Plants obtained by new genomic techniques: information requirements and verification of category 1 status

Open-pollinated seed-breeder. This comment concerns the implementing act under Article 27 of Regulation (EU) 2026/1388. Category 2 adaptations must not make the authorised event unfindable. I need the same live grower maps on this door so I can protect open-pollinated lines from gene flow and from patented material. Detection methods must still find the authorised event.

Open-pollinated seed-breeder. This comment concerns the implementing act under Article 27 of Regulation (EU) 2026/1388. Category 2 adaptations must not make the authorised event unfindable. I need the same live grower maps on this door so I can protect open-pollinated lines from gene flow and from patented material. Detection methods must still find the authorised event.

Open-pollinated seed-breeder This comment concerns the delegated act under Articles 25 and 26 of Regulation (EU) 2026/1388. After Category 1 verification these plants are treated as conventional. I need live public maps of where they are grown so I can protect my lines from unintended crossing with potentially faulty or patented genetic material.

The Canada Grains Council (CGC) welcomes the opportunity to provide input to the European Commission's consultation on the implementation of the framework for Category 2 plants obtained through new genomic techniques (NGTs). CGC is a national organization representing the Canadian grain, oilseed, pulse and special crops value chain.

The Canada Grains Council (CGC) welcomes the European Commission's implementation of the Category 1 new genomic techniques (NGTs) framework and the opportunity to provide input to the consultation. CGC is a national organization representing the Canadian grain, oilseed, pulse and special crops value chain.

www.phytoformlabs.com Ref. Ares(2026)9163366 - 28/09/2026 Response on the implementation of Category 1 NGT plants Phytoform Labs Ltd | European Commission call for evidence | 28 September 2026 Phytoform Labs welcomes Regulation (EU) 2026/1388 and the Commission’s work to establish a predictable, science-based route for Category 1 NGT plants.

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

Genesprout Initiative welcomes the adoption of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs) and their products. The Regulation represents an important development in the EU regulatory framework, recognizing the substantial advances in plant genome editing since the establishment of the existing EU GMO framework in 2001.

COGEM is an independent scientific advisory body that advises the Dutch government on the potential risks to human health and the environment associated with the production and use of genetically modified organisms (GMOs). COGEM has provided scientific advice on the regulation of New Genomic Techniques (NGTs) on several occasions and welcomes the opportunity to contribute to this initiative.

(zu NGT-1) Mit der Verordnung (EU) 2026/1388 ermöglicht die EU die Nutzung neuer genomischer Techniken (NGT), die die Landwirtschaft bei der Anpassung an den Klimawandel unterstützen, die Landnutzung verringern, den Pflanzenschutzmitteleinsatz senken und die Resilienz des Ernährungssystems stärken können. Für die Überprüfung des Status als NGT-Pflanze der Kategorie 1 sollte die Umsetzung folgende Punkte beachten.

NGT_2: Green Biotech Europe Deutschland (GBE-D) calls for a predictable process for category 2 from assessment to commercial use. Requirements for further breeding and renewal of approval should take into account existing evidence and experience. Implementation should be uniform across the EU, protecting health and the environment and avoiding unnecessary regulatory burdens.

Filed in German · English published by the European Commission

The implementation of Regulation (EU) 2026/1388 for NGT 2 plants must focus on practicality, legal certainty and uniform application across the EU. The risk assessment should be case-by-case, science-based and proportionate. The final product should be decisive, taking into account the natural genetic variation of the species.

Filed in German · English published by the European Commission

NGT2 – there seems to be a website problem: The verification process should aim at a consistent, proportionate, science-based assessment across the EU, providing legal certainty, ensuring practicability and enabling innovativeness for public and private research projects and commercial implementation.

Filed in German · English published by the European Commission

NGT1 – there seems to be a website problem: Practicality must be kept in mind when transposing EU Regulation (EU) 2026/1388 into a delegated act and into national implementing rules. Additional regulatory hurdles must be avoided.

Filed in German · English published by the European Commission

The Antama Foundation is a non-profit organisation whose primary purpose is the dissemination, communication and information on innovation and technology applied in the fields of agriculture, food and the environment. The Antama Foundation warmly welcomes this call for consultation by the European Commission.

Filed in Spanish · English published by the European Commission

Resurrect Bio is a UK based startup developing disease resistance traits. These traits will help farmers increase food production whilst decreasing agri-chemical usage. New Genomic Techniques allow our traits to be rapidly introduced into farmer preferred varieties.

The Antama Foundation is a non-profit organisation whose primary purpose is the dissemination, communication and information on innovation and technology applied in the fields of agriculture, food and the environment. The Antama Foundation warmly welcomes this call for consultation by the European Commission.

Filed in Spanish · English published by the European Commission

„Hodowla Ziemniaka Zamarte” Sp. z o.o. - Grupa IHAR to spółka zajmująca się od 80 lat hodowlą twórczą ziemniaka. Prowadzimy hodowlę zachowawczą, nasiennictwo i sprzedaż kwalifikowanego sadzeniaka własnych odmian.

Filed in Polish · English published by the European Commission

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

Input by the Dutch Government for the call for evidence regarding delegated and implementing acts to supplement and implement the NGT Regulation: The Dutch government welcomes the new Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques and their products (NGT Regulation).

Green Biotech Europe Deutschland (GBE-D) welcomes the adoption of Regulation (EU) 2026/1388. GBE-D calls for clear rules so that breeders know early what evidence they need and how to breed verified plants. The delegated regulation must lay down binding requirements in this regard. Technical guidelines must remain up-to-date without introducing additional obligations.

Filed in German · English published by the European Commission

IGTC welcomes the adoption of Regulation (EU) 2026/1388, which brings the EU into closer alignment with many of its trading partners regulatory frameworks. As the Regulation approaches its date of application in 2028, IGTC calls for a workable, predictable and proportionate implementation framework adapted to the bulk nature of international commodity trade. Additional information is attached.

SUBMITTER: Lucas Lieber, Founder and CEO of BioHeuris, an Argentine agbiotech SME. BACKGROUND: BioHeuris developed an NGT-derived herbicide-tolerant sorghum that enables a 40- to 216-fold reduction in chemical load, far surpassing the EU's Farm to Fork pesticide reduction goals. Anticipating the EU's restrictive stance, we diverted SME funding to recreate these exact mutations using random chemical mutagenesis.

IGTC welcomes the adoption of Regulation (EU) 2026/1388, which brings the EU into closer alignment with many of its trading partners' regulatory framework. As the Regulation approaches its date of application in 2028, IGTC calls for a workable, predictable and proportionate implementation framework adapted to the bulk nature of international commodity trade. Additional input is attached.

Under Regulation (EU) 2026/1388, NGT 1 plants should in future be regarded as equivalent to naturally occurring plants or plants produced by conventional breeding and should therefore be exempted from all previous GMO rules. This assumption is scientifically untenable. That is why AbL e.V.

Filed in German · English published by the European Commission

I worked on a closely related verification problem for my second PhD dissertation. That experience leads me to question whether the proposed information requirements can reliably establish Category 1 status across the material under consideration: plants produced are always genetically heterogeneous to some degree, and information may also be deliberately withheld.

Pulse Canada supports a science- and risk-based, transparent approach. We recommend the Commission make trade facilitation and international regulatory alignment core goals, pursue streamlined pathways for imported grain, and enact a future-ready framework that promotes new breeding innovations without disrupting trade.

In the view of BUND Naturschutz, the Regulation does not meet the requirement of a high level of protection laid down in Article 1. In particular, the criteria for NGT1 plants set out in Annex 1 should be improved. We consider it irresponsible not to carry out an impact assessment of the criteria.

Filed in German · English published by the European Commission

COCERAL, FEDIOL and FEFAC welcome the possibility to provide views on the Call for evidence on the secondary legislation on plants obtained by new genomic techniques (NGTs). Our associations, representing the EU grain and oilseed trade, crushing and feed industries, support the European Commissions efforts to ensure a swift, effective, and consistent implementation of the NGT Regulation in a global context…

COCERAL, FEDIOL and FEFAC welcome the possibility to provide views on the Call for evidence on the secondary legislation on plants obtained by new genomic techniques (NGTs). Our associations, representing the EU grain and oilseed trade, crushing and feed industries, support the European Commissions efforts to ensure a swift, effective, and consistent implementation of the NGT Regulation in a global context…

The basis for organic breeding is to develop breeding approaches that maintain or increase crop diversity in such a way that future generations of breeders and farmers have open access to crop genetic diversity adaptable for future needs. More genetic diversity within varieties, as is the case with organic varieties, allows crops to become better adaptable to diseases and the effect of climate change.

Wageningen University and Research welcomes Regulation (EU) 2026/1388 and its potential for the plant breeding sector. However, a number of requirements and definitions need to be further explained to make the Regulation practical for developers of NGT plants and products. The Regulation should not impose additional requirements for verification, which would make the procedure unnecessarily lengthy and complicated.

Limagrains submission to the public consultation on implementing acts relating to Category 2 NGT plants Limagrain, French cooperative seed company operating in 53 countries, is pleased to contribute to the establishment of implementing acts under Regulation (EU) 20261388 on plants obtained through new genomic techniques (NGTs), especially regarding category 2 NGTs.

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Limagrains submission to the public consultation on implementing acts relating to Category 2 NGT plants Limagrain, French cooperative seed company operating in 53 countries, is pleased to contribute to the establishment of implementing acts under Regulation (EU) 20261388 on plants obtained through new genomic techniques (NGTs), especially regarding category 2 NGTs.

