Genetic Technologies (Precision Breeding Techniques) Bill: a call for sector support
Soil Association Certification are calling on our clients and other trade partners to help us raise awareness of the potential impacts the Genetic Technologies (Precision Breeding Techniques) Bill on both the organic sector and wider UK agri-food.
We ask for your help to prevent the Bill being passed in its current form. The Bill seeks to change regulation of genetic technologies for England and will remove some of the current regulatory oversight and safeguards. This will be a risk to all regions of the UK.
The impact assessment carried out on the Bill has been ‘red rated’ by the Regulatory Policy committee, as it was deemed not fit for purpose and did not take into account the economic impact of the Bill. The Bill, in its current form, is likely to lead to severe economic shocks in the marketplace, undermining the viability of farmers and food businesses, especially those with organic products, across the United Kingdom.
Why is the Genetic Technologies (Precision Breeding Techniques) Bill problematic?
The Bill seeks to reform regulation of genetic technologies for England and in so doing removes some of the current regulatory oversight and safeguards.
We are deeply concerned that the expected due process and required evidence to underpin this Bill are missing, and we are not alone. In the opinion of the Regulatory Policy Committee, Defra’s Impact Assessment for the Bill was rated red, i.e. ‘unfit for purpose’. This is largely unprecedented, being the first ‘unfit for purpose’ rating for the Department for Environment, Food and Rural Affairs since 2015. The expert evidence sessions and following debate at the Bill Committee stage saw little support for the Bill, serving only to validate and expand on the concerns set out by the Regulatory Policy Committee.
We are aware that following such a ‘red’ rating, decisions on whether to proceed with the Bill are for Ministers to take, but that it is very unusual to proceed without undertaking a more thorough Impact Assessment. We believe that to progress the Bill without a proper Impact assessment erodes the credibility of a Government department (which otherwise has a highly commendable record of evidence-based decision making) and undermines industry and public confidence in Defra.
Furthermore, the failure to fully consider economic impact is likely to seriously undermine the economic viability of both organic and non-organic farmers and food businesses across the whole of the United Kingdom.
How could the Bill affect the organic sector and wider agri-food in the UK?
There could be significant impact to businesses such as organic, and those that seek to secure GE free markets. The absence of mandated supply chain traceability, labelling and coexistence measures is likely to result in the loss of market opportunities, with a high potential for devastating impacts. A quantification of these impacts is needed, alongside a quantified comparison with scenarios where these measures are mandated.
Deregulation could create commercial drivers which may push the overall use of these technologies down pathways that are at odds with environmental, climate, social and ethical goals. Peer-reviewed research is needed to review these risks.
There is legal ambiguity around the definition of ‘precision bred’ which forms the heart of the Bill, posing a high risk that plants and animals with genetic alterations that go beyond that expected, may nonetheless legally meet this definition. We believe peer-reviewed research is needed to review these risks.
What are we asking the government to do?
We are shocked that the Government has failed to assess the economic impact of this Bill, which is a huge risk to British businesses, but we know that this can be resolved if the Bill is paused, evidence is collected, and appropriate amendments are made and a fit-for-purpose impact assessment is undertaken.
This must include an assessment of the three areas (above) identified as potentially affecting UK organic and wider agri-food sectors and must inform the Bill accordingly, before it proceeds to report stage. To do so later, risks baking in ill-informed assumptions around what changes may be needed and risks developing legislation that is not only ineffective but counter-productive.
We are clear however that these issues are not insurmountable. With this evidence and analysis underpinning decisions, solutions can be found. Without this assessment now however, the aims for this Bill – to expand the use of these technologies and to deliver public good – could very well fail.
What can I do?
We are asking our clients to share our concerns with their MP and ask that the government uphold the long running Government standards in evidence-based decision making and to protect farmers, food businesses and the interest of citizens across the country.
We have attached a template letter, the content of which is based on a communication recently sent to the Secretary of State for Environment and Rural Affairs on behalf of the organic sector.