Currently, all organisms derived from genetic engineering processes must undergo risk assessment before they can be released, cultivated or consumed as food. The Commission now wants to abandon this basic principle of EU legislation. Testbiotech is warning against such far-reaching deregulation.
TVI
Testbiotech e.V. - Institute for Independent Impact Assessment of Biotechnology
NGO · Germany · EU Transparency Register 151554816791-61
4
positions filed
in the 673 files tracked
2
legislative files
of 673 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 673 consultation files tracked so far (58,314 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1109 non-governmental organisations on this site, they rank #506 by legislative files engaged, a count of participation, not a measure of influence.
0.8
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2015
in the register since
Declares membership of
- European Environmental Bureau, EEB
Self-declared to the EU Transparency Register (snapshot 20 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- Testbiotech
- Head office
- München, Germany
Self-declared to the EU Transparency Register (snapshot 20 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Testbiotech e.V. - Institute for Independent Impact Assessment of Biotechnology filed 4 positions between 31 Aug 2023 and 28 Sept 2026, across 2 of the 673 legislative files tracked here, attaching a full position paper 4 times.
2023 · 1 filed2026 · 3 filed
What they argued
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.
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 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.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
Showing 5 of 48.
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Everything on this page comes from Testbiotech e.V. - Institute for Independent Impact Assessment of Biotechnology’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.