Addressing the Impact of Biosafety Systems

Towards a Regional Approach to Biotechnology and Biosafety for Southern African Countries (RABSAC) – a background literature review

By Marnus Gouse

December 2005

1. Introduction

Developing countries in general and in particular the Southern African Development Community

(SADC) countries, are at crossroads regarding their decision on whether or not to embrace rapidly

evolving biological technologies and related products such as genetically modified organisms

(GMOs). The pace at which SADC countries are engaging in biotechnology is a cautious and

precautionary one. While a number of countries strive to establish the policy and regulatory

frameworks on biosafety and biotechnology, few have the capacity to fully enforce them. This

emphasises the need for a common regulatory approach and policy position in the SADC region

with acceptable standards that could be approved across countries.

The Food, Agriculture and National Resources Policy Analysis Network (FANRPAN), in

collaboration with national SADC nodes and technical partners and funded by the USAID

through PBS, has endeavoured to document a balanced review of the technical information

needed to inform SADC’s regional biosafety policy choices responsibly. The initiative is

designed to generate, for the SADC countries, new information regarding biosafety regulation

and legislation, necessary market systems and infrastructure, identification and quantification of

possible costs and benefits as well as the economic costs and benefits of attempting to remain a

“GM-free” region. The ultimate aim of this project is to ensure improved food security and

incomes in the agricultural systems in the SADC countries through adoption of appropriate

productivity enhancing technologies. This project will help to ensure that the SADC countries

have a balanced view of the costs and benefits of biotechnology/GMO adoption, for better

decision-making.

This project has been undertaken in three selected SADC countries, i.e. Malawi, Mauritius and

South Africa. The three selected countries have strong national biotechnology institutions and are

at different levels of biosafety regulation and legislation development.

The aim of this paper is not to stand alone as a document but to serve as source document and

literature review to assist in the compilation and compliment the three final project report papers

focussing on the real and possible impacts of transgenic crop policies in the three focal countries.

The three papers will focus on:

• Trade in agricultural products

• Staple food imports, food aid and food aid policies, and

• Possible effects of commercial adoption of transgenic crops based on crops, production

areas and production limiting factors.

This paper will focus on a couple of main issues pertaining to genetically modified crops i.e.

modern biotechnology and the regimes that govern it, the effect the introduction of GMOs have

had on international trade, health effects of GM food and the environmental. A brief overview of

global GM crop adoption and a summary of the economic and farm-level impacts of GM crop

adoption are supplied.

2. Modern biotechnology and the international regimes that govern it

Modern biotechnology

According to the FAO publication “The State of Food and Agriculture” (FAO, 2004),

biotechnology can be broadly defined as any technique that uses living organisms or substances

from these organisms to make or modify a product for a practical purpose. The Convention on

Biological Diversity (CBD) defines biotechnology as: “any technological application that uses

biological systems, living organisms, or derivatives thereof, to make or modify products for

specific use” (Secretariat of the Convention on Biological Diversity, 1992). This definition

includes medical and industrial applications as well as many of the tools and techniques that are

commonplace in agriculture and food production.

The Cartagena Protocol on Biosafety defines “modern biotechnology” more narrowly as the

application of:

(a) In vitro nucleic acid techniques, including recombinant deoxyribonucleic acid (DNA) and

direct injection of nucleic acid into cells or organelles, or

(b) Fusion of cells beyond the taxonomic family, that overcome natural physiological

reproductive or recombination barriers and that are not techniques used in traditional

breeding and selection.

(http://www.biodiv.org/biosafety/faqs2.aspx?area=biotechnology&faq=1)

The FAO Glossary of biotechnology defines biotechnology narrowly as “a range of different

molecular technologies such as gene manipulation and gene transfer, DNA typing and cloning of

plants and animals” (FAO, 2001a seen in FAO, 2004). Recombinant DNA techniques, also

known as genetic engineering or (more familiarly but less accurately) genetic modification, refer

to the modification of an organism’s genetic make-up using transgenesis, in which DNA from

one organism or cell (the transgene) is transferred to another without sexual reproduction.

Genetically modified organisms (GMOs) are modified by the application of transgenesis or

recombinant DNA technology, in which a transgene is incorporated into the host genome or a

gene in the host is modified to change its level of expression. The terms “GMO”, “transgenic

organism” and “genetically engineered organism (GEO)” are often used interchangeably although

they are not technically identical (FAO, 2004). These terms are often used as synonyms.

Modern agricultural biotechnology includes a range of tools that scientists employ to understand

and manipulate the genetic make-up of organisms for use in the production or processing of

agricultural products. Some applications of biotechnology, such as fermentation and brewing,

have been used for millennia. Other applications are newer but also well established. For

example, micro-organisms have been used for decades as living factories for the production of

lifesaving antibiotics including penicillin, from the fungus Penicillium, and streptomycin from the

bacterium Streptomyces. Modern detergents rely on enzymes produced via biotechnology, hard

cheese production largely relies on rennet produced by biotech yeast and human insulin for

diabetics is now produced using biotechnology (FAO, 2004).

