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ECVC response to the European Commission’s targeted consultation on new genomic techniques

4 August 2022

As part of its initiative to propose a new regulatory framework for new genomic techniques [1], the European Commission's Directorate-General for Health and Food Safety (DG SANTE) commissioned the consultancy services Technopolis, Ecorys, Arcadia International, as well as Wageningen University to consult a number of stakeholders [2] in order to contribute to the impact assessment of this initiative.

In this context, ECVC was invited by Technopolis to participate in an interview, as well as to take part in a "targeted survey" assessing the impact of several potential regulatory scenarios by means of a multiple choice questionnaire. These scenarios include a single question about maintaining the current legislation. All other questions concern the weakening or disappearance of its requirements for risk assessment, detection, labelling and traceability for products derived from these new genetic modification techniques if they are considered to be 'sustainable' (without sustainability criteria being defined) or similar to products derived from traditional techniques.

ECVC considers that the 'targeted survey' proposed in the form of a multiple-choice questionnaire is a biased form of consultation, which is based on a premise that is favorable to the deregulation of these techniques, and does not allow for opposition to this deregulation to be formulated in each question. Indeed, all the questions in this survey, with the exception of the first few questions, assume that there will be an increase in the use of plants produced using these new techniques. Answering the questionnaire therefore means accepting this assumption, which we reject. For this reason, ECVC has chosen not to take part in this survey, just as we refused for the same reasons to take part in the last public consultation of the European Commission on the same subject. Furthermore, ECVC questions the usefulness of conducting such a consultation process with four subcontractors with targeted stakeholders, while a second public consultation is still ongoing.

Nevertheless, ECVC agreed to take part in the interview requested by Technopolis in order to explain the reasons for our refusal to respond to the consultation, without the constraint of biased multiple-choice questions.

[1] The European Commission uses this term to refer to the techniques of cisgenesis and targeted mutagenesis, which are considered by the current European legislation on GMOs as techniques of genetic modification not exempted from its scope.

[2] The list and selection process of consulted stakeholders has not been made public by the consultancy firm.

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