FEPEX Federación Española de Asociaciones de Productores y Exportadores de Frutas, Hortalizas, Flores y Plantas Vivas welcomes the opportunity to contribute to the implementation of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGT).

Filed in Spanish · English published by the European Commission

Limagrains submission to the public consultation on delegated and implementing acts relating to Category 1 NGT plants Limagrain, French cooperative seed company operating in 53 countries, is pleased to contribute to the establishment of implementing acts under Regulation (EU) 20261388 on plants obtained through new genomic techniques (NGTs), especially regarding category 1 NGTs.

FEPEX Federación Española de Asociaciones de Productores y Exportadores de Frutas, Hortalizas, Flores y Plantas Vivas welcomes the opportunity to contribute to the implementation of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGT).

Filed in Spanish · English published by the European Commission

Both NGT1 and NGT2 plants are prohibited in organic production. Category 2 NGTs are GMOs with complex modifications. While the proposal intends to keep Category 2 plants subject to risk assessment, traceability, and labelling, I am concerned by provisions seeking to lower standards via "tailored" requirements.

France Nature Environnement (FNE), a federation which brings together 8 215 associations for the protection of nature and the environment, calls on the European Commission to construct the delegated acts provided for in Regulation (EU) 2026/1388 for NGT1 on the basis of a principle: a favourable decision must not be based on a declaration that is impossible to check, nor on a presumed equivalence based solely on the…

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In 2024, ANSES published an opinion proposing a method for assessing the health and environmental risks associated with plants obtained using certain new genomic techniques (ANSES 2024). This work was initiated before the European Commission published its proposal for a Regulation on NGTs. Its scope and approach differ from those considered under the European initiative.

CropLife Canada welcomes the opportunity to contribute to the Commissions call for evidence on the implementing NGT framework. CropLife Canada is the national trade association representing Canadas plant science industry, including companies involved in developing and commercializing crop protection products and plant biotechnology.

CropLife Canada welcomes the opportunity to contribute to the Commissions call for evidence on Regulation 1388/2026. This regulation is a welcome development that brings the EU closer to the growing global regulatory consensus on NGTs, including Canada.

Stanowisko DANKO Hodowla Roślin Konsultacje Komisji Europejskiej dotyczące wdrożenia rozporządzenia NGT 28 września 2026 r. DANKO Hodowla Roślin popiera wykorzystanie nowych technik genomowych jako narzędzi wspierających rozwój odmian odpornych na choroby i stres klimatyczny, dostosowanych do lokalnych warunków uprawy.

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

Submitter: Lucas Lieber, Founder and CEO of BioHeuris, an Argentine agbiotech SME with 12 employees developing sustainable crop solutions. A) The Real-World Impact of the Proposed EU NGT Framework: Evidence from BioHeuris Using gene editing, BioHeuris developed a sulfonylurea-tolerant sorghum that provides effective weed control using 15 grams of active ingredient per hectare (g a.i./ha).

France Nature Environnement (FNE), a federation of 8 215 nature and environmental associations, calls on the European Commission to draw up the implementing acts for GMOs derived from category 2 NGTs on the basis of strict and scientifically robust monitoring of the reductions in the obligations under Directive 2001/18/EC laid down in Regulation 2026/1388 (EU).

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Vylor, the advanced seed and genetics company spinning off from Corteva on 1 October 2026, welcomes the Commission's Call for Evidence. We appreciate the opportunity for industry, plant breeding associations such as Euroseeds, and countries that already operate successful frameworks for such plants to contribute the information needed to shape the framework under Regulation (EU) 2026/1388.

The International Seed Federation (ISF) welcomes the opportunity to contribute evidence to the European Commission as it finalises the implementing regulation giving effect to Category 2 New Genomic Techniques under Regulation (EU) 2026/1388.

The starting point is wrong: putting profit at the heart of commerce rather than people. This erodes the already worrying rule of law (EU resolution 28/02/2024 paragraph 73, 2023/2113 (INI)). Question 1 is not how much and whether it is possible in nature, but whether interference is justifiable.

Filed in Dutch · English published by the European Commission

I am a senior scientist in organic plant breeding research. Consumer trust fundamentally relies on organic products being strictly free from Genetically Modified Organisms (GMOs), including plants derived from New Genomic Techniques (NGTs).

Defra response to EC Call for Evidence – Ares(2026)8283054 Information requirements for and verification of Category 1 NGTs, and applications for consent or authorisation of Category 2 NGTs and their products September 2026 Response Introduction The United Kingdom Department for Environment, Food and Rural Affairs (Defra) is responsible for regulating the application and use of modern biotechnologies in England…

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

The International Seed Federation (ISF) welcomes the opportunity to contribute evidence to the European Commission as it finalises the delegated act giving effect to Category 1 New Genomic Techniques (NGT1) under Regulation (EU) 2026/1388.

International Confederation of European Beet Grower Ref. Ares(2026)9156370 - 28/09/2026 CONFEDERATION INTERNATIONALE DES BETTERAVIERS EUROPEENS * CONFEDERAZIONE INTERNAZIONALE DEI BIETICOLTORI EUROPEI INTERNATIONALE VEREINIGUNG EUROPÄISCHER RÜBENANBAUER * MIĘDZYNARODOWA KONFEDERACJA EUROPEJSKICH PLANTATORÓW BURAKA 111/9 Boulevard Anspachlaan – B-1000 Brussels Tel: [phone removed] – Fax: [phone removed] [email…

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

Summary SAA Contribution Category 1 NGT Plants The Seed Association of the Americas (SAA) welcomes the opportunity to contribute to the implementation of Regulation (EU) 2026/1388 from the perspective of the Americas, a region with more than a decade of practical regulatory experience with new genomic techniques (NGTs).

Summary SAA Contribution Category 2 NGT Plants The Seed Association of the Americas (SAA) welcomes the opportunity to contribute to the implementation of Regulation (EU) 2026/1388 from the perspective of the Americas as a region with extensive practical experience with gene-edited plants and closely connected through plant breeding, seed production and international agricultural trade.

International Community of Breeders of Asexually Reproduced Horticultural Varieties (CIOPORA) strongly welcomes the enactment of Regulation (EU) 2026/1388, which distinguishes between the two categories of genome-edited plants, NGT1 and NGT2.

COCERAL, FEDIOL and FEFAC welcome the possibility to provide views on the Call for evidence on the secondary legislation on plants obtained by new genomic techniques (NGTs). Our associations, representing the EU grain and oilseed trade, crushing and feed industries, support the European Commissions efforts to ensure a swift, effective, and consistent implementation of the NGT Regulation in a global context…

COCERAL, FEDIOL and FEFAC welcome the possibility to provide views on the Call for evidence on the secondary legislation on plants obtained by new genomic techniques (NGTs). Our associations, representing the EU grain and oilseed trade, crushing and feed industries, support the European Commissions efforts to ensure a swift, effective, and consistent implementation of the NGT Regulation in a global context…

The company, as a company operating multi-species breeding programmes for agricultural plants, draws attention to the need to create clear and workable rules for category 1 NGT plants. The applicability of new genomic techniques will depend primarily on the extent of testing required, the cost and duration of procedures, and the legal certainty associated with the further use of the material.

Filed in Polish · English published by the European Commission

This submission was prepared jointly by Dr. Luíza Favaratto and Prof. Stuart J. Smyth. We welcome the European Commissions implementation of the Category 1 NGT framework and the opportunity to contribute to this consultation.

CEEV supports a simple, science-based, proportionate and fully harmonised EU approach to NGT-1 verification. Information requirements should be clear, predictable and limited to what is necessary to establish NGT-1 status, avoiding unnecessary administrative or testing burdens that could increase costs, restrict access to innovation or reduce competition.

Tropic is a UK-based SME applying NGTs to tropical crops, banana and rice. Our bananas have been determined to be equivalent to conventionally bred, non-GMO plants in many countries including the USA, Canada, Japan, Brazil, Colombia, Ecuador, Costa Rica, the Philippines, Panama, Singapore and England. Banana is the EUs favourite fruit.

Wageningen University and Research welcomes Regulation (EU) 2026/1388 and its potential for the plant breeding sector. However, a number of requirements and definitions need to be further explained to make the Regulation practical for developers of NGT plants and products. The Regulation should not impose additional requirements for verification, which would make the procedure unnecessarily lengthy and complicated.

The company, as a company operating multi-species breeding programmes for agricultural plants, draws attention to the need to create clear and workable rules for category 1 NGT plants. The applicability of new genomic techniques will depend primarily on the extent of testing required, the cost and duration of procedures, and the legal certainty associated with the further use of the material.

Filed in Polish · English published by the European Commission

Cereals Canada submission attached for Call for Evidence on Plants obtained by new genomic techniques: information requirements for and verification of category 1 status, and applications for consent or authorisation of category 2 plants and their products.

Inari is the SEEDesign company, integrating genomics, AI and gene editing to bring speed and precision to plant breeding. Founded in 2016, Inari is headquartered in Cambridge, MA, with sites in W. Lafayette, IN, and Ghent, Belgium.

The GMO Network welcomes the opportunity to provide input to the European Commission on the implementation of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques. The GMO Network is a Norwegian umbrella organisation representing organisations working in areas including agriculture, the environment, consumer interests and development policy.

