The Use of GM Crops in Developing Countries
Interdependence: the impact of European and international trade policy
5.43 The issues associated with the provision of food aid derived from GM crops clearly illustrate the powerful influence that external factors can have on decision making regarding the use of GM crops in developing countries. As we have observed, the attitudes of consumers in Europe and the US and the provision of direct and indirect agricultural subsidies by developed countries have been significant. However, the impact of EU regulatory policy for the management of GM crops and GM food may have an even greater impact.
5.44 In the case of GM food crops intended for export, decisions made by developing countries about the choice of crops are likely to be influenced by the selection of crops approved by European regulations. The revised Directive 2001/18/EC in conjunction with Regulations 1830/2003/EC and 1829/2003/EC on Traceability and Labelling and on Food and Feed determine the types of GMOs that may be imported into the EU. Furthermore, if the current perception of the majority of European consumers that such imported materials are ‘contaminated’ prevails, it is very likely that GM food and feed, and products derived from GM crops, will be less competitive on European markets.
5.45 There are also issues with regard to ensuring the traceability requirements specified in the EU regulations. As we have said, most developing countries may find it difficult and costly to put in place adequate institutions and systems to assure required standards of monitoring. EU regulations may also have a significant financial impact when a developing country decides to use GM crops for domestic use only. As the thresholds for labelling are very low (0.9% for an approved GMO, and 0.5% for an unapproved GMO), care would have to be taken to prevent mixing of grain and flour from GM crops intended for domestic use with non-GM grain and flour intended for export. Ensuring adequate separation of the two is likely to be costly. It would be highly undesirable for developing countries to choose not to use higher yielding GM crop varieties for domestic use because of concerns about ‘contamination’ of non-GM crops for export.
5.46 Within any country, regulations similar to those in the EU would tend to discriminate strongly against poor small-scale farmers, for two reasons. First, the grades and standards of verification for, say, 1,000 hectares of a crop is more costly if those hectares are divided between 1,000 farmers, than if they comprise one very large (and almost certainly labourdisplacing) farm.33 Secondly, where the food supply chain comprises a great number of small-scale farmers connected through many small-scale retailers, the verification of GM content and processing methods will be much more expensive than for a few large farmers linked mainly to supermarkets or multinational exporters. Where traceability is required, the effect will be especially harmful to poor farmers. Under the newly approved EU regulations, the determination of the level and type of genetically modified DNA in the end-product will not suffice. Instead, verification will be required for all stages of the production and processing, throughout the whole food chain, from producer to final user.
5.47 Just as overly stringent regulation which focuses almost exclusively on the possible risks of GM crops discriminates against poor countries, so it also discriminates against smaller and poorer producers and retailers. Many small-scale farmers in developing countries grow crops for export such as sugar, coffee, tea, rubber and cotton. Small-scale farms are run by much poorer people, and employ considerably more workers per hectare than large plantationbased farms. It is therefore especially important that developed and developing countries avoid measures that discriminate against these small-scale growers.
5.48 Unless European consumers become far less sceptical towards GM crops, few developing countries will wish to grow them. We have observed that a rapid spread of GM crops has already occurred in several parts of the world (paragraph 3.21). However, scarcely any GM food and feed crops have been approved for commercial planting in the developing countries of Asia, Africa or the Middle East. This situation appears to derive in part from fears that a highly restrictive interpretation of the precautionary approach in Europe and Japan will close off export sales.
5.49 The freedom of choice that farmers in developing countries can exercise is severely restricted by the agricultural policy of the EU. This policy has been developed primarily to protect European consumers and the environment from potential dangers. But after almost a decade of use of GM crops, there is no robust scientific evidence that their consumption has adverse effects on human health.34 There have been reports of gene flow from GM crops to other cultivars or wild relatives. However, as we have said (see paragraphs 4.28- 4.34) this phenomenon is not specific to GM crops. It also occurs frequently in the case of organic and conventionally bred crops, and from improved crops, which have been changed in their genetic structure by exposure to radiation or chemical substances. In our view, the possibility of gene flow as such cannot justify the prohibition of the planting of a crop; only specific adverse consequences which result from it should provide the basis for such a decision (see paragraphs 4.28-4.34).
5.50 There is thus a considerable imbalance between the hypothetical benefits afforded by the EU policy for its own citizens, and the probable and substantial benefits that could be afforded to developing countries (see also paragraphs 4.1-4.2 of the 1999 Report). We conclude that the current provisions of the revised Directive 2001/18/EC, Regulation 1830/2003/EC on Traceability and Labelling and Regulation 1829/2003/EC on Food and Feed have not taken sufficiently into account the negative effect that these policy instruments are likely to have on those working in the agricultural sector in developing countries. It seems unlikely that the current and proposed European regulations will be substantially revised in the near future to prevent the raising of artificial trade barriers for GM products from developing countries. However, we recommend that the European Union (EU), the UK Department for International Development (DFID) and appropriate non-governmental organisations which monitor the agricultural policy of developing countries examine the consequences of EU regulatory policies for the use of GM crops in developing countries. We recommend that the European Commission (EC) establish a procedure to report on the impact of its regulations accordingly.
Footnotes33 Reardon T et al. (2001) Global change in agrifood grades and standards: agribusiness strategic responses in developing countries, International Food and Agribusiness Management Review 2(3).
34 FAO and WHO (2002) Safety Aspects of Genetically Modified Foods of Plant Origin Report of a Joint FAO/WHO Expert Consultation on Foods Derived from Biotechnology, WHO, Geneva, Switzerland, 29 May – 2 June 2000 (Geneva: WHO); Royal Society (2002) Genetically Modified Plants for Food Use and Human Health – an update (London: Royal Society).