Biotechnology is being used to address problems in all areas of agricultural production and

processing. This includes plant breeding to raise and stabilize yields; to improve resistance to

pests, diseases and abiotic stresses such as drought and cold; and to enhance the nutritional

content of foods. Biotechnology is being used to develop low-cost disease-free planting materials

for crops such as cassava, banana and potato and is creating new tools for the diagnosis and

treatment of plant and animal diseases and for the measurement and conservation of genetic

resources. Biotechnology is being used to speed up breeding programmes for plants, livestock

and fish and to extend the range of traits that can be addressed. Animal feeds and feeding

practices are being changed by biotechnology to improve animal nutrition and to reduce

environmental waste. Biotechnology is used in disease diagnostics and for the production of

vaccines against animal diseases. Clearly, biotechnology is more than genetic engineering.

Indeed, some of the least controversial aspects of agricultural biotechnology are potentially the

most powerful and the most beneficial for the poor. Genomics, for example, is revolutionizing

our understanding of the ways genes, cells, organisms and ecosystems function and is opening

new horizons for marker-assisted breeding and genetic resource management. At the same time,

genetic engineering is a very powerful tool whose role should be carefully evaluated. It is

important to understand how biotechnology – particularly genetic engineering – complements and

extends other approaches if sensible decisions are to be made about its use (FAO, 2004)

2.2 Governing modern biotechnology

In a January 2003 brief by the International Food and Policy Research Institute (IFPRI, 2003),

Peter Phillips found that there are predominately nine international bodies that regulate and

govern different aspects of food safety and agricultural biotechnology. Philips divides the

institutions into three types. Five are mainly science-based organisations namely: the

International Plant Protection Convention (IPPC), International Epizootics Organisation (OIE),

Codex Alimentarius (Codex), the Food and Agricultural Organisation (FAO) and the World

Health Organisation (WHO). The World Trade Organisation is a trade-based organisation while

the remaining three organisations have broader objectives such as environmental protection and

other political or social goals: the Organisation of Economic Co-operation and Development

(OECD), the Cartagena BioSafety Protocol (BSP) and some Regional Initiatives. These

organisations endeavour to establish standards for health, safety, and labelling for GM foods,

develop testing procedures to ensure the standards are met, provide rules for allowable policies,

and create systems to manage disputes.

Philips states that despite substantial effort by these organisations (Table 1), there is no common

view on the goal of international regulation. While most bodies agree that safety is the main issue,

few can agree on what that means, whose opinion should hold the most weight (scientists’ or

citizens’), or how to handle nonsafety issues like social, economic or ethical concerns. Philips

(IFPRI, 2003) summarises the role of each organisation and the linkages and cooperation between

them as follows: The FAO and WHO promotes food security and public health and have worked

to develop a consensus about the implications of biotechnology for their areas of interest. The

IPPC and OIE on the other hand, are multilateral treaties that seek to protect plants and animals

from the spread of pathogens through international trade, thereby providing much of the scientific

consensus that underlies domestic food safety systems. Both institutions have their own

nonbinding dispute avoidance and settlement systems, but their most important role in

international trade is through the WTO Sanitary and Phytosanitary Agreement (SPS), which uses

the IPPC and OIE standards as the basis for evaluating SPS disputes. National measures based on

international standards from either of these institutions will generally not be open to challenge

under the WTO dispute resolution process. Furthermore, both the IPPC and OIE nominate experts

for WTO SPS dispute panels and provide technical background information to the panels based

on their standards. As such, they can have far-reaching economic and political consequences on

food trade.

Table 1: International regulatory institutions

Institution Members Coverage Food and Agricultural Organisation of the United Nations (FAO)

184 Food security programmes

World Health Organisation (WHO) 191 Health science and policy

International Plant Protection Convention (IPPC) 107 Pests and pathogens (crops)

International Epizootics Organisation (OIE) 155 Pests and pathogens (animals)

Codex Alimentarius (Codex) 165 Food standards and labels World Trade Organisation (WTO) 139 Trade rules for all goods; Dispute

Settlement Mechanism Organisation for Economic Cooperation and Development (OECD)

29 Harmonise standards and policies

Regional Initiatives Various Harmonise science and/or progress

Cartagena BioSafety Protocol (BSP) Ratified by 130 countries Transboundary movements of

living modified organisms Adapted from (IFPRI, 2003)

The Codex, under the joint FAO/WHO Food Standards Program, provides a similar service

related to processed foods. The Codex develops international food standards, which identify the

product and its essential composition and quality factors, identify additives and potential

contaminants, set hygiene requirements, provide labeling requirements, and establish the

scientific procedures used to sample and analyze the product. Each standard normally takes six or

more years to develop. Determination of the safety of the food product is based on scientific risk

analysis and toxicological studies. Once a Codex standard is adopted, member countries are

encouraged to incorporate it into any relevant domestic rules and legislation, but they may

unilaterally impose more stringent food safety regulations for consumer protection, provided the

different standards are scientifically justifiable. Codex plays an important role in agri-food trade

because its standards, guidelines, and recommendations, like the IPPC and OIE provisions, are

acknowledged in the SPS and Technical Barriers to Trade Agreements during consideration of

trade disputes. There has been an eight-year process to develop a Codex standard for products of

biotechnology, but consensus eludes the negotiators. The OECD, composed of 29 industrial

democracies, has actively assisted in harmonizing international regulatory requirements,

standards, and policies related to biotechnology since 1985. The OECD has through a number of

projects attempted to make regulatory processes more transparent and efficient, to facilitate trade

in the products derived through biotechnology, and to provide information exchange and dialogue

with non-OECD countries (IFPRI, 2003).