Primary Food Processors (PFP) welcome the opportunity to provide input to the European Commissions Call for Evidence regarding secondary legislation under Regulation (EU) 2026/1388 on plants obtained by new genomic techniques (NGTs).

Hollandbio is the Dutch industry association for biotechnology companies, representing start-ups, scale-ups, established companies and multinational enterprises. Our members include plant breeders and other companies that develop and apply new genomic techniques. Drawing on their scientific expertise and practical experience, we welcome the opportunity to provide input implementing act for Category 2 NGT plants.

Hollandbio is the Dutch industry association for biotechnology companies, representing start-ups, scale-ups, established companies and multinational enterprises. Our members include plant breeders and other companies that develop and apply new genomic techniques.

We would like to see proportional, science based risk assessment for Cat2 plants, with a process that is predictable, equitable and not overly onerous for applicants. We agree with the findings of EFSAs safety assessment; that the technologies themselves are not linked to hazards, and will lead to fewer unintended modifications to the genome than conventional breeding techniques.

28. September 2026 Danish Potato Association comments to the Call for Evidence on New Genomic Techniques (NGT) Implementing Acts The Danish Potato Association supports a simple, science-based, and fully harmonized verification process for NGT-1 plants under Regulation (EU) 2026/1388.

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

We welcome the NGT Regulation and agree with the focus on characteristics of the plant rather than technology. The Cat1 verification process needs to be proportionate, science-based, and accessible to SMEs and academics. It should be carried out by a panel of experts and harmonised across Member States who should not add additional requirements beyond the Regulation.

BASF Agricultural Solutions appreciates the opportunity to provide its views in response to the Call for Evidence on the implementing act for Category 2 NGT plants under Regulation (EU) 2026/1388. BASFs recommendations draw on our extensive experience in developing new crop varieties, including through the use of modern biotechnology and new genomic techniques, and by our experience in preparing applications for the…

BASF appreciates the opportunity to contribute to the European Commissions Call for Evidence on the delegated act under Regulation (EU) 2026/1388. Our input is guided by the principles that the framework should be future-proof and technology-, crop- and trait-neutral; focus on the characteristics of the final plant intended for deliberate release and/or placing on the market, rather than the technical route used to…

The Polish Food and Agriculture Fund supports NGT technology and sees it as an opportunity for the development of agriculture in Europe. Category 2 NGT plants include differentiated combinations of traits that do not present a higher risk than category 1 NGTs or conventionally bred plants, as confirmed by the EFSA opinion (11/07/2024).

Filed in Polish · English published by the European Commission

BIOVEGEN, the Spanish Technological Platform for Plant Biotechnology (a public-private entity comprising 185 companies, public research centres and associations in the agri-food sector), welcomes the establishment of a specific European regulatory framework for plants obtained using New Genomic Techniques (NGTs) within the framework of Regulation (EU) 2026/1388.

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BIOVEGEN, the Spanish Technological Platform for Plant Biotechnology (a public-private entity comprising 185 companies, public research centres and associations in the agri-food sector), welcomes the establishment of a specific European regulatory framework for plants obtained using New Genomic Techniques (NGTs) within the framework of Regulation (EU) 2026/1388.

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EUPPA Contribution to the Call for Evidence – Plants obtained by new genomic techniques: information requirements and verification of Category 1 status Introduction The European Potato Processors' Association (EUPPA) represents more than 90% of the potato processing industry in Europe.

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

Save Our Seeds is an initiative of the Foundation on Future Farming. We campaign for responsible regulation of genetic engineering and promote agroecological and organic innovation in European and global agriculture. Our submission focusses on the information and assessments needed to establish whether NGT1 plants and their products are indeed equivalent to those obtained through conventional breeding.

Please find below our position in relation to the Commission’s Call for Evidence concerning the delegated act under Regulation (EU) 2026/1388. The success of the New Legislative Framework for plants obtained by certain new genomic techniques will depend on the Delegated Regulation, which must provide legal certainty while ensuring a practical, proportionate and innovation-friendly approach.

Filed in Polish · English published by the European Commission

**1. Recommendations to verify conformity to the definition of Cat. 1 & Cat. 2 NGT plants** The Regulation must define categories 1 and 2 without ambiguity. DNA sequence information required to verify NGT1 status (Articles 6 and 7), and the methods used, should follow unified recommendations and formats set by EFSA and Member State competent authorities.

*INRAE comments the fact that, according to Regulation 2026/1388, the evaluation of NGT2 plants for risk assessment and market access is now performed case by case and is based on the product itself, not on the process used to create such plants.

A proportionate and science-based authorization framework for Category 2 NGT plants Variety Denmark, Danish Seed association and the Danish Association of Plant Breeders welcome Regulation (EU) 2026/1388 and support an effective, science-based framework for Category 2 NGT plants.

ILVO welcomes the opportunity to contribute to the development of the implementing acts under Regulation (EU) 2026/1388. The attached text represents ILVO's vision on what the building blocks for the secondary legislation should be. Very briefly, Category 1 verification should remain a technical, information-based procedure rather than develop into an analytical detection challenge.

Danish support for proportionate Category 1 NGT verification Joint response to initiative 18805 by Variety Denmark, Danish Seed association & the Danish Association of Plant Breeders. Variety Denmark, Danish Seed association and the Danish Association of Plant Breeders fully support Euroseeds recommendations for implementing Regulation (EU) 2026/1388 for Category 1 NGT plants.

BioCompas supports the Commission's work on the delegated act under Article 25 of Regulation (EU) 2026/1388 and welcomes the opportunity to provide input. Our full contribution is set out in the attached document.

1. Introgression of useful genes from wild relatives of crops by classical breeding is slow, especially in polyploid vegetative crops like potato. It took 50 years from the first crosses to bring to market potatoes with late blight resistance gene Rpi-blb2 from a wild relative Solanum bulbocastanum.

Ri.Nova Soc. Coop. submits the attached contribution concerning the interpretation of production of a known insecticidal substance under Annex II of Regulation (EU) 2026/1388 in relation to Host-Induced Gene Silencing (HIGS).

The entry into force of Regulation (EU) 2026/1388 with the distinction between the two categories of genome-edited plants lacks of scientific and technical evidence and creates insecurity for public administration and the whole food sector. The criteria set out in Annex I are not adequate to evaluate equivalence between NGT and conventionally bred/naturally occurring plants. See also Mundorf, J.; Simon, S.

ASAJA, COAG and UPA, together with Cooperativas Agro-alimentarias de España, FEPEX and the Asociación Española de Agricultura de Conservación Suelos Vivos (Spanish Association for Conservation Farming of Live Soils), which includes the professional agricultural organisations at national and general level, promote the sustainable production model based on scientific evidence.

Filed in Spanish · English published by the European Commission

The Polish Seed Chamber, on information requirements and verification of the status of plants obtained by new genomic techniques of category 1, the Polish Seed Chamber (PIN), representing companies in the breeding and seed sector in Poland, calls for simple, proportionate and uniformly applied rules to verify the status of category 1 NGT plants.

Filed in Polish · English published by the European Commission

ASAJA, COAG and UPA, together with Cooperativas Agro-alimentarias de España, FEPEX and the Asociación Española de Agricultura de Conservación Suelos Vivos (Spanish Association for Conservation Farming of Live Soils), which includes the professional agricultural organisations at national and general level, promote the sustainable production model based on scientific evidence.

Filed in Spanish · English published by the European Commission

Meiogenix SAS is a French SME, a spin-off of the Institut Curie and INRAE, with the R&D site in North Carolina, USA. We developed a targeted meiotic recombination platform that helps breeders move valuable traits, especially disease resistance from wild relatives, into elite varieties without unfavourable DNA linked to them (linkage drag). We welcome Regulation (EU) 2026/1388.

Coldiretti, the largest organisation representing farmers in Italy and Europe, with its 1.6 million members, welcomes the European Commission’s initiative to gather views on plants obtained through new genomic techniques: information requirements and verification of category 1 status. See detailed position paper attached.

Filed in Italian · English published by the European Commission

DIB welcomes the adoption of the EU Regulation on plants obtained by certain New Genomic Techniques (NGTs). The regulation is an important step towards a more differentiated and proportionate European framework for plant breeding and plant innovation. The new framework recognises that NGT plants are not a uniform regulatory category.

Bio Germany expressly supports the grouping of genome-edited plants into two categories, as provided for in this draft Regulation. The regulatory framework offers, in particular, small and medium-sized enterprises and researchers in public and university institutions a realistic perspective of bringing results from basic research to market.

Filed in German · English published by the European Commission

Expert Groups NGT of the GFÖ - Ecological Society of Germany, Austria, and Switzerland, and the EEF - European Ecological Federation (approval pending) We welcome the opportunity to comment on the implementation of Regulation (EU) 2026/1388. The GFÖ is the largest scientific ecological society in the EU, and the EEF unites the European ecological societies under a single roof.

Testbiotech filed a comment to the EU consultation on the implementation of the new Regulation (EU) 2026/1388 on plants derived from new genomic techniques (NGT) on 9 September 2026. In this comment, we refer to Groover et al. (2026), which reports of hypermorphing of plant characteristics by interfering with gene regulation.

DIB welcomes the adoption of the EU Regulation on plants obtained by certain New Genomic Techniques (NGTs). The regulation is an important step towards a more differentiated and proportionate European framework for plant breeding and plant innovation. The new framework recognises that NGT plants are not a uniform regulatory category.

