engineering techniques is safe. The behaviour of genetically modified organisms in the field and their impact on the ecosystem cannot be estimated. It is also not possible to simulate these long-term effects in the laboratory. Nature is too complex.

Filed in German · English published by the European Commission

Genetic engineering opponents often argue that consumers must have the freedom of choice. So they can support GMO-free agriculture. But how is the situation perceived from the other side? I consciously don't buy food products that bear the label "GMO-free", I would rather die. However, when it comes to milk, it's really difficult.

This whole charade is just ridiculous. I am a researcher in Austria, with lots of collaborations and outsourced work overseas because everything is so strictly regulated in the EU - and thus not feasible to do within reasonable time frames within the EU.

16.08.2023 Beitrag des Deutschen Tierschutzbundes zur EU-Konsultation „Rechtsvorschriften für Pflanzen, die mithilfe bestimmter neuer genomischer Verfahren gewonnen werden“ Der Deutsche Tierschutzbund lehnt den Vorschlag der EU-Kommission ab. Die Chance, längst überfällige Korrekturen zugunsten des Tierschutzes vorzunehmen, wird verpasst.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Hello, I am the president of a small French environmental association (500 supporters and some twenty activists) and speak on behalf of the association in which there is unanimity. First, your consultation will only receive input from people who have an account. Only 5 people are in our association. We do not agree that the legislation is not adapted.

Filed in French · English published by the European Commission

9 August 2023 Give your feedback on: Legislation for plants produced by certain new genomic techniques (europa.eu) Compassion in World Farming EU welcomes the opportunity to consult the proposal for a regulation on plants obtained by certain new genomic techniques and their food and feed. In the following contribution, we wish to raise a few considerations we find crucial.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I consider that NBT are not GMOs and the new varieties obtained by those techniques can be regarded as similar, in terms of their registration, to conventional varieties. In person, you don’t see anything about their use in organic farming in February. They would make it possible to achieve even more sustainable objectives in all respects.

Filed in Italian · English published by the European Commission

In particular, in the context of the planned reduction in the use of plant protection products, the ongoing climate change and the energy savings sought, the reregulation of plant breeding using new breeding methods, such as CRISPR/Cas, appears to be superfluous. A reduction in quality and quantity production should not be accepted in the event of an increasing demand for high-quality food.

Filed in German · English published by the European Commission

My name is Alexander Vatchev. As a small vegetable farmer from Bulgaria I strongly condemn the new legislation about to be adopted by the European Union since it only takes into consideration the interest of the agroindustry and doesnt reflect the potetntial damage to the health of the people, the biodiversity and quality of the food on our tables.

The IFOAM Seeds Platform represents constituents across the entire value chain from seed to final consumer and is the only worldwide network on seeds used by organic and agroecological producers. The proposed legislation leaves gaping holes with respect to assuring public health and environmental sustainability. In the attached document we propose a saner approach.

This draft is deeply worrying for the future of the organic sector and for all GM-free agriculture in Germany. The European precautionary principle is not respected and democratic processes are eliminated. On behalf of our approximately 1400 members from agriculture, processing, trade and food-related civilians, we urge the European Commission to: Withdraw this draft.

Filed in German · English published by the European Commission

Comments of the Conselleria of Agriculture, Livestock and Fisheries of the Generalitat Valenciana to the Proposal for a Regulation of the European Parliament and of the Council on plants obtained by certain new genomic techniques and their food and feed, and amending Regulation (EU) 2017/625. 1.

The Commission proposal says the NTG1 plants are conventional plants and that mutations introduced therein could happen naturally: thin means that NTG1 are equal to normal plants. I agree with this definition if two conditions will be more deeply clarified. 1.

We believe that this long-awaited proposal will be crucial for the European agricultural sector and for meeting the targets proposed by the Green Deal. We are pleased to see that the European Union is making efforts to implement a regulation, based on scientific criteria, providing for technological advances, particularly as regards the regulation of plants obtained by NGT’s.

Filed in Portuguese · English published by the European Commission

We are concerned that the proposal reflects the initial intention of the EU Commission to deregulate some GMOs as defined by European Court of Justice, and that it's based on political considerations rather than scientific evidences.

Modern genetic engineering, which is not multi-species, is an acceleration of traditional breeding methods. These should be supported. CrsprCAS example. These methods do not pose a risk of cross-species interference. A distinction must be made between the different genetic engineering techniques. It is important to know whether a technology works across species. Herbert Netter, Koblenz

Filed in German · English published by the European Commission

Organic Landsforening (beer) attaches great importance to the fact that the ban on NGT in organic farming is removed from the horizontal regulation of NGT and is written into the Organic Regulation. This process should assess whether the ban should cover all types of NGT when NGT is expected to become the most widely used technologies in plant breeding.

Filed in Danish · English published by the European Commission