Commissioner Vytenis Andriukaitis
Directorate General Health and Food Safety European Commission
Rue de la Loi 170
Dear Commissioner Andriukaitis:
On behalf of MAIZALL, the International Maize Alliance, we are writing to express our serious concern regarding the continued lack of action by the European Commission to provide the final authorization for import approvals of 13 genetically modified organisms (GMOs). This is troubling as there have been no import authorizations since November 2013, despite positive opinions from the European Food Safety Authority (EFSA) affirming these 13 products are as safe as conventional products. MAIZALL represents maize producer associations from Argentina, Brazil, and the United States. Our member countries account for approximately 70 percent of global maize exports, and we seek harmonized access to trade with the Member States of the European Union that import maize and maize co-products.
Producers in our countries that export to the European Union have experienced years of undue delays in the approval of GMOs for import. The EU relies on imports from third countries such as ours to meet annual deficits of its feed ingredients for livestock and poultry production. As the world’s major producers, we are committed to world markets, including the EU. We work with our partners in importing countries to ensure we are able to meet the needs of a growing, and increasing prosperous world. However, this asynchronous environment for approvals exacerbates an already untenable trade environment with the European Union.
As a member of the World Trade Organization, the European Union has a clear, unequivocal obligation to ensure that sanitary and phytosanitary measures are not more trade-restrictive than required to achieve their appropriate level of protection. Suspension of import approvals for products that have already received a positive food, feed and environmental safety opinion from the European Food Safety Authority does not meet this criteria and violates the spirit of the WTO Agreement.
We are equally concerned that the current European Commission review of existing EU legislation governing the biotechnology approval process for imports will result in yet more delays and even the fragmentation of the internal market for imported commodities. This is a growing problem as the number of biotech product submissions has increased over the years. Further, with new, mostly stacked biotech events being submitted for approval, the backlog will only increase as will the likelihood of adventitious presence of traces of EU-unauthorized GM crops in imports.
The absence of a workable EU standard on low-level presence is a further impediment. In 2011, the EU adopted a 0.1% tolerance threshold for testing – which applies to feed only—for unintended presence of a GM event that is not yet approved in the EU. This so-called “technical solution” does not replace the EU’s zero-tolerance policy and will not effectively address the risks associated with unapproved events that could be included in shipments to the EU. Further trade disruptions will not only deny the opportunity for global feed grain exports, it will result in increased costs for our customers.
At the same time that the EU has been slowing down approvals, the major corn exporting countries of the Americas – the US, Argentina and Brazil — have been taking steps to improve and accelerate their respective authorization systems.
As maize producers, we urge the Commission to lift the de facto moratorium on import approvals of GMOs and to use the review of the procedures for imports to significantly shorten the timelines for EU approvals.
Immediate Past Chairman, U.S. Grains Council, United States
First Vice President,
MAIZALL President, ABRAMILHO, Brazil
Second Vice President, MAIZALL
Immediate Past Chairman, MAIZAR, Argentina