Agriculture Reference
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of PMPs, substance-specific threshold limits would be more likely. In
analogy to the limit values for pesticide residues (EU Regulation
396/2005), limit values will need to be harmonized across the EU, either
for specific substances or for particular categories of PMPs, as differ-
ences in limits between EU member-states would hamper food and feed
trade. Limit values would not only be an issue regarding contamination
of conventional or organic crops, it would also pertain to GM food/feed
crops. Such a scenario would render food control a more complex
matter.
A related issue would be the question of liability that is of paramount
interest to the food and feed industry, as well as to farmers. 53 Who would
be liable in case of accidental commingling of pharm crops with food or
feed crops? Who would be responsible for the economic damages from
low levels of pharm crops found in food crops when producers fully com-
ply with the rules? In such cases, compensation might cover a broad
range of direct and indirect costs including 54
lost export earnings
retrieval of contaminated grain
reduced value of nonpharma grain or oilseeds
recall of products from grocery shelves
cleaning of grain elevators and processing plants
testing expenses
added transportation and handling costs
lost storage and merchandising income
long-term market loss resulting from increased foreign competition
rejected supplies of meat, dairy products, and eggs
animal or human illnesses
53 S. Smyth et al., Liabilities and Economics of Transgenic Crops. 20 Nature Biotechnol-
ogy 537-541. (2002).
54 R. Wisner, The Economics of Pharmacutical Crops. Potential Benefits and Risks for
Farmers and Rural Communities, (Union of Concerned Scientists, 2005).
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