The Danish Agency for Green Transition and Aquatic Environment welcomes the opportunity to submit feedback to the ongoing implementation of the NGT-regulation 2026/1388. According to the implementation strategy, the Commission will develop two delegated acts and three implementing acts. The Danish authorities hereby submit their feedback to the call.

EOCC (European Organic Certifiers Council, gathering 74 Control Bodies) welcomes the opportunity to contribute to the preparation of the delegated and implementing acts required for the application of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques and their products. Please see below the full EOCC Position on this.

This statement is given in the capacity as an official of the German Federal Office of Consumer Protection and Food Safety (BVL). The BVL is the competent authority in Germany according to Directive 2001/18/EC. This statement has been coordinated with all relevant units within the BVL. It does not necessarily reflect the views of the Government of the Federal Republic of Germany.

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

Contributions of the German Federal Agency for Nature Conservation (BfN): Persistence and Invasiveness: Likely scenarios of NGT2 plants (NGT2-P) include traits for agriculture (yield, resistance to biotic and abiotic stressors) or bioeconomy. Many of such traits require significant metabolic changes or may result in phenotypic changes increasing fitness of NGT2-P, also under natural conditions (Dolezel et al.

NégoA, a federation representing agricultural trading companies, supports the establishment of a proportionate European framework allowing the authorisation and marketing of category 2 NGT plants, while ensuring a high level of safety and legally controllable compliance conditions for all operators in the chain.

Filed in French · English published by the European Commission

For Category 2 NGT plants, the implementing act should ensure that risk assessment requirements remain proportionate to the characteristics of the plant and the potential risks identified. While many of these products could, in principle, be obtained through conventional breeding methods, doing so would often require substantial investments of time, resources and breeding effort.

NégoA, a federation representing agricultural trading companies, supports the establishment of a European framework allowing the development and marketing of plants obtained by new genomic techniques, while ensuring simple, harmonised and legally secure implementation for operators.

Filed in French · English published by the European Commission

This statement is given in the capacity as an official of the German Federal Office of Consumer Protection and Food Safety (BVL). The BVL is the competent authority in Germany according to Directive 2001/18/EC. This statement has been coordinated with all relevant units within the BVL. It does not necessarily reflect the views of the Government of the Federal Republic of Germany.

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

The VBIO has been advocating for a differentiated view of genome-edited plants since 2016 and welcomes the distinction of genomed plants into the NGT-1 and NGT-2 categories provided for in Regulation (EU) 2026/1388. We expect the EU Regulation to facilitate the translation of research results into practice.

Filed in German · English published by the European Commission

Assobiotec, the National Association for the Development of Biotechnology, considers the implementing act on Category 2 NGT plants to be a crucial element in ensuring that the new European regulatory framework is able to combine high safety standards with the ability to support innovation, competitiveness and sustainability of the European agri-food system.

Filed in Italian · English published by the European Commission

CropLife International (CLI), representing the global plant science industry, welcomes Regulation (EU) 2026/1388 and the opportunity to contribute to its implementation from the perspective of a global trade perspective. CLI would like to highlight three specific areas 1.

CropLife International (CLI), representing the global plant science industry, welcomes Regulation (EU) 2026/1388 and the opportunity to contribute to its implementation from the perspective of a global trade perspective. CLI would like to highlight three specific areas 1.

Assobiotec, the National Association for the Development of Biotechnology, welcomes the launch of the consultation on the delegated act provided for in Regulation (EU) 2026/1388 on New Genomic Techniques (NGTs) as a key step to ensure a consistent and harmonised implementation of the new European regulatory framework.

Filed in Italian · English published by the European Commission

WePlanet welcomes the opportunity to contribute to this call for evidence, and welcomes this implementing act. Regulation (EU) 2026/1388 was adopted because new genomic techniques (NGTs) can help agriculture adapt to climate change, reduce pesticide use, make better use of biomass, and strengthen food security and the EU's food system sovereignty. Whether that potential is realised now depends on implementation.

The implementation of Regulation (EU) 2026/1388 for NGT 2 plants must focus on practicality, legal certainty and uniform application across the EU. The risk assessment should be case-by-case, science-based and proportionate. The final product should be decisive, taking into account the natural genetic variation of the species.

Filed in German · English published by the European Commission

Lithuanian Research Centre for Agriculture and Forestry (LAMMC) welcomes the European Commissions Call for Evidence on Category 1 NGT plants. Verification should require only the information needed to assess the Annex I equivalence criteria. It should be predictable and proportionate to the crop species and the stage of development.

Opinion of Öko-Progressiven Netzwerk e.V. (summary, detailed version with references in the attached document) With Regulation (EU) 2026/1388, the EU enables the use of new genomic techniques (NGTs) that can help agriculture adapt to climate change, reduce land use, reduce the use of plant protection products and strengthen the resilience of the food system.

Filed in German · English published by the European Commission

CropLife International (CLI), representing the global plant science industry, welcomes Regulation (EU) 2026/1388 and the opportunity to contribute to its implementation from the perspective of a global trade perspective. CLI would like to highlight four specific areas 1.

Europatat contribution to the European Commission consultation on plants obtained by new genomic techniques: information requirements and verification of category 1 status 28 September 2026 Europatat welcomes the ongoing call for information to facilitate the implementation of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques and their products.

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

The Danish Agency for Green Transition and Aquatic Environment welcomes the opportunity to submit feedback to the ongoing implementation of the NGT-regulation 2026/1388. According to the implementation strategy, the Commission will develop two delegated acts and three implementing acts. The Danish authorities hereby submit their feedback to the call.

APSA welcomes the opportunity to contribute to the preparation of delegated acts under EU NGT Regulation 2026/1388 (NGT 1) as follows. 1. Facilitate Trade and Ensure Non-EU Access - Confirm that entities without an established presence in the EU may submit verification requests as many developers of varieties for EU import markets are based outside the EU.

EPSO welcomes the European Commission Call for Evidence on Category 1 NGT plants and provides input regarding the information necessary for the verification process. A detailed listing of points of the Regulation (EU) 2026/1388 that should be more precise and elaborated in the secondary legislation is attached as pdf file.

The attached text provides a synthesis of the opinions and contributions that were expressed by Researchers of the Hellenic Agric Agricultural Organization DIMITRA (ELGO-DIMITRA), through the Research Institutes which are currently working on procedures relating to NGTs (Institute of Plant Breeding and Plant Genetic Resources, Institute of Olive, Subtropical Plants and Vines and Institute of Technology of…

The attached text provides a synthesis of the opinions and contributions that were expressed by Researchers of the Hellenic Agric Agricultural Organization DIMITRA (ELGO-DIMITRA), through the Research Institutes which are currently working on procedures relating to NGTs (Institute of Plant Breeding and Plant Genetic Resources, Institute of Olive, Subtropical Plants and Vines and Institute of Technology of…

We welcome Regulation (EU) 2026/1388 and its recognition that the information needed to assess category 2 NGT (NGT2) plants will vary case by case. Our comments aim to ensure the implementation of this principle, including a simplified pathway where scientifically justified Below we submit a summary and attached you can find our detailed comments. 1.

The United States supports the European Union taking an expansive, forward-looking approach in establishing technical criteria for Category 2 New Genomic Techniques (NGTs), given the broad scope of potential applications. Many of these applications would not be subject to substantive regulation in nations with established NGT policy frameworks. The United States is a global leader in applying NGTs to plant breeding.

CEFS, the European Association of Sugar Manufacturers, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the secondary legislation implementing Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs) and their products.

Category 2 NGTs The success of the NGT Regulation depends on the operational arrangements that will be implemented. According to the EFSA opinion of 11/07/2024, NGT cat 2 plants do not, by nature, pose higher risks than cat 1 plants or even conventionally bred plants. In this respect, and in the light of recital 37, their assessment requires a flexible approach, on a case-by-case basis and proportionate to the risk.

Filed in French · English published by the European Commission

CEFS, the European Association of Sugar Manufacturers, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the secondary legislation implementing Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs) and their products.

The United States supports the European Union taking an expansive, forward-looking approach in establishing technical criteria for Category 1 New Genomic Techniques (NGTs). This approach should: 1. recognize the diverse genomesincluding polyploidyof many agricultural cultivars; and 2. account for the sustainability-focused application of NGTs to critical plant protection challenges.

Phyteis’ contribution to the public consultation on the executive acts relating to category 1 NGT plants. The success of the new framework (EU) 2026/1388 applicable to the plants defined in cat1 will depend on the executive acts which must be clear, proportionate, favourable to innovation and guarantee uniform implementation between the various Member States, without any restrictions or requirements additional to…

Filed in French · English published by the European Commission

The information submitted by a company for the purpose of verification of category 1 NGT plant status should allow the fulfilment of the objectives of Regulation (EU) 2026/1388 and its proper implementation. This includes article 5(2), article 32(3) and the possibility for organic operators, who have to comply with Regulation (EU) 2018/848, to ensure that no NGTs are used in the organic production process.

The current regulation of GMOs should not be the basis for the assessment of NGT 2, as GMOs are based on precautionary historical doubts and do not reflect scientific progress and experience with GM crops in recent years. Moreover, those regulations do not provide any flexibility to cover the wide range of properties and the various risk profiles expected from NGT 2 plants.

Filed in Lithuanian · English published by the European Commission

The delegated acts for gene scissors (New Genomic Technologies) should ensure an enabling environment for innovation, be practicable and avoid MS creating barriers or additional national requirements for NGT1 plants. Guidance documents and delegated acts should ensure flexibility and be future-oriented and not create unnecessary barriers to technology.