Various bilateral or multilateral regional initiatives have played an increasingly important role in

regulating trade in goods and services. These initiatives help create the consensus necessary to

establish international rules, given that many food safety concerns in trade are bilateral and the

knowledge base to develop standards resides in a few countries only. Regional agreements,

memoranda of understanding, mutual recognition agreements, formal dialogues, and joint

research projects are mechanisms that can be used to decrease bilateral regulatory barriers to GM

food trade (IFPRI, 2003).

The WTO has become the “go-to” institution for examining and resolving trade disruptions

related to GM foods. Although there was a nonbinding agreement on technical barriers to trade in

the Tokyo Round of the General Agreement on Tariffs and Trade, the 1995 SPS agreement for

the first time extended the newly formalised and binding dispute settlement system to cover trade

concerns related to sanitary and phytosanitary rules and technical barriers to trade. The WTO

agreement permits national standards or regulations for the classification, grading or marketing of

commodities in international trade (Article XI) and the adoption or enforcement of measures

necessary to protect human, animal, or plant life or health (Article XX(b)), but also sets some

rules on when and how they may be used. Specifically, the SPS Agreement requires that

measures (1) do not discriminate between member states; (2) conform where possible to

international standards developed by Codex, OIE, or IPPC; (3) be based on scientific principles

and the completion of a risk assessment study; and (4) do not constitute a disguised restriction on

international trade. Although the WTO is the main locus of dispute resolution for many countries,

it has some limitations. Principally, as currently interpreted, the SPS Agreement allows

regulations based on science but does not permit regulations that restrict trade based on

nonscience concerns such as consumer preference, animal welfare, or nonmeasurable

environmental risks (IFPRI, 2003).

The Cartagena Protocol on Biosafety was adopted by the Convention on biological diversity in

September 2000 and came into force in September 2003. The objective of the Protocol is to

protect biological diversity from the potential risks posed by safe transfer, handling and use of

LMOs resulting from modern biotechnology. Risks to human health are also considered. The

Protocol is applicable to all LMOs, except pharmaceuticals for humans that are addressed by

other international agreements or organizations. The Protocol sets out an Advance Informed

Agreement (AIA) procedure for LMOs intended for intentional introduction into the environment

that may have adverse effects on the conservation and sustainable use of biodiversity (FAO,

2004). The Protocol also provides for labeling of GM elements in commodity shipments destined

for the food chain. Some supporters of GMOs recognize that the multilateral instrument could

help to build confidence in GM technology under the umbrella of an international regulatory

framework. However, others believe that the Protocol may lead to trade barriers, due to

potentially wide interpretation of certain provisions and additional costs associated with

implementation. It has even been suggested that ‘the Cartagena Protocol represents the biggest

threat to international agricultural trade, after subsidies’ (Jooste et al., 2004), by potentially

introducing additional requirements for cross-border trade in agricultural products, increasing

bureaucracy, raising transactions costs and providing a means for countries trying to protect local

markets to limit imports. At this stage, however, there does not appear to be sufficient evidence

to support or refute this (Wolson, 2005).

According to Philips the only conclusion one can derive from his survey of international

institutions is that no one institution, and perhaps not even the entire array of institutions, is likely

to yield an early resolution to concerns about diverging national policies and regulations

concerning GM foods (IFPRI, 2003).

According to a June 2005 International Food and Agriculture Trade Policy Council (IPC) Trade

Negotiations Brief (IPC, 2004b), the developed world, developing countries will accept and

incorporate GM technology in their agricultural policies at different times and in different ways,

based on assessment of their own agricultural, environmental and trade policies as well as their

social and cultural views of science, technology and innovation. The controversy over GM crops

and products, combined with a highly regulated environment in many developed countries has led

many developing countries to adopt a very cautious approach to products of GM technology.

According to the IPC the most common constraint remains the limited institutional capacity to

evaluate, regulate and manage these innovations. Most developing countries want to ensure that

these products are tested to the same levels of safety as in the developed world before they are put

in the hands of their farmers. This applaudable objective has been and is however hampered by

the reality that many countries, particularly least developed countries, do not have the resources –

human, financial and sometimes institutional – to develop a science-based regulatory

infrastructure similar to the industrialized economies and the large emerging economies. In the

absence of local scientific infrastructure, policy makers in developing countries often feel they

cannot proceed with acceptance of innovative GM technology. The fact that some products of

GM technology are not approved in major markets provides an additional rationale to postpone

decisions (IPC, 2004b).

