Agriculture Reference
In-Depth Information
whether the different coexistence and liability regimes in the EU
member-state, which are of continuing importance because of nonman-
datory EU recommendations, would be a sensible basis for molecular
farming. Furthermore, different from first-generation GM farming con-
tamination by PMPs and PMIs would be an issue for all food and feed
farmers of organic, conventional, and GM crops.
Even before the first PMP or PMI will be commercially cultivated in
the EU, if this technology advances further in the United States, Canada,
or any other agricultural or food export country, EU regulators may
have to deal with questions of threshold limits earlier than expected. The
recent contamination incidents from noncommercial field trials on lim-
ited acreages of GM crops show that even in such cases, commingling
with conventional food crops can occur.
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Third, there is no equivalent procedure in the EU to what is envis-
aged for commercial molecular farming in the United States. EU Direc-
tive 2001/18/EC foresees two different authorization tracks: time- and
area-limited field trials (Part B) and placing on the market of GM crops
including import, transport, processing, handling, storage, and cultiva-
tion (Part C). Part B authorization can be granted by the respective
member-state only, though derived products must not be used for com-
mercial purposes. Conversely, Part C authorizations would allow for
commercialization, but have to be granted at the EU level by a process
involving all member-states in both risk assessment and decision making.
Both procedures are not appropriate for PMPs. At least these proce-
dures would need to be applied differently compared to first-generation
GM food and feed crops.
Perhaps most PMPs could be produced on limited acreages, such as
100 to 10,000 hectares that compare to large-scale field trials and do
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E.g., The GMO Contamination Register, US GM rice trials contaminate world rice
supplies, available at http://www.gmcontaminationregister.org/index.php?content
=
nw detail2.