Filed in Lithuanian · English published by the European Commission

The Bundesverband Deutscher Pflanzenzüchter e.V. (BDP) represents the plant breeding sector in Germany. It brings together the interests of its around 130 members, with more than 5500 employees from breeding and seed trade, and works to optimise the framework conditions for breeding and seed management and to promote plant research and new technologies.

Filed in German · English published by the European Commission

Assosementi (the Italian Seed and Plantraisers Association) welcomes the European Commission's Call for Evidence on secondary legislation under Regulation (EU) 2026/1388 regarding Category 2 NGT plants (NGT2). Secondary legislation must establish a flexible, scientifically based, proportionate and fully harmonized European framework that fosters agricultural innovation, EU competitiveness, and climate resilience…

Assosementi (the Italian Seed and Plantraisers Association) welcomes the European Commission's Call for Evidence on secondary legislation under Regulation (EU) 2026/1388. NGT1 plants are scientifically recognized as having a risk profile equivalent to conventionally bred varieties.

Stellungnahme zum Call for Evidence der Europäischen Kommission zu den Rechtsakten nach der Verordnung (EU) 2026/1388 über mit bestimmten neuen genomischen Techniken gewonnene Pflanzen Berlin/Hamburg, 28.09.2026 DER AGRARHANDEL (DAH) fordert eine praxistaugliche Umsetzung der NGT Verordnung: Pflanzen der Kategorie 1 müssen tatsächlich wie konventionelle Pflanzen behandelt werden, die Verantwortung für Verifizierung…

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)

Stanowisko Hodowli Roślin Strzelce w konsultacjach dotyczących wymogów informacyjnych i weryfikacji statusu roślin NGT kategorii 1 Przygotowując szczegółowe przepisy dotyczące NGT, należy uwzględnić sytuację i specyfikę przedsiębiorstw typu MśP prowadzących wielogatunkową hodowlę roślin w warunkach lokalnych i sprzedających odmiany przede wszystkim na rynkach własnych, wewnętrznych.

Filed in Polish · English published by the European Commission

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

EL PINAR welcomes the opportunity to provide feedback regarding the implementation of Regulation (EU) 2026/1388. As a berry grower, our business depends on access to improved plant varieties that help address the practical challenges of modern fruit production. European berry growers compete in global markets and depend on access to the same innovations available to growers in other regions.

Opinion ON AN INITIATIVE (without impact assessment) Plants obtained by new genomic techniques: Information requirements for or review of category 1 status and notifications of consent or applications for authorisation of category 2 plants and products thereof As a medium-sized company in European plant breeding, we expect that the implementation of the delegated act will create legal certainty.

Filed in German · English published by the European Commission

After several years of debate at European level, LIDEA welcomed the conclusion of European legislative work. This enables the EU to finally adopt rules that will regulate, under balanced conditions, the development and placing on the market of NGT plants, in particular category 1.

Filed in French · English published by the European Commission

KWS welcomes the EU Regulation on plants obtained by new genomic techniques (NGTs) as an urgently needed framework to ensure future-readiness and competitiveness for the European plant breeding sector and European farming.

Contributions of the German Federal Agency for Nature Conservation (BfN): Persistance and Invasiveness: Likely scenarios of NGT2 plants (NGT2-P) include traits for agriculture (yield, resistance to biotic and abiotic stressors) or bioeconomy. Many of such traits require significant metabolic changes or may result in phenotypic changes increasing fitness of NGT2-P, also under natural conditions (Dolezel et al.

NGT1 status under Regulation (EU) 2026/1388 is established through verification of the criteria of equivalence (Annex I) and exclusion of certain traits (Annex II). The regulatory purpose of molecular characterization thereby shifts from supporting risk assessment to demonstrating compliance with criteria, which has implications for the molecular data required for regulatory assessment.

Input from KMC amba to the Call for Evidence on New Genomic Techniques (NGT) Implementing Acts The following comments relate to NGT category 1 and concerns verification of NGT 1 plants, registration of a new NGT 1 variety and transition from a GMO plant to a NGT 1 plant. See attachment

APROSE is the Professional Association of Selecta Seed Producers, which represents the interests of the Spanish seed producing sector. In the context of the implementation of Regulation (EU) 2026/1388, APROSE considers it essential that its development through secondary legislation be based on a clear, coherent, proportionate, science-based framework capable of adapting to developments in science and technology.

Filed in Spanish · English published by the European Commission

Feedback to Commission Public Consultation New Genomic Technique (NGT) - information requirements and verification of category 1 status 28th September 2026 The Irish Farmers Association (IFA hereafter) welcome the introduction of a regulation framework 2026/1388 on plants obtained by new genomic techniques in the European Union and for the opportunity to respond to the EU Commission’s call for evidence on Category 1…

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

Danish Agriculture & Food Council welcomes a simple, predictable, science-based, and fully harmonized NGT-1 verification regarding the Regulation (EU) 2026/1388 on plants produced by certain new genomic techniques (NGTs). It is expected that the number of NGT-1 varieties will grow as soon as the implementation period is over in 2028.

The Confederation of Danish Industry (DI) welcomes the opportunity to comment on the Commissions Call for Evidence concerning the implementation of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs). The forthcoming delegated and implementing acts should ensure that the Regulation can be applied uniformly, effectively and in a timely manner across the EU from 17 July 2028.

This initiative complements Regulation (EU) 2026/1388 on plants produced by certain new genomic techniques (NGTs). It specifies the information required from operators to demonstrate that a plant is a NGT plant and the information necessary to verify plants and products equivalent to conventional ones (category 1).

Filed in Italian · English published by the European Commission

The Australian Seed Federation (ASF) welcomes the opportunity to comment on the implementation of the European Unions framework for Category 2 plants developed using New Genomic Techniques (NGTs). Australia is an important participant in global seed supply chains.

The Australian Seed Federation (ASF) welcomes the opportunity to comment on the implementation of the European Unions framework for Category 1 plants developed using New Genomic Techniques (NGTs). ASF supports a science-based, proportionate and predictable framework for Category 1 NGT plants.

The American Seed Trade Association (ASTA) welcomes the opportunity to submit feedback on the European Commissions call for evidence concerning the Implementing Act under Regulation (EU) 2026/1388 for Category 2 NGT plants (Initiative 18806). ASTA represents nearly 700 member companies involved in seed production and distribution, plant breeding, seed treatment, and related industries in North America.

Simplot Plant Sciences welcomes the opportunity to provide input on the implementation of Regulation (EU) 2026/1388 for Category 1 New Genomic Technique (NGT-1) plants. As a developer of genome-edited potato and strawberry products that have undergone regulatory review in the United States, Canada, and the United Kingdom, Simplot has practical experience supporting regulatory determinations for products developed…

The American Seed Trade Association (ASTA) welcomes the opportunity to submit feedback on the European Commissions call for evidence concerning the Implementing Act under Regulation (EU) 2026/1388 for Category 2 NGT plants (Initiative 18806). ASTA represents nearly 700 member companies involved in seed production and distribution, plant breeding, seed treatment, and related industries in North America.

The American Seed Trade Association (ASTA) welcomes the opportunity to submit comments in response to the European Commissions call for evidence concerning the Delegated Act under Regulation (EU) 2026/1388. ASTA represents nearly 700 member companies involved in seed production and distribution, plant breeding, seed treatment, and related industries in North America.

As an employee of a plant breeding company, we would like to stress the importance of a simple implementation of the NGT Regulation. As NGT1 varieties are recognised as equivalent to conventional varieties, documentary and scientific requirements should remain limited to the information strictly necessary to verify their status.

Filed in French · English published by the European Commission

As a company that breeds new varieties of agricultural plants using new genomic techniques, we draw attention to the practical operation of the procedure for verifying the NGT status1 provided for in Articles 6 and 7 of Regulation (EU) 2026/1388. It is crucial to define the scope of the information and studies required from the applicant.

Filed in Polish · English published by the European Commission

Under the EU Regulation ((EU) 2026/1388), NGT 1 plants are to be treated in the same way as conventionally bred plants. It is very important that this principle is also consistently and practically implemented in the delegated act. It should be possible to carry out the verification procedure for NGT1 plants in a proportionate and cost-effective manner.

Filed in German · English published by the European Commission

The successful implementation of Regulation (EU) 2026/1388 will depend on a verification framework that is science-based, proportionate, predictable and workable across the diversity of crop species, breeding approaches and operators present in the European Union.

AISR supports a science-based, risk-proportionate and practical framework for Category 2 NGT plants, benchmarked against conventional breeding. The implementation should focus on the characteristics of the final plant, the intended trait and clearly identified risks, while avoiding unnecessary data requirements and duplication.

AISR supports a clear, science-based and proportionate framework for Category 1 NGT plants that provides legal certainty while allowing innovation and breeding practices to evolve. The verification process should focus on the intended changes in the final plant, allow fit-for-purpose scientific methods and avoid unnecessary requirements or duplication.

Pairwise Plant Services, Inc. is a small agricultural biotechnology company in Durham, North Carolina. We use CRISPR to improve fruit crops that have received little modern breeding investment, principally blackberry and sweet cherry. We qualify as a small or medium-sized enterprise (SME) under Commission Recommendation 2003/361/EC, and our primary crops are minor crops when considering total EU acreage.

