As worldwide acreage of biotech crops continues to increase at double digit annual percentages and government regulators approve more varieties of biotech crop, increasing attention is being paid to international trade and public policy issues on traceability and labeling biotech crops and consumer products. Consumers will not receive the full benefits from biotechnology until food producers, processors and retailers and government regulators in major countries have adopted a system of traceability and labeling that is cost effective and meets the needs of consumers.
The USDA Advisory Committee on Biotechnology and 21st Century Agriculture released a report in early May titled “Global Traceability and Labeling Requirements for Agricultural Biotechnology-Derived Products: Impacts and Implications for the U.S.” that serves as a good starting point for further consideration of the issues.
The seriousness of these issues should not be underestimated. Some insurance carriers for grain processors have chosen to discontinue coverage for liability associated with unauthorized biotechnology-related presence in non-biotech crops. Labeling requirements have led processing companies to choose to exclude biotech crops as ingredients so a biotech label is not required. Markets that had become increasingly unified over the past 30 years are now becoming fragmented to the disadvantage of producers, processors and consumers.
The report begins by noting that the U.S. government has consistently argued that there is no scientific justification for imposing mandatory labeling requirements on biotech crops based solely on the process by which the products were produced. At the same time, USDA has also worked to provide tools and services related to product testing and process verification to help market participants meet consumer demands. Government regulatory actions need to be based on sound science, but consumers ultimately rule in a market system, and market forces remain the best way to sort out labeling and traceability issues.
Labeling and traceability and related issues like testing, segregation and identity preservation are not new to the food industry. Beginning at the farm, hard red winter wheat is kept separate from soft red winter wheat because they have different uses and values for millers and bakers. Retail food labeling laws have continued to be broadened in recent years in response to various health claims and concerns. Processors of baby foods have developed product tracing systems so the source of raw ingredients and pesticides used in production are fully known. Even ominous phrases like “adventitious presence”, used to refer to the presence of biotech proteins and DNA in what is thought to be non-biotech crops, has also been used to refer to low levels of unintended hybrids in hybrid seed corn and foreign material in wheat.
This learning process would be much less complex were it not for two issues: the unfounded image of “Frankenfoods” spread by anti-biotech groups and the goal of some people for absolute zero biotech crop adventitious presence in non-biotech crops. A small amount of corn in soybeans or soft red winter wheat in hard red winter wheat does not make a significant difference in the value of the products. A goal of absolute zero would not be cost effective. Science says the same thing about a small amount of biotech corn in non-biotech corn. But the fear of “Frankenfoods” has made what the report refers to as an “acceptable zero” unacceptable in the quest for absolute zero.
The search for absolute zero is further complicated by the fact that in some processed products the detectible protein or DNA has been broken down to the point that the biotech product is no different than the non-biotech one. If the end products look exactly the same, the only way to distinguish between the two is to develop elaborate tracing systems so that the products can be process verified. The only countries that do not exempt these processed products from labeling are the EU, Brazil and China.
The report highlights the need to establish international testing standards. The commercial risks for the grain processing industry is extremely high because grain that meets the established standard at point A using test number 1 and again at point B using test number 2 may then fail at point C using test number 3. Has the grain become commingled at some point, or is it the same grain with a different sampling error, or is test number 3 measuring something that tests 1 and 2 did not measure? The current system lacks predictability which increases costs.
All of these uncertainties must be sorted out by governments or the private trade or some combination of the two. Governments have met for several years under Codex and the Cartagena Protocol on Biosafety and to a lesser extent under the International Plant Protection Convention and the WTO without major breakthroughs. Part of the problem is that groups pursuing the “Frankenfood” image and absolute zero adventitious presence do not seek solutions based on sound science or reasonable costs.
That leaves the market as the best hope for initial breakthroughs. As the report points out, participants in the grain markets assume substantial liabilities as they seek to meet the needs of consumers. They have the financial incentives to find real solutions to real problems. The task is made more difficult by the lack of a single test that can detect all biotech events.
Once market participants begin to rally around standards or guidelines, they can then begin to encourage government regulators to move international discussions toward reasonable approaches to labeling, traceability and testing. In many countries the regulatory frameworks are still in the formative and implementation stages and open to reasonable arguments about the best approach to regulations.