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We must have adequate consultations on gene editing

Have your say on the Food Standards Agency consultation on gene-editing

The Food Standards Agency have launched a public consultation on the evolving regulation of gene-edited products – or ‘precision-bred’ organisms (PBOs).


The questions proposed in the consultation are technical and complicated. So, we have created some guidance to help you respond. Your response will need to be personalised to be considered. There are two ways to respond to the FSA’s consultation:

• You can use the online form

• Or you can submit a letter via email 

Use the guides below to formulate your response by 8th January. These include;

1) A detailed technical guide with suggested responses to each question.

2) A summary of our main concerns;

  • Changing from regulation to no regulation is not proportionate, especially since the safety of these new GMOs have yet to be established. 
  • The main beneficiaries of this two-tiered approach are the developers who are being allowed to self-certify the status of their precision-bred organism. 
  • The premise that precision-bred organisms are different from other GMOs is scientifically unsound and a poor basis for regulatory decisions. 
  • Without labelling, consumers and businesses will find it difficult to avoid PBOs in their food supply, and farmers will not be able to choose what they feed their animals. 
  • The FSA says there is a lack of evidence that PBOs are intrinsically riskier to consumers. The absence of evidence is not the same thing as proof of safety and this deviates from the precautionary approach that is generally applied in food safety matters. 
  • The information pack does not provide adequate information on how these proposals will work within the UK internal market, particularly in Scotland and Wales whose governments oppose the Act.
  • The FSA has only conducted a partial impact assessment and has chosen to rely on an earlier Defra Impact Assessment which the government’s own Regulatory Policy Committee found to be “not fit for purpose”. Key considerations missing from the impact assessment include: 
    • Consumer’s right to know what they are eating and their ability to judge this at any point of sale 
    • Impacts on trade, especially where UK regulations differ from those of trade partners. 
    • The cost and economic losses associated with a product recall if a GMO/PBO causes a toxic or allergic reaction. 
    • The implications for traditional breeders and the organic sector. 

The above guidance was developed by Beyond GM. Additional material has been added by the Biodynamic Association, GM Freeze, Organic Farmers and Growers and the Soil Association.

The consultation was launched on the 8th of November and comes nine months after the Genetic Technology (Precision Breeding) Act was passed into law. This was despite significant public and industry opposition

The Genetic Technology Act pitches gene-editing as a different category of genetic modification - one in which the outcomes could hypothetically be possible through traditional breeding. As a result, the law strips away the regulation for so-called 'precision bred' organisms, ignoring overwhelming public demand to maintain these crucial safeguards.  

How these organisms will be produced and sold, including whether they are labelled or not, depends on the development of secondary legislation over the coming months. This is where the Food Standards Agency (FSA) comes in. They are responsible for protecting public health and consumer confidence, placing them at the heart of the conversation on the future of gene-edited products. They must ensure that emerging legislation protects society from any unintended consequences these organisms could trigger.   

The FSA has produced a set of proposals for how they intend to do this and has invited members of the public to share their views. You can do this here.

However, the Soil Association and other organisations have noticed various red flags within the consultation, including:

  • Its timeline. The consultation period is four weeks shorter than the official recommended 12-week timeframe for public consultation and coincides with the winter festivities. This is likely to restrict the capacity of many businesses and individuals to respond. 
  • Its assumptions about organic. In section 11.26 of the consultation, the FSA states, ' Traditional breeders and organic food and feed firms could be disproportionately impacted should they choose to continue to supply non-PBO food/feed.’ This suggests that the exclusion of PBOs from organic production is somehow optional. It is not. Genetically modified organisms are prohibited in organic systems, and that includes PBOs.  


In response to these concerns, a series of letters have been sent to the FSA: the Soil Association coordinated one for the organic sector. GM Freeze and Beyond GM have also highlighted vital flaws in the consultation. While we hope the FSA will take these comments on board and make the necessary amendments, the clock is ticking, so we urge anyone interested in the consultation to respond as soon as possible. 

Here are details on our response and advice on submitting yours in the coming weeks.

Read our position statement here to learn more about broader concerns with the Genetic Technology Act.