Position of the Council for Agricultural Research and Economics (CREA) on NGT Status and Category 1 Verification The Council for Agricultural Research and Economics (CREA) is Italys main public research institution for agriculture, agri-food systems and forestry.

NGT2: North Hill Group (NHG) is a regulatory advisory firm helping developers of gene-edited crops, mainly SMEs, with regulatory classification and market access. Drawing on more than 60 determinations across 14 countries, our submission focuses on how NGT2 classification will affect trade in products developed outside the EU. Full details of the evidence are provided in the attached document.

NGT1: North Hill Group (NHG) is a regulatory advisory firm helping developers of gene-edited crops, mainly SMEs, with regulatory classification and market access. Drawing on more than 60 determinations across 14 countries, our submission sets out what a workable NGT1 verification procedure looks like in practice. Full details of the evidence are provided in the attached document.

On behalf of Unlabelled Kitchen, an independent consumer transparency initiative, I welcome the opportunity to contribute to this Call for Evidence. I am submitting consumer evidence for consideration in the implementation of Regulation (EU) 2026/1388 and the Category 1 NGT framework, with particular regard to consumer information and informed consumer choice.

EU NGT – Call for Evidence Submission September 2026 Category 2 NGT Plants Grain Farmers of Ontario welcomes the opportunity to provide input on the European Commission’s implementation of the framework for Category 2 plants obtained through new genomic techniques. Grain Farmers of Ontario represents Ontario’s 28,000 barley, corn, oat, soybean and wheat farmers.

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

Grain Farmers of Ontario welcomes the opportunity to provide input on the European Commissions implementation of the Category 1 new genomic techniques framework. Grain Farmers of Ontario represents Ontarios 28,000 barley, corn, oat, soybean and wheat farmers.

We encourage the European Commission to implement the Category 2 framework in a manner that is science-based, proportionate and internationally aligned. Agricultural commodities move through integrated global supply chains, and EU regulatory requirements can therefore affect the availability of technologies in countries outside the EU.

The Canola Council of Canada (CCC) welcomes the opportunity to provide input to the European Commission's consultation on the implementation of the framework for Category 1 plants obtained through new genomic techniques (NGTs). The CCC is a national value chain industry association representing all segments of the Canadian canola industry, including seed developers, farmers, exporters, and processors.

Cibus supports the EUs progress in establishing Regulation (EU) 2026/1388 and welcomes the opportunity to provide comments during the call for evidence. The Implementing Act should implement the Regulation in a clear, science-based, proportionate, and predictable manner, recognizing that plants obtained by certain new genomic techniques (NGTs).

Cibus supports the EUs progress in establishing Regulation (EU) 2026/1388 and welcomes the opportunity to provide comments during the call for evidence. The Delegated Act should implement the Regulation in a clear, science-based, proportionate, and predictable manner, recognizing that plants obtained by certain new genomic techniques (NGTs) verified to be Category 1 have a risk profile equivalent to conventionally…

IPK Leibniz Institutes contribution. In general, the IPK welcomes a scientifically sound and proportionate implementation of the NGT Regulation. Based on our expertise in conserving and researching plant genetic resources, cereal genetics, and genomics, we make the following recommendations in the attached document. These are guided by the requirements of research practice at the IPK Leibniz Institute.

The German Botanical Society calls for a science-based, affordable, EU-wide uniform NGT1 test, accessible also to public research, small breeders and sparsely processed crop species. The examination must remain a technical status determination. NGT definition, Annex I and exclusion traits to be considered; an additional GMO risk assessment is not justified.

Filed in German · English published by the European Commission

Testbiotech welcomes the opportunity to provide feedback on the implementation of Regulation (EU) 2026/1388 and its requirements with regard to the risk assessment of NGT 2 plants Our detailed comments and recommendations are provided in the attached document.

The Innovative Genomics Institute (IGI) is a public academic research institute formed through partnerships among multiple University of California campuses and national laboratory collaborators. IGI appreciates the EU Commissions diligent approach to gathering stakeholder views and evidence on specific approaches and methodologies to ensure scientifically sound and proper implementation of Regulation (EU)…

Simplot Plant Sciences welcomes the opportunity to provide input on the implementation of the Category 2 New Genomic Technique (NGT-2) provisions under Regulation (EU) 2026/1388. As a developer of genome edited potato and strawberry products that have undergone regulatory review in the United States, Canada, and the United Kingdom, Simplot has practical experience supporting regulatory determinations for products…

Position of the Italian Society of Agricultural Genetics (SIGA) on NGT Status and Category 1 Verification Information requirements Information requirements should focus on objectively verifiable elements, including the technique used, the molecular characterisation of the genetic modification, and the absence of sequences foreign to the breeders gene pool.

EuropaBio welcomes the opportunity to provide feedback on the implementation of Regulation (EU) 2026/1388. Its implementing framework should be science- and product-based, proportionate, predictable and workable, enabling innovation and competitiveness while maintaining a high level of protection for human health and the environment.

Hjelle Consulting Group (HCG) provides regulatory services to a range of technology developers, including Small and Medium Enterprises. We provide our comments in support of our clients and agriculture in general. We appreciate the opportunity to comment and the EUs commitment to creating a clear regulatory path for new genomic techniques (NGTs).

Hjelle Consulting Group (HCG) provides regulatory services to a range of technology developers, including Small and Medium Enterprises. We provide our comments in support of our clients and agriculture in general. We appreciate the opportunity to comment and the EUs commitment to creating a clear regulatory path for new genomic techniques (NGTs).

𝗥𝗲𝗹𝗶𝗮𝗯𝗹𝗲 𝘃𝗲𝗿𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻 𝗼𝗳 𝗖𝗮𝘁𝗲𝗴𝗼𝗿𝘆 𝟭 𝗡𝗚𝗧 𝘀𝘁𝗮𝘁𝘂𝘀 𝗿𝗲𝗾𝘂𝗶𝗿𝗲𝘀 𝗿𝗼𝗯𝘂𝘀𝘁 𝗴𝗲𝗻𝗼𝗺𝗶𝗰 𝗱𝗮𝘁𝗮 The Aurelia Foundation is a non-profit, science-based foundation dedicated to the protection of pollinating insects and biodiversity. In its view, Regulation (EU) 2026/1388 has shortcomings with regard to environmental and consumer protection, the precautionary principle and scientific consistency.

(Detailed arguments and full supporting references are set out in the attached submission) I lead a laboratory working on transposable elements, gene silencing and targeted insertion in plants, and am the Founder and Chief Scientific Officer of Spearhead Bio, Inc., which develops transposase-assisted insertion technology. I disclose both capacities.

As IP firms, Società Italiana Brevetti and SIB LEX wish to share their joint feedback on a specific aspect set out by the new Regulation, in particular the creation of the database system provided for in Articles 9 and 10 of Regulation (EU) 2026/1388, which is intended to allow users (breeders, companies, research institutes, but also IP attorneys) to access and gather information on NGT-1 plants and products, as…

(Detailed arguments and full supporting references are set out in the attached submission) I lead a laboratory working on transposable elements, gene silencing and targeted insertion in plants, and am the Founder and Chief Scientific Officer of Spearhead Bio, Inc., which develops transposase-assisted insertion technology. I disclose both capacities.

Forum Grüne Vernunft e.V. ∙ OT Gatersleben ∙ Am Schwabeplan 1b ∙ 06466 Stadt Seeland Stellungnahme zu VO (EU)2026/1388 –FGV- Entwurf Sehr geehrte Damen und Herren, das Inkraftsetzen der Verordnung (EU) 2026/1388 mit der Unterscheidung der beiden Kategorien von genomeditierten Pflanzen wird nachdrücklich begrüßt.

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

APROSE (Asociación Profesional de Empresas Productoras de Semillas Selectas) representa al sector de las empresas productoras de semillas y se complace en contribuir, a través de esta Call for Evidence, al desarrollo de esta nueva Reglamentación, poniendo a disposición de la Comisión Europea la experiencia y el conocimiento acumulados por el sector.

Bayer welcomes the opportunity to contribute to this Call for Evidence and supports a Category 1 verification framework delivering consistent, reliable decisions proportionate to the technical and declaratory purpose of the procedure.

Brussels, 25.09.2026 Call for evidence for an initiative on Plants obtained by new genomic techniques: information requirements for and verification of category 1 status, and applications for consent of authorisation of category 2 plants and their products – Submission by the Biodynamic Federation Demeter International NGT 1 Status – Equivalence criteria and Novel Food Regulation Annex I of the Regulation sets out…

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

September 25, 2026 Response to the Call for Evidence on the Implementation of Regulation (EU) 2026/1388 About Plant Sciences Genetics Plant Sciences Genetics (PSG) is a mid-sized, family-owned, professionally managed business based in Watsonville, California.

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

Bayer CropScience welcomes the opportunity to contribute to this call for evidence and supports an implementing act that ensures Regulation (EU) 2026/1388 provides a science-based and innovation-conducive framework for Category 2 NGT plants and their products.

Seeds Canada welcomes the opportunity to contribute to the Commissions call for evidence on the implementing NGT framework. Seeds Canada is the voice of the Canadian seed sector, representing seed growers, analysts, breeders, distributors, processors, retailers, service providers, and all other stakeholders along the seed value chain. Seeds Canada members employ over 14,000 Canadians from coast to coast.

Seeds Canada welcomes the opportunity to contribute to the Commissions call for evidence on Regulation 1388/2026. This regulation is a welcome development that brings the EU closer to the growing global regulatory consensus on NGTs, including Canada.