The lack of domestic regulatory policy for testing, release and commercialization of GM products

makes it difficult to field test new varieties designed for subsistence farmers or non-commercial

crops. Without proper testing and evaluation under the specific climactic and growing conditions

in developing countries themselves, it will be impossible for developing countries to collect

sufficient information to evaluate GM technologies. While many people cite the tangle of

intellectual property rights as the single most important impediment to bringing appropriate GM

technology to developing countries, researchers more often cite the lack of internal regulations

and regulatory capacity. The absence of an international policy framework on the role of the life

sciences in achieving the global objectives of poverty reduction, health care, and environmental

conservation is a serious hindrance in the quest of many countries to set up a rational regulatory

framework for GM technology. The starting point for a regulatory framework for GM technology

in developing countries is the development of a GM technology policy, with a clear vision of the

place of innovation in the future of agricultural and environmental policies. Countries like

Argentina, Brazil, China and India have embraced GM technology in their long-term agricultural

strategies, and built a regulatory framework that considers both agricultural and environmental

policy objectives (IPC, 2004b).

3. Implications of agricultural biotechnology for regional and international trade

It is said that the current diversity of regulatory regimes constrains the diffusion of agricultural

biotechnology to farmers in the developing world as it is difficult for a developing country farmer

to satisfy the multiplicity of labelling and regulatory schemes in developed country markets (IPC,

2004b). While developed countries have established their national frameworks to deal with agro-

biotechnology and biosafety focusing predominantly on domestic priorities and strategies, most

developing countries are doing so under less flexible circumstances. Instead of enjoying the

freedom to assess risks and benefits that agricultural biotechnology may bring about and act

accordingly, developing countries increasingly seem to be expected to set up their national

regulatory schemes based on the requests and expectations of their main trade partners (UN,

2005). According to the IPC report (2004b), some countries regulate based on detectability of

genetically-modified protein or genetic material, while others regulate simply on the use of GM

technology. Some countries require labelling only on intermediate products; others require it on

consumer labels. Some countries require mandatory labels; others allow voluntary labelling.

Some countries require positive labels (contains or is derived from genetic material) while others

require negative labels (does not contain genetic material). Trade becomes difficult when

regulatory regimes vary so widely, particularly for developing countries that often do not have the

resources to comply with complex regimes and developing countries are worried about current

and potential export markets.

The IPC (2004b) suggest that the introduction of GM products coincided with a shift in power in

the agri-food system from farmers and first level processors to retailers and consumers.

Consumers have gained control of the food sector through purchase power and willingness or

lack thereof to fund agricultural support through tax money. As a result, the issue of regulatory,

commercial and consumer acceptance of GM products has become crucial for producers in

developed and developing countries alike. Even though a number of genetically modified crops

and products have been approved by the European Commission International trade does not

happen between countries. It is the aggregate of transactions between economic operators in the

food chain – consumers, producers, food companies, supermarket chains, and others. Though it is

unclear how broad consumer concerns about GM technology are, the depth of those concerns in

some markets has made food companies wary of embracing the technology. In the late nineties,

food companies were confronted with massive campaigns against their products and the European

Union announced new regulations on labelling and traceability without clarifying the precise

form that this new regulation would take. As a result, many processors, branded food companies,

and retailers have sought to minimize their risk by establishing purchasing policies, which in

practice have more impact on the decision-making of producers than the formal regulatory

requirements. From the perspective of these companies, this creates a “safety zone” around their

supply chain, and it reduces the cost of segregating product streams. It also reduces the pressure

to pay premium prices for non-GM supplies of raw materials. The requirements for channelling

GM products and the levels of identity preservation imposed by corporate purchasing policies

were put in place long before the major importing countries established regulatory standards –

and in many cases are much stricter than official regulations. For producers in developing

countries, it is more difficult to keep their supply contracts with distributors in the developed

world intact than to comply with developed country regulatory requirements, per se (IPC, 2004b).

According to IFPRI (2003), US exports of maize to the EU have fallen by 70% in the recent

couple of years preceding 2003. US soya-bean exports have dropped by 48% and Canadian

canola exports to the EU have dropped 96%. The EU have in the meanwhile sourced GM-free

soya and canola from Brazil and Australia respectively where at the time the GM varieties were

not approved just yet. According to IFPRI these changed trade flows have not had significant

ramifications with trade simply being reallocated between adopting and non-adopting countries,

but over time such policies have the potential to seriously distort trade flows.

