GENTECH archive 8.96-97


Letter to European Parliament

Dear Member of Parliament:

On Thursday the European Parliament will vote on the proposed text of the Novel
Foods Regulation. 

On behalf of the International Council of Natural Law Parties we urge you to 
VOTE NO on this regulation, or to abstain, if you are not completely clear 
concerning the ramifications of this legislation.

The implicit intent in formulating a novel foods regulation is to govern the 
marketing of genetically engineered foods to ensure that they are safe and that
consumers are provided with sufficient information to make informed food 
purchasing decisions. However, in its current form, the Novel Foods Regulation 
falls far short of this objective.

This bill is worded so ambiguously and is so open-ended that it gives the 
European Commission carte blanche to regulate--or not regulate--genetically 
engineered foods in any way that they choose. 

What can we expect from the Commission if they secure this power? The 
Commission9s Draft Guidelines for the Competent Authorities on Implementation o
the Novel Foods Regulation provides detailed--and disturbing--information on 
this topic. Not surprisingly, in light of its contents and in light of the past
record of the Commission on this issue1, this document is inaccessible to the 
public and available to Members of the European Parliament only with great 
difficulty. Because of this, most Members of the European Parliament will be 
voting on the Novel Foods Regulation without understanding fully its 
ramifications for the safety of consumers and for consumers9 right to make 
informed food purchases.

In short, these ramifications are as follows: 
(1) Liberal use of the concept of substantial equivalence (discussed below2) 
will speed most genetically engineered foods to market with only the most 
superficial safety testing. This will expose consumers to potentially hazardous
genetically engineered foods. 
(2) At least 80% of genetically manipulated products will not be labeled and th
other 20% will be labeled so ambiguously that the genetically engineered nature
of these products will be totally obscured. As a result, consumers will be 
deprived of the information that they need to choose for themselves whether or 
not to accept the risk associated with genetically engineered foods.

Access to safe, nutritious food and the ability to make informed choices 
regarding food purchases are fundamental and inalienable rights. Citizens 
implicitly trust that their government faithfully guards these and other rights
Yet, in its current form, the Novel Foods Bill ignores these rights while 
favoring the commercial interests of foreign multinational corporations.

To ratify this regulation, in its current form will be to betray the trust of 
the citizens of Europe. 

We urge you to consider the following lines of action. 
- - First, vote against ratification of the Novel Foods Regulation.
- - Second, if an opposing vote is not possible, abstain from voting on this bill
- - Third, if you have not examined for yourself the Commission9s draft guideline
on how they intend to implement the Novel Foods Regulation, then put forward a 
motion to postpone consideration of this bill until such time as all Members of
the European Parliament have been provided with the full text of this document.

You and your colleagues in the European Parliament have in the past made wise 
and prudent decisions regarding genetic engineering. The legislation that you 
will be considering on Thursday is critical to the welfare of your constituents
We trust your power to judge in support of life for all future generations.  
Please, accept, the assurances of our highest esteem,

Jan Storms, M.A.
Director of the Scientific Bureau 
Member of the Board
Natural Law Party of The Netherlands

John Fagan, Ph.D.
Professor of Molecular Biology
Scientific Advisor 

1. The Commission9s highly inappropriate bias is reflected in their recent 
decisions to admit gene-spliced soy beans and corn to the EU market without 
adequate safety testing and without labeling. Why should the interests of singl
corporations take precedence over the health and rights the whole European 
population? This does not even make economicf sense, since Monsanto and 
Ciba-Geigy, the companies producing these crops, are not even based in EU membe

Polls in every European country show that the vast majority of consumers do not
want genetically altered foods, and that an even larger majority wants clear 
labeling that will allow them to choose for themselves whether or not to eat 
these inadequately tested foods. Consumers are also concerned about the safety 
of these novel foods. The Novel Foods Regulation, in its current form, ignores 
all of these issues. Thus it would be hard to find a more blatant case of 
dissonance between the wishes of the population and the stance of the 

The Commission9s highly favorable stance toward use of genetic engineering in 
food production is primarily based on the belief that this technology offers th
key to competitiveness in the global food market for the 21st century. It shoul
be emphasized that the basis of this belief is highly speculative. There is no 
objective evidence that this promise will be fulfilled, and thus it is highly 
unrealistic to so unreservedly foster this technology at the expense of the 
health and rights of consumers.

The Commissions naive faith in genetic engineering is quite short-sighted in 
light of the fact that the objectives that they hope attain can actually be 
achieved much more directly and reliably through other technologies. These 
agricultural technologies are far safer for consumers and the environment, as 
well as more effective, and economical. They are also ready for implementation 
today, instead of requiring years more of research and development, as is the 
case with genetic engineering. 

Here we refer to the wide range of sustainable approaches in agriculture 
available today. These can maintain and even increase food production, while 
avoiding poisonous chemicals and practices that harm health and destroy 
agricultural resources. The natural course of evolution will inevitably lead in
the direction of real progress in many areas of life as a consequence of the 
rising consciousness and increasingly holistic values of the population. These 
are driving the growth in popularity of more integrated and balanced food 
production technologies, a trend in society that is diametrically opposed to 
that which is now being promoted by the Commission.

2. The International Council of Natural Law Parties wishes to point out that th
concept of "substantial equivalence" upon which the Commission bases its 
proposed regulation is a subjective and nebulous term which is left undefined i
the bill and which is therefore open to arbitrary interpretation. A rigorous an
scientific interpretation of the concept would lead to the conclusion that ever
gene-spliced food unavoidably differs substantially from its natural 
counterpart. The gene-splicing itself introduces foreign DNA or RNA sequences i
the food organism. These sequences program the food organism to make novel 
proteins not normally present in the organism. These proteins, themselves, make
the genetically engineered food non-equivalent to its genetically engineered 
counterpart, and they can also alter the metabolic and other functions of the 
food organism, leading to other significant differences between the genetically
engineered food and its natural counterpart. Processed foods, such as oil, 
lecithin, and syrup, are often claimed to be free of transgenic proteins and 
other compounds and thus no different from their non-genetically engineered 
counterparts. This is fallacious reasoning because these prepared foods are 
never chemically pure, and will therefore contain a certain amount of these 
genetically engineered proteins. Thus, even heavily processed foods cannot be 
argued to be substantially equivalent, since they will be contaminated with 
genetically engineered proteins or their products. 

While it is scientifically untenable to claim that a genetically engineered foo
is substantially equivalent to its non-genetically engineered counterpart, this
phrase, as it is used today, implies that the two are equivalent in all 
important ways. Since this is not the case, the use of this phrase is no more 
than a ploy to escape the in-depth safety testing and accurate labeling that th
consumer rightfully expects. 

A vast number of people in the European Union consider genetic manipulation to 
be a technology that  is harmful to the integrity of living beings and nature a
a whole, and it is without a doubt a technology whose long-term safety has not 
been demonstrated. In these two ways, gene-spliced foods are clearly  
3substantially non-equivalent2 to natural foods.

The International Council of Natural Law Parties supports legislation that woul
require that all gene-spliced products be tested rigorously to assure safety an
that they be clearly labeled, without exception. Labeling is practically 
possible on the basis of separation of genetically altered products, and 
certification of non-manipulated products. Rigorous testing procedures capaable
of distinguishing natural and genetically altered  ingredients are available. 
The logistics to segregate gene-spliced products from natural ones are 
straightforward, and already being implemented quietly in the US based on 
consumer demand. There is no excuse for not systematically implementing these 
measures through legislation in Europe.

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