UFS contribution concerning cat 2 of the LUFS NGT Regulation welcomes the adoption of European Regulation 1388/2026 on the use of NGTs. However, the approach proposed by the European authorities for category NGT2 does not make it possible to envisage their real development in the medium or long term.

Filed in French · English published by the European Commission

LUFS welcomes the adoption of the European NGT Regulation. For this progress to be effective, secondary acts will have to establish functional and achievable devices. The NGT1 status verification procedure must therefore comply with the following 3 principles: 1.

Filed in French · English published by the European Commission

The British Agriculture Bureau (BAB) welcomes the opportunity to respond to the Commissions call for evidence on the information requirements and verification of Category 1 plants obtained through new genomic techniques.

ANOVE represents companies and public centres dedicated to plant breeding and seed and plant innovation in Spain and considers it necessary for implementation to take into account the diversity of crops, traits and genetic improvement strategies that may fall under category 2.

Filed in Spanish · English published by the European Commission

ANOVE represents companies and public centres dedicated to plant breeding and seed and plant innovation in Spain and considers that the verification process for NGT Category 1 plants should be a clear, flexible, proportionate, predictable and science-based process.

Filed in Spanish · English published by the European Commission

EU-SAGE welcomes the opportunity to contribute to the implementation of Regulation (EU) 2026/1388 for Category 2 NGT plants. The secondary legislation should ensure that the case-by-case and proportionate approach established by the Regulation is effectively implemented in practice, with information requirements driven by the characteristics of the plant and by identified safety questions rather than by a fixed data…

EU-SAGE welcomes the opportunity to contribute to the implementation of Regulation (EU) 2026/1388. We consider it essential that the verification of Category 1 NGT plants remains a technical, proportionate and predictable procedure, reflecting their equivalence to conventionally bred plants as established by the Regulation.

The Spanish Bioindustry Association (AseBio), which represents the Spanish biotechnology ecosystem, welcomes the preparation of the implementing acts for the Regulation on new genomic techniques. The adaptations provided for category 2 NGT plants must translate into real procedural improvements, while maintaining high standards of protection and avoiding new burdens, duplication and regulatory uncertainty.

The Spanish Bioindustry Association (AseBio), representing the Spanish biotechnology ecosystem, welcomes the preparation of the delegated acts on information requirements and verification of category 1 NGT plants. Verification should be a technical, fast, predictable and administratively efficient procedure, and must not become a de facto authorisation process.

Ministry of Agriculture of the Czech Republic: clarification of information concerning the submission of evidence for demonstrating category 1 NGT plant status and verification of equivalence with conventional plants In the context of the European Commission public consultation on the initiative “Plants obtained by new genomic techniques: information requirements and verification of category 1 status”, the Ministry…

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

MINISTERIO DE AGRICULTURA, PESCA Y ALIMENTACION Y MEDIO AMBIENTE Convocatoria de datos sobre los actos delegados y de ejecución para apoyar la aplicación del Reglamento sobre nuevas técnicas genómicas Una vez consultados los diferentes Departamentos Ministeriales afectados, se trasladan las siguientes consideraciones.

Filed in Spanish · English published by the European Commission

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

MINISTERIO DE AGRICULTURA, PESCA Y ALIMENTACION Y MEDIO AMBIENTE Convocatoria de datos sobre los actos delegados y de ejecución para apoyar la aplicación del Reglamento sobre nuevas técnicas genómicas Una vez consultados los diferentes Departamentos Ministeriales afectados, se trasladan las siguientes consideraciones.

Filed in Spanish · 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 Swedish Seed Companies Association (SVUF) appreciates the opportunity to contribute to the Commission’s work on delegated acts under Regulation (EU) 2026/1388. In order for regulation to achieve its objective, delegated acts should be designed in a way that ensures effective, uniform and legally certain application across the Union.

Filed in Swedish · English published by the European Commission

European Commission Date: 25.09.2026 Your ref: Ares(2026)8283054 NIBIO Postboks 115, 1431 Ås Tlf: 406 04 100 [email removed] nibio.no Org. nr: 988 983 837 Plants obtained by new genomic techniques: information requirements and verification of category 1 status This initiative supplements Regulation (EU) 2026/1388 on plants produced by certain new genomic techniques (NGTs).

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

CiB (Centro de Informação de Biotecnologia) welcomes the call of the European Commission for Evidence on the implementing framework for Category 2 NGT plants under Regulation (EU) 2026/1388. CiB considers that Category2 NGT plants require a regulatory framework specifically designed for new genomic techniques and not one derived from the existing EU regulatory approach for classical genetically modified organisms.

Euroseeds welcomes the opportunity to contribute to the preparation of implementing acts under Regulation (EU) 2026/1388 on plants obtained through new genomic techniques (NGTs). Effective implementation will be critical to ensuring that the framework is workable, scientifically credible and capable of accommodating the diversity of products expected within Category 2.

Euroseeds welcomes the Commissions Call for Evidence and the opportunity to contribute to the preparation of delegated acts under Regulation (EU) 2026/1388. A clear, predictable, proportionate, and innovation-friendly framework aligned with the objectives of the primary legislation is essential to support investment, farmer access to improved varieties, EU competitiveness, and sustainability, while minimizing…

CIB welcomes the call of the European Commission for Evidence on the implementation of the verification system for Category 1 NGT plants under Regulation (EU) 2026/1388. CIB considers that the success of the new framework will depend on a verification procedure that is scientifically sound, proportionate, predictable and workable.

Filed in Portuguese · English published by the European Commission

On behalf of the board of directors of the Greek Seed Trade Association (SEPY), please find attached our feedback regarding the public consulation of the European Commission on the supplementary legislation for Regulation 2026/1388. Dr. A.D. Diamantidis Agriculturalist General Director GREEK SEED TRADE ASSOCIATION (SEPY) Avlidos 5, 115 27 ATHENS Τ: [phone removed] http://www.sepy.gr

EdiVite contribution to the EC Call for Evidence Verification of Category 1 NGT plants EdiVite S.r.l., a University of Verona spin-off developing DNA-free genome-edited grapevines, welcomes the opportunity to take part in the Call for Evidence and submit comments in view of the preparation of the delegated act on Category 1 NGT verification.

For the specific detection of NGT 2 plants, the individual genetic modification shall not be considered alone. For example, even if it is identical to a modification occurring in conventional plants, the NGT 2 plant may be distinguishable by its variety-specific genetic fingerprint.

Filed in German · English published by the European Commission

25 September 2026 EFFCA’s Contribution to the Commission’s Call for Evidence on the Implementation of the NGTs Regulation (first call) The European Food and Fermentation Cultures Association (EFFCA) welcomes the opportunity to contribute to the preparation of the delegated act concerning the information requirements and verification procedure for Category 1 NGT plant status.

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

For reliable verification of NGT 1 status, complete genome sequence data of the plant must be provided before and after the intervention. Only by comparing these data can it be verified that the NGT 1 criteria are met and that no foreign DNA is present. When placed on the market, at least the sequence data of the genetic modifications and appropriate varietal markers shall be publicly available.

Filed in German · English published by the European Commission

Argentina welcomes the adoption of Regulation (EU) 2026/1388 and the opportunity to comment on its implementation, drawing on eleven years of regulatory experience with products obtained through New Breeding Techniques (NBTs). Argentinas regulatory framework does not divide products obtained through NBTs into two categories. Resolution No.

Argentina welcomes the adoption of Regulation (EU) 2026/1388 and the opportunity to comment on its implementation, based on eleven years of experience in determining the regulatory status of products obtained through New Breeding Techniques (NBTs). For Category 1 NGT plants, a case-by-case procedure based on scientific evidence and focused on the final product is recommended.

Comments from the National Directorate for Bioeconomy of the Secretariat of Agriculture, Livestock and Fisheries of Argentina on plants obtained by new genomic techniques Ref. Ares (2026) 8283054 Information and verification requirements for category 1 status and requests for consent or authorisation for category 2 plants and their products General comment from Argentina welcomes the adoption of Regulation (EU)…

Filed in Spanish · English published by the European Commission

Comments from the National Directorate for Bioeconomy of the Secretariat of Agriculture, Livestock and Fisheries of Argentina on plants obtained by new genomic techniques Ref. Ares (2026) 8283054 Information and verification requirements for category 1 status and requests for consent or authorisation for category 2 plants and their products General comment from Argentina welcomes the adoption of Regulation (EU)…

Filed in Spanish · English published by the European Commission

Beyond GM is a UK civil society organisation working on the governance of genetic technologies in food and farming. We offer these comments particularly in light of recent experience with England's new precision-breeding regulatory framework, which provides a useful live comparator as the EU develops its own implementing rules.

Beyond GM is a UK civil society organisation working on the governance of genetic technologies in food and farming, with particular interests in transparency, traceability, organic production, regulatory accountability and meaningful public oversight. We recognise that Regulation (EU) 2026/1388 establishes the framework for Category 1 NGT plants.

As the Association of Greek Antiphylloarium Vine Plants (SEFAA), please find attached our observations and proposals concerning the application of Regulation (EU) 2026/1388 and, in particular, the preparation of the delegated acts provided for in Article 25 thereof.

Filed in Greek · English published by the European Commission

Authorisation of new breeding techniques is a historic breakthrough for innovation and sustainability in agriculture. The European regulation on new breeding techniques (NGTs) has been published. This will finally make it possible for European plant breeders to start using these techniques.