Accordingly the United States, on May the 13th 2003 informed the European Commission that it

would seek WTO consultations to end an alleged EC moratorium on the approval for

commercialisation of agricultural biotechnology products. The US claimed that the alleged

moratorium violated provisions of the WTO agricultural, technical barriers to trade (TBT) and

sanitary / phytosanitary (SPS) agreements, as well as the General Agreement on Trade and Tariffs

(GATT). To its complaint the US added a list of biotech product applications for

commercialisation that had been submitted to EC member states from 1996 through 2001, all of

which either were pending approval or which had been withdrawn. The majority of the plaintiffs’

claims of EC violations of WTO rules concern the SPS agreement, however, the panel will almost

certainly rule on the violations charged under other agreements as well. The US further justified

its complaint by arguing that biotech products were necessary to feed developing countries. The

EC characterised the filing of the complaint as “legally unwarranted, economically unfounded

and politically unhelpful [with regard to EC efforts to develop a regulatory system for GMOs].”

Two weeks later, President George Bush brought the GM crop trade dispute to wider public

attention by charging that the alleged moratorium on GMO approvals was hindering efforts to

reduce hunger in Africa (IATP, 2005).

In August 2003, because the EC consultations with the U.S., Canada and Argentina did not result

in the ending of the alleged moratorium, the WTO Dispute Settlement Body (DSB) announced

the formation of a single panel to rule on the case. In March 2004, the three panellists were

named and in April, the first submissions of evidence began. In addition to the three plaintiff

WTO members, Australia, Brazil, Chile, Colombia, India, Mexico, New Zealand and Peru

requested consultations with the European Communities and reserved their rights as third parties

to benefit from the ruling (IATP, 2005).

While the EU restarted approvals of GM products in 2004 after a break if close to six years, the

end of the Union’s de facto biotech ban did not come with the blessing of all its 25 member

countries, who repeatedly fail to agree on genetically modified crops. Since 1998, the EU

member states have not found enough of a voting majority to agree on any new GMO approvals.

Three more GM maize varieties were approved by the European Commission on the 13th of

January 2006, bringing the total number of GM products approved since the end of the alleged

moratorium and the new European traceability and labelling regulations entered into force in

April 2004 to nine. It is said that whether or not the United States wins the EC-Biotech Products

case, it is likely that the U.S. will file another case against the Directive on labeling and

traceability of GMOs. As one industry official put it, “removal of the moratorium is ‘utterly

useless’ if it is replaced by labeling and traceability rules.” (ICTSD, 2006).

The WTO dispute panel announced on 3 October 2005 that it will not be able to meet the 10

October deadline that it had announced in July. Ruling was delayed until January or February

2006. Commentators speculated that the ruling was delayed out of fear that its findings could

have adverse effect on negotiations at the WTO Ministerial Conference in Hong Kong in

December 2005. The ruling can be expected to be treated as a precedent by future WTO panels

ruling on food safety, public health and environmental health measures applied to international

traded goods and services. Developing countries, many of which have yet to establish regulatory

regimes for GMO crops, will be particularly affected by the ruling (IATP, 2005).

However, according to the IPC (2004b), resolution of the current regulatory complexities will not

restore calm in the trading environment of agricultural products by itself. Developing countries

may decide it is simply easier to avoid the issue altogether by avoiding biotech products. In

addition to the regulatory and commercial barriers facing GM products (especially with the new

traceability and labelling regulations of the EU), the overall global agricultural trade environment

affects the economics of adopting biotechnology in developing countries. Trade-distorting

subsidies that depress world commodity prices, coupled with traditional market access barriers

such as tariffs and quotas, will make it economically unattractive to adopt new technologies in

some crops. Farmers do not have an incentive to make investments in technologies that will

improve their productivity if they know that they will continue to have to compete with

subsidised imports from developing countries and that they have no hope of being able to export

their products to wealthy markets. These considerations are certainly more important for farmers

producing cash crops or exporting to world markets, but even subsistence farmers can face

competition from subsidised crops imported from rich countries.

4. Possible impacts of agricultural biotechnology on health and the environmental

Health

Science does not take a broad position that GM crops are safe or unsafe; each GM crop presents

potential risks and benefits that must be evaluated on a case-by-case basis. When early farmers

began to change the appearance of crops by conventional breeding 10,000 years ago, they also

directed changes in crop DNA. In some cases, the changes have been so great that only a well-

trained botanist can identify the wild ancestor of a crop. The nature of these changes has become

clearer as we have been able to sequence the genetic code of domesticated plants and their wild

relatives. We know that practically all plants we eat are extensively genetically modified

compared with their wild ancestors. Often these modifications have been achieved through

human selection of traits introduced through interspecific hybridization or created by random

mutation using radiation or mutagenic chemicals (CAST, 2005).

According to a report by the Council for Agricultural Science and Technology (CAST) the

potential hazards associated with transgenic crop technology have been studied by the U.S.

National Academy of Sciences (NAS). The NAS repeatedly has concluded that biotechnology is

no more likely to produce unintended effects than conventional technology—indeed the greater

precision and more defined nature of the changes introduced may actually be safer. European

Union scientists addressed this same issue and concluded that conventional plant breeding

produces more unintended changes than are introduced in the construction of a transgenic plant

(Cellini et al. 2004). These studies found that there are no new risks associated with the transfer

of genes across species barriers. They concluded that transgenic crops on the market today are as

safe to eat as their conventional counterparts, and likely more so, given the greater regulatory

scrutiny to which they are exposed. After 10 years of safe use, it is fair to conclude that the

inherent safety of the technology and the premarket case-by-case safety assessments conducted

by regulatory agencies around the world have ensured that foods from transgenic crops are as safe

to eat as any food (CAST, 2005).

