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.
GFA
German Federal Agency for Nature Conservation (BfN)
Public authority · Germany
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 655 files tracked
1
legislative file
of 655 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 655 consultation files tracked so far (56,999 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
German Federal Agency for Nature Conservation (BfN) filed 2 positions on 28 Sept 2026, across 1 of the 655 legislative files tracked here, attaching a full position paper 1 time.
What they argued
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.
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