Filed in Dutch · English published by the European Commission

EUROPLANT breeds, grows and sells high-quality potato varieties with a portfolio of more than 100 modern and powerful food, processing and starch varieties. The delegated act as well as the implementing rules of the Member States must consistently support the facilitated handling of NGT1 plants and must not create additional regulatory hurdles that cannot be overcome by medium-sized breeding operations.

Filed in German · English published by the European Commission

Stellungnahme NPZ zum Delegierten Rechtsakt betreffend die Informationen und Daten für die Verifizierung von NGT1-Pflanzen sowie die Inhalte der Patentinformationen und Lizenzerklärungen 1. Grundsatzerwägungen Der Delegierte Rechtsakt muss dem Grundgedanken der umzusetzenden NGT-Verordnung folgen: Die Nutzung von NGT1-Pflanzen soll unter strikter Ausrichtung an wissenschaftlichen Kriterien konsequent erleichtert und…

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 entry into force of Regulation (EU) 2026/1388 with the distinction between the two categories of genome-edited plants is warmly welcomed. This Regulation will facilitate the translation of research results into marketable genome-edited plants for SMEs and scientists from governmental and university research institutions. For users and consumers, this can bring safe and improved plants to the market, e.g.

Filed in German · English published by the European Commission

September 24, 2026 CoverCress Inc (CCI) has converted field pennycress through advanced breeding and use of gene editing tools to create a regenerative agricultural oilseed crop marketed under the trade name of CoverCress®. This new domesticated pennycress crop has a winter annual growth cycle, allowing it to fit into an existing corn and soybean crop rotation, and is currently grown in the Midwest United States.

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

The entry into force of Regulation (EU) 2026/1388 with the distinction between the two categories of genome-edited plants is strongly welcomed. This Regulation will facilitate the translation of research results into marketable genome-edited plants for SMEs and scientists from governmental and university research institutions.

Filed in German · English published by the European Commission

Category 2 NGT plants encompass diverse crop-trait combinations that do not inherently pose greater risks than Category 1 NGTs or conventionally bred plants (EFSA opinion of 11/07/2024). As acknowledged in Recital 37, their assessment requires a flexible, case-by-case, risk proportionate approach driven by clearly defined risk hypotheses.

CropLife Europe welcomes the Commissions Call for Evidence on the delegated act under Regulation (EU) 2026/1388. The success of the new framework for plants obtained by certain new genomic techniques will depend on the delegated regulation that provides legal certainty, is practical, proportionate, and supportive of innovation.

NGT1 plants (Recital 16 of the Regulation) are defined as plants that could also occur naturally or be produced by conventional breeding techniques. However, the criteria set out in Annex I are not by themselves adequate to evaluate equivalence between NGT and conventionally bred/naturally occurring plants.

The value of the European rules for New Genomic Techniques (NGT) is ultimately determined by the feasibility of the verification procedure. For breeders and public researchers, it should be clear in advance what information is needed, how changes are counted and when a plant can be definitively treated as category 1 (NGT-1).

Filed in Dutch · English published by the European Commission

Loacker is an international confectionery company headquartered in Bolzano, Italy. Our products are exported to more than 100 countries. For many years, the recipes have been based on selected ingredients with different quality characteristics, even without genetic engineering. This attribute is valued by consumers.

Filed in German · English published by the European Commission

NGT-1 verification should therefore be simple, science-based, predictable, low-cost and fully harmonised across the EU. Regulation should not create unnecessary barriers that reduce farmers access to new varieties or increase seed costs. Verification costs must remain proportionate, particularly as the number of NGT-1 applications is expected to grow.

NGT-1 verification should therefore be simple, science-based, predictable, low-cost and fully harmonised across the EU. Regulation should not create unnecessary barriers that reduce farmers access to new varieties or increase seed costs. Verification costs must remain proportionate, particularly as the number of NGT-1 applications is expected to grow.

Practical and low-bureaucratic rules are essential for the targeted and effective implementation of Regulation (EU) 2026/1388 on plants obtained by new genomic techniques (NGTs). We would therefore ask you to continue to develop the above-mentioned Regulation in accordance with Decision 19/12747 of the Bavarian State Parliament of 7 July 2026.

Filed in German · English published by the European Commission

Practical and low-bureaucratic rules are essential for the targeted and effective implementation of Regulation (EU) 2026/1388 on plants obtained by new genomic techniques (NGTs). We would therefore ask you to continue to develop the above-mentioned Regulation in accordance with Decision 19/12747 of the Bavarian State Parliament of 7 July 2026.

Filed in German · English published by the European Commission

Verification procedure of NGT-1 plants Only the essential information that is necessary to describe if the used plant is fulfilling the equivalence criteria regarding NGT-1 status described in Annex I should be mandatory. The verification process should ideally be efficient and predictable for both developers and competent authorities.

GEFSES from McGill University welcomes the European Commission's implementation of the Category 1 NGT framework and the opportunity to provide input to the consultation. As a Canadian [industry/producer/food/feed/agricultural organization], we recognize the EU is an important trading partner for Canada.

Euromaisiers, the association representing the European maize milling sector, welcomes the opportunity to provide comments on the implementing rules concerning the verification of Category 1 plants obtained through New Genomic Techniques (NGTs) and the related information requirements.

The European flour milling sector welcomes the Commission's initiative to establish practical rules for the verification of Category 1 NGT plants and the associated information requirements under Regulation (EU) 2026/1388.

New Genomic Techniques — Call for Evidence AFBV’s Response on the Verification of Category 1 Status 21 September 2026 The Association Française des Biotechnologies Végétales (AFBV) thanks the Commission for allowing all stakeholders to take part in this Call for Evidence and submits the following comments on the information and procedural requirements for demonstrating that a plant is an NGT plant and for verifying…

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

Nouvelles techniques génomiques (NTG) — Appel à Contributions (Call for Evidence) Réponse de l’AFBV sur l'évaluation des végétaux de catégorie 2 21 septembre 2026 L'AFBV soumet les commentaires suivants sur les exigences en matière d'information et sur la méthodologie applicable à l'évaluation des risques des végétaux et produits NTG de catégorie 2, ainsi que sur les exigences de notification et de demande…

Filed in French · English published by the European Commission

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

New Genomic Techniques (NTG) — Call for Evidence AFBV’s Response on the Assessment of Category 2 Plants 21 September 2026 AFBV submits the following comments on the information requirements and on the methodology applicable to the risk assessment of category 2 NGT plants and products, as well as on the associated notification and authorization requirements. 1.

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

Nouvelles techniques génomiques (NTG) — Appel à Contributions (Call for Evidence) Réponse de l’AFBV sur la vérification du statut de catégorie 1 21 septembre 2026 L'Association Française des Biotechnologies Végétales (AFBV) remercie la Commission d'avoir permis à toutes les parties prenantes de participer à cet appel à contributions (Call for Evidence) et soumet les commentaires suivants sur les exigences en matière…

Filed in French · English published by the European Commission

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

Affinché il potenziale delle nuove tecniche genomiche si traduca in benefici concreti per l'intera filiera agroalimentare, è condizione necessaria che il quadro normativo sia armonizzato, proporzionato e di agevole applicazione.

No Patents on Seeds! demands that within the delegated acts, the delineation between patents on NGT plants and the non-patentability of naturally occurring biological resources (as used in conventional breeding) is clarified. This issue should become part of the information request under Articles 6 and 7 that can be defined by the Commission (as empowered by Article 25).

The Regulation has major shortcomings from a consumer protection perspective. We call on the Commission to make full use of the existing scope for improvements related to the criteria for NGT 1 plants. 1. Equivalence criteria and plausibility check: Please note that according to Groover et al.

Filed in German · English published by the European Commission

Transparency throughout the chain is indispensable to the acceptance of NGTs. The Regulation already provides for "NGT-1" identification of plant reproductive material and its entry in the relevant catalogues and in a public database.

Solana is a family-owned potato breeding and seed potato business based in Germany. We have been breeding potatoes for over 120 years and sell into more than 50 countries. Potato is tetraploid, highly heterozygous and propagated vegetatively. For a company like ours the question is narrow and practical: can a mid-sized breeder actually assemble the evidence the verification procedure will ask for?

Filed in German · English published by the European Commission

The Regulation has large deficiencies, not all of which can be cured by the upcoming delegated acts. However, some improvements may be possible. There is room to bring the criteria for NGT 1 plants in line with some recent technological developments.

ASAJA Asociación Agraria Jóvenes Agricultores Aportaciones de ASAJA a la convocatoria de datos sobre los actos de desarrollo del Reglamento de nuevas técnicas genómicas (NTG) La Unión Europea no puede exigir a sus agricultores que reduzcan insumos, se adapten al cambio climático y mantengan su competitividad mientras limita su acceso a las herramientas necesarias para conseguirlo.

Filed in Spanish · English published by the European Commission

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

This submission does not question the architecture of Regulation (EU) 2026/1388 or the treatment of category 2 NGT plants under the GMO legislation. It concerns what the justification permitting the arrangements for analytical methods to be adapted must contain, and how control laboratories obtain the means of applying those methods.

This submission does not question the architecture of Regulation (EU) 2026/1388 or the two-category classification. It concerns the consistency between an objective the legislator stated and the instruments the delegated act is to define.

Could societal debates over the future of new genomic techniques (NGTs) in sustainable agriculture be hampered by entrenched positions of environmental groups and/or populist political actors, as was the fate of genetically modified organisms (GMOs) in Europe?