The International Council for Science (ISCU) in 2003 also found, after analysis of findings of

approximately 50 science-based reviews1, published in years 2000-2003, on modern genetics and

its applications in food, agriculture and the environment, that foods made from genetically

modified crops are safe to eat. Food safety assessments by national regulatory agencies in

numerous countries have deemed GM foods as safe to eat as their non-GM or conventional

counterparts and suitable for human and animal consumption. The methods used to test the safety

of these foods have also been deemed appropriate. This view is shared by a number of

intergovernmental agencies including the FAO / WTO Codex Alimentarius Commission of food

safety, the European Commission (EC) and the Organisation for Economic Cooperation and

Development (ISCU, 2003).

To date, world-wide, there have been no verifiable toxic or nutritionally harmful effects resulting

from the cultivation and consumption of foods derived from genetically modified crops (GM

Science Review Panel, 2004). Millions of people have consumed foods derived from GM plants –

mainly maize, soybean and oilseed rape – without any observed adverse effects (ICSU, 2003).

The main food safety concerns associated with transgenic products and foods derived from them

relate to the possibility of increased allergens, toxins or other harmful compounds; horizontal

gene transfer particularly of antibiotic-resistant genes; and other unintended effects (FAO, 2004).

Many of these concerns also apply to crop varieties developed using conventional breeding

methods and grown under traditional farming practices (ICSU, 2003). Exhaustive scientific tests

by private product developing companies, regulatory bodies and independent laboratories

endeavour to ensure that all types of food that reach the consumer market, do not contain

abnormal allergens or toxins.

1 This literature study will not go into the details of the different studies and test procedures. Some

references to these studies will be supplied in the reference list.

4.2 Environmental impacts

According to the FAO (2004), agriculture of any type – subsistence, organic or intensive – affects

the environment, so it is natural to expect that the use of new genetic techniques in agriculture

will also affect the environment. The ICSU, the GM Science Review Panel and the Nuffield

Council on Bioethics (seen in FAO report), among others, agree that the environmental impact of

genetically transformed crops may be either positive or negative depending on how and where

they are used. Genetic engineering may accelerate the damaging effects of agriculture or

contribute to more sustainable agricultural practices and the conservation of natural resources,

including biodiversity (FAO, 2004).

Releasing transgenic crops for commercial production may have direct effects including: gene

transfer to wild relatives or conventional crops, weediness, trait effects on non-target species and

other unintended effects. These risks are similar to that of conventionally bred crops

(ICSU,2003). Although scientists differ in their views on these risks, they agree that

environmental impacts need to be assessed on a case-by-case basis and recommend post-release

ecological monitoring to detect any unexpected events (ICSU, Nuffield Council, GM Science

Review Panel). Transgenic crops may also have positive or negative indirect environmental

effects through changes in agricultural practices such as pesticide and herbicide use and cropping

patterns (FAO, 2004).

The FAO’s State of Food and Agriculture paper of 2004 summarises the main environmental

concerns and effects as it is reported in applicable accredited literature:

Gene flow:

Scientists are in agreement that gene flow from GM crops is possible through pollen from open-

pollinated varieties crossing with local crops or wild relatives. Gene flow between land races and

conventionally bred crops has happened for millennia and it is thus reasonable to expect that it

could also happen with transgenic crops. Crops vary in their tendency to outcross, and the ability

of a crop to outcross depends on the presence of sexually compatible wild relatives or crops

(ICSU, 2003 & GM Science Review Panel, 2003). Scientists do not fully agree whether or not

gene flow between transgenic crops and wild relatives matters, in and of itself (ICSU, 2003 &

GM Science Review Panel, 2003). If a resulting transgenic/wild hybrid had some competitive

advantage over the wild population it could flourish in the environment and potentially disrupt the

ecosystem. According to the GM Science Review Panel, hybridization between transgenic crops

and wild relatives seems “overwhelmingly likely to transfer genes that are advantageous in

agricultural environments, but will not prosper in the wild. Furthermore, no hybrid between any

crop and any wild relative has ever become invasive in the wild in the UK” (GM Science Review

Panel, 2003). The ICSU (2003) states that whether the otherwise benign flow of transgenes into

land races or conventional varieties would itself constitute an environmental problem is a matter

of debate, because conventional crops have long interacted with land races in this way.

Weediness refers to the situation in which a cultivated plant or its hybrid becomes established as a

weed in other fields or as an invasive species in other habitats. Scientists agree that there is only a

very low risk of domesticated crops becoming weeds themselves because the traits that make

them desirable as crops often make them less fit to survive and reproduce in the wild. Weeds that

hybridize with herbicide-resistant crops have the potential to acquire the herbicide-tolerant trait,

although this would only provide an advantage in the presence of the herbicide. The ICSU and

the GM Science Review Panel concur that research is needed to improve the assessment of the

environmental consequences of gene flow, particularly in the long run, and to understand better

the gene flow between the major food crops and land races in centres of diversity (FAO, 2004).

