Author: Desislava Georgieva
Published On: 02/02/2024

On 4 January 2024 at 11.30 am in the meeting room of the District Administration – Varna, the Public Centre for Environment and Sustainable Development (PCESD) will present to the Governor of Varna Professor Andriyana Andreeva an open letter to the Prime Minister Acad. Nikolay Denkov and Minister of Environment and Water Yulian Popov. The document is a call for a vote against the European Commission’s proposal to deregulate GMO plants produced with “new genomic techniques”. The meeting of the Council of Environment Ministers of the EU member states, which will be attended by the Bulgarian minister, will take place on 11 January 2024 in Brussels.

Together with the open letter, Ilian Iliev from the EQSD will present the Governor with a crate of environmentally friendly vegetables of guaranteed origin produced by small local farmers. The symbolic act expresses the desire and hope of the small farmer to preserve his livelihood, which will be seriously threatened after the entry into force of the European GMO deregulation regulation.

Listen to what the growers we took the vegetables from had to say about the Governor:

The Public Center for Environment and Sustainable Development was one of the main organizers of the protests at local level against the authorization of GMOs in Bulgaria 13 years ago. As a result, one of the EU’s most stringent laws on GMOs was passed in the country. Currently, the Bulgarian government is refraining from taking a strong stance against the introduction of new genomic techniques by the European Parliament and from opposing the destruction of Bulgarian agriculture, the livelihoods of small producers, biodiversity and the right of Bulgarian consumers to choose clean food.

Here is the full text of the open letter:

TO:

ACAD. NIKOLAI DENKOV

PRIME MINISTER

JULIAN POPOV

MINISTER FOR ENVIRONMENT AND WATER

The agricultural industry wants GMO crops resistant to herbicides and insecticides to be allowed into our fields and on our plates without safety checks or labelling. The European Commission and some members of the European Parliament have obeyed the industry’s orders by developing a GMO deregulation law that will harm health, biodiversity and farmers.

On 11 January 2024, crucial votes are due in the Council of Ministers (EU member states) and the European Parliament’s Environment Committee on the European Commission’s proposal to deregulate GMO plants produced with “new genomic techniques” (NGTs) such as gene editing.

The agricultural industry wants GMO crops resistant to herbicides and insecticides to be allowed into our fields and onto our plates without safety checks or labeling. The European Commission and some Members of the European Parliament have defied the industry’s orders by developing a GMO deregulation law that will harm health, biodiversity and farmers.

On 11 January 2024, crucial votes are due in the Council of Ministers (EU member states) and the European Parliament’s Environment Committee on the European Commission’s proposal to deregulate GMO plants produced with “new genomic techniques” (NGTs) such as gene editing.

The Public Centre for Environment and Sustainable Development urges the Bulgarian government to push the EU to prevent the removal of regulations protecting European citizens from the uncontrolled spread of GMOs in nature and our food.

Without established procedures for discussion in working groups at national level and then in Brussels, the EC urgently demands a vote on the proposal for a regulation on new GMOs as one of the eleven items on the agenda of the Council of Ministers, along with many other topics. This has never happened before. The hope is that many people will not understand what is happening. Because it affects everyone and everything!

In Bulgaria, too, there is a rush, with no answers to scientific questions, with arguments such as ‘we have already agreed to support the EC’.

On 5.07.2023, the European Commission published its legislative proposal to remove regulations on the new generation of genetically modified plants – new GMOs or so-called “new genome techniques” (NGT).

The plan is to remove the new genetic modification label on food packaging because this 20+ year old label makes it easier for big agribusiness to sell their GMOs unnoticed. And consumers will no longer know what they are eating.

New lobbying documents show that even in the final days before the Commission’s final proposal was published on 5 July, it was changed to weaken it even further and push herbicide-tolerant (HT) GM crops into European fields – in line with the wishes of these same corporations. Indeed, while the industry pushed for the deregulation of HTs, claiming that they would help reduce pesticide use, at the same time its misleading lobbying campaign led to the failure of the Pesticide Reduction Regulation (PRR – SUR).

After protests from organisations and scientists, changes were inserted into the proposal for a new regulation, but the absurdities remain:

Absurdity 1: The draft regulation on new GMOs creates two different routes to market for “new genomic techniques” plants: (category 1); and plants with more complex modifications (category 2 – already established GMOs).

The EC, the Bulgarian Ministry of Agriculture and the GMO Commission of the Ministry of Environment claim that the new category 1 GMOs are equivalent to natural plants and conventionally produced hybrids.

Ivelin Zhelyazkov, director of the Plantis Agricultural Research and Technology Centre, says: “The fact that the basic principles of NGT are borrowed from the bacterial genome shows that NGT are as resistant as the bacterial genome. The plant genome is complex and multi-layered, and it is still unclear how it works, despite the complete sequencing of some genomes. We may know what the bricks of a building look like, but we do not currently know what the building itself looks like or how it is constructed. One cannot draw an analogy between NGT on the one hand and hybridization-mutagenesis on the other. With mutations, the process is slow and takes place over many generations until that mutation becomes part of the whole genome, resulting in a new species of plant. In NGT, the new trait usually disappears in the next generation, since the genetic technique itself does not result in the trait being incorporated into the conserved part of the genome. Realistically, NGTs are also GMOs, since cutting a gene packet is also a modification of the genome, however much the companies using NGTs deny this.”

Absurdity 2: Introduce labelling of seeds of NGT 1 plants and voluntary national ‘NGT-free’ labelling schemes. The EC argues that this provides the opportunity for informed consumer choice.

Labelling does not eliminate the danger of a product for which there is insufficient evidence of safety, but on the contrary, there are many suspected adverse effects on human health. The responsibility for possible health effects should not be passed on to the consumer. Informed choice implies consumer competence, which also implies discrimination on this basis. All regulations imposed by the EU and the state must guarantee the health of consumers before products are placed on the market, and not pass the buck to the consumer in the form of informed choice.

There is a need for impartial and independent assessment of the impact of modified organisms at the level of science, laboratories, experimental fields, not at the level of agricultural production and products in food chains.

Nowhere in the Commission’s regulatory proposal is there an explicit request to assess the unintended effects caused by NTM processes.

There is no provision for traceability of the whole process chain – seeds, cultivation, processing, production of the final product for sale in the retail chain.

Voluntary schemes at national level could not work because almost all processed foods are also produced with imported raw materials for which there may be no labelling due to the voluntary nature of labelling.

Scientists cannot yet assess and predict how cultivated plants will function once released into the environment, where conditions are not equivalent to those in the laboratory.

Small and large companies work with the seeds of multinationals and will be subject to their control and dependence. Most of these seeds are also patented by the multinationals, which further puts all producers under absolute control.

The future lies in an innovative agriculture and informed choices that go hand in hand with genuine protection of health and the environment.

The Public Centre for Environment and Sustainable Development urges the Bulgarian government not to succumb to external pressure and the urgent deadlines it faces to issue a positive opinion to remove regulations on the new generation of genetically modified plants – new GMOs or so-called “new genomic techniques” (NGT). A vote of abstention is also not a decision because it implies tacit agreement” with the proposal.

We call on the Bulgarian government and in particular the Bulgarian Minister for the Environment to vote against the European Commission’s proposal to deregulate GMO plants produced with ‘new genomic techniques’ at the Council of Ministers (EU Member States) on 11 January 2024.

This letter is part of the initiative of the Coalition “For Nature to Remain in Bulgaria” against the authorization of GMO plants produced with new genomic techniques without prior risk assessment and labeling.

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