Trait effects on non-target insects:

Scientists agree that some transgenic traits – such as the pesticidal toxins expressed by Bt genes –

may also affect non-target species (besides the crop pests they are intended to control) but they

disagree about how likely this is to happen (ICSU, 2003 & GM Science Review Panel, 2003).

The monarch butterfly controversy demonstrated that it is difficult to extrapolate from laboratory

studies to field conditions. The GM Science Review Panel (2003) reports that field studies have

indicated some differences in soil microbial community structure between Bt and non-Bt crops,

but these are within the normal range of variation found between cultivars of the same crop and

do not provide convincing evidence that Bt crops could be damaging to soil health in the long

term. Although no significant adverse effects on non-target wildlife or soil health have so far been

observed in the field, scientists disagree regarding how much evidence is needed to demonstrate

that growing Bt crops is sustainable in the long term. Scientists agree that the possible impacts on

non-target species should be monitored and compared with the effects of other current

agricultural practices such as chemical pesticide use. They acknowledge that they need to develop

better methods for field ecological studies, including better baseline data with which to compare

new crops (FAO, 2004).

Indirect environmental effects

The ICSU and GM Science Review Panel agree that transgenic crops may have indirect

environmental effects as a result of changing agricultural or environmental practices associated

with the new varieties. These indirect effects may be beneficial or harmful depending on the

nature of the changes involved. The use of conventional agricultural pesticides and herbicides has

damaged habitats for farmland birds, wild plants and insects and has seriously reduced their

numbers. Transgenic crops are changing chemical, land-use and other farming practices, but

scientists do not fully agree whether the net effect of these changes will be positive or negative

for the environment and acknowledge that more comparative analysis of new technologies and

current farming practices is needed (FAO, 2004).

Pesticide use

The scientific consensus is that the use of transgenic insect resistant crops have reduced the

volume and frequency of chemical insecticide use on maize, soybean and especially cotton in all

the adopting countries (FAO, 2004) The environmental benefits include less contamination of

water supplies and less damage to non-target insects (ICSU, 2003). Reduced pesticide use

suggests that Bt crops would be generally beneficial to in-crop biodiversity in comparison with

conventional crops that receive regular, broad-spectrum pesticide applications, although these

benefits would be reduced if supplemental insecticide applications were required (GM Science

Review Panel, 2003). As a result of less chemical pesticide spraying on cotton, health benefits

for farm workers have been documented in China (Pray et al., 2002) and small-scale farmers in

South Africa (Bennett et al (2003).

Herbicide use

The FAO (2004) reports that, Traxler (2004) found that there has been a marked shift away from

more toxic herbicides to less toxic forms, but total herbicide use has increased. Scientists agree

that HT crops are encouraging the adoption of low-till crops with resulting benefits for soil

conservation (ICSU, 2003). There may be potential benefits for biodiversity if changes in

herbicide use allow weeds to emerge and remain longer in farmers’ fields, thereby providing

habitats for farmland birds and other species, although these benefits are speculative and have not

been conclusively supported by field trials to date (GM Science Review Panel, 2003). There is

concern, however, that greater use of herbicides – even less toxic herbicides – will further erode

habitats for farmland birds and other species (ICSU, 2003). The Royal Society has published the

results of extensive farm-scale evaluations of the impacts of transgenic HT maize, spring oilseed

rape (canola) and sugar beet on biodiversity in the United Kingdom. These studies found that the

main effect of these crops compared with conventional cropping practices was on weed

vegetation, with consequent effects on the herbivores, pollinators and other populations that feed

on it. These groups were negatively affected in the case of transgenic HT sugar beet, positively

affected in the case of maize and showed no effect in spring oilseed rape. They conclude that

commercialization of these crops would have a range of impacts on farmland biodiversity,

depending on the relative efficacy of transgenic and conventional herbicide regimes and the

degree of buffering provided by surrounding fields (Royal Society, 2003). Scientists acknowledge

that there is insufficient evidence to predict what the long-term impacts of transgenic HT crops

will be on weed populations and associated in-crop biodiversity (FAO, 2004).

Pest and weed resistance

According to the FAO (2004) there is agreement amongst scientist on the fact that extensive long-

term use of Bt crops and glyphosate and gluphosinate (the herbicides associated with HT crops)

can promote the development of resistant insect pests and weeds. Similar breakdowns have

routinely occurred with conventional crops and pesticides and, although the protection conferred

by Bt genes appears to be particularly robust, there is no reason to assume that resistant pests will

not develop (GM Science Review Panel, 2003). Worldwide, over 120 species of weeds have

developed resistance to the dominant herbicides used with HT crops, although the resistance is

not only associated with transgenic varieties (ICSU, 2003 & GM Science Review Panel, 2003).

Because the development of resistant pests and weeds can be expected if Bt and glyphosate and

gluphosinate are overused, scientists advise that a resistance management strategy be used when

transgenic crops are planted (ICSU, 2003). Scientists disagree about how effectively resistance

management strategies can be employed, particularly in developing countries and the extent and

possible severity of impacts of resistant pests or weeds on the environment are subject to debate

(FAO, 2004).

5. Adoption and economic and on-farm effects of agricultural biotechnology

Global status of GM crops

According to the recently released International Service for the Acquisition of Agri-Biotech

Applications report by Clive James (ISAAA, 2005), 2005 marked the tenth anniversary of the

commercialisation of GM crops after first introduction in 1996. It is estimated that about 90

million hectares of approved GM crops were planted in 2005; 9 million hectares more than the 81

million of 2004. GM crops were grown in 21 countries, 3 up from the 17 in 2004. Of the four new

countries, three were European Union countries namely Portugal, France and the Czech Republic.

France and Portugal resumed Bt maize planting after a gap of 4 and five years respectively and

the Czech Republic planted Bt maize for the first time in 2005. Five EU countries are now

producing Bt maize on a commercial level i.e. Spain, Germany, Portugal, France and the Czech

Republic.

Transgenic soya-beans continued to be the most planted GM crops covering 54.4 million hectares

(60% of the global biotech area), followed by maize covering 21.2 million hectares (24%), cotton

covering 9.8 million hectares (11%) and canola with 4.6 million hectares at 5 % of global GM

crop area. Genetically modified rice, squash, potato, tomato and papaya still cover only small

areas.

Economic and on-farm effects of GM crop adoption

During the first decade of GM crop adoption, herbicide tolerance has been the dominant trait with

insect resistance in the second place. It has been proven by a number of studies across the globe

that the use of the herbicide tolerant technology increases weed control efficiency, decreases

fossil fuel use, decreases machine hours and increases profitability. Due to these benefits Brazil

has, for example, increased their herbicide tolerant soya-bean area by 5 million hectares in 2005

to 9.4 million, from 4.4 in 2004. Enough proof that farmers are benefiting.

Weeds are a constant obstacle in crops production and it can be generally excepted that a farmer

who has weed problems can benefit from herbicide tolerant technology. Pest pressure is however

a horse of a different colour. Pest pressure is not constant over seasons and the profitability of

insect resistant technology depends on the pest pressure in the specific season. If the particular

pests are present but not in sufficient numbers to significantly effect yield, or if the pests affect

yield but can be inexpensively controlled by other means, then the producer of the pest resistant

crop may not experience a net benefit. If the pests are prevalent to an economically damaging

extent in the area, however, then this complete control can result in significant yield increases

(Marra, Pardey & Alston, 2002).

Insect resistant seed adoption influences the on-farm profitability in mainly three ways:

- Increase in yield due to better pest management

- Decrease in input cost through savings on insecticide chemicals and application costs

- Increase in input cost through a higher seed price and an additional technology fee.

Table 2 summarises the findings of a number of more recent studies focussing on different GM

crops produced in different countries.

Table 2: Summary of GM crop country study findings

Crop Country Yield effect Cost of technology ($/ha) Estimated cost savings (including fuel, mechanisation and pesticides) excluding cost of technology ($/ha) and Sources

US None $14.82 1996-2002 $17.3 in 2003

$25.2 1996-97 (Marra et al., 2002), $33.9 1998-2000 (Gianessi & Carpenter, 1999), $73.4 2003 (Carpenter & Gianessi, 2001), $78.5 2004 (Sankula & Blumenthal, 2004)

Argentina None $3-4 in 2002 $24-30; (Qaim & Traxler, 2002) Brazil None $15 in 2004 $88 in 2004 Paraguay & Uruguay

None Same as Argentina No country-specific analysis available

Canada None $26.5 in 1997-02, $40 in 2003, $37.3 2004

$39-74 1997-2004 (George Morris Center, 2004)

South Africa None $26 in 2005 $35 in 2005 (Monsanto S. Africa, 2005)

Herbicide tolerant soya-beans

Romania +31% increase and 2% price premium for cleaner delivered harvest

$160 1999 & 2000, $148 2001, $135 2002, $130 2003 inclusive of 4 litres of Roundup

$140-239 1999-2003 (Brookes, 2003)

US None $14.8 $39.9 (Carpenter & Gianessi, 2001; Sankula & Blumenthal, 2004)

Canada None $22 $40.5 (Monsanto, Canada, 2005)

Herbicide tolerant maize

South Africa None $13 $18 (Monsanto S.A, 2005) US None $12.85 1996-2000,

$21.32 in 2001 $34.12 1996-2000, $66.59 in 2001 (Carpenter & Gianessi, 2001; Sankula & Blumenthal, 2004)

Australia None $38 2000 $46 2000 (Doyle et al., 2002; Monsanto Australia, 2005)

Herbicide tolerant cotton

South Africa None $21 in 2001 $25 2001 (Monsanto S. Africa, personal communication, 2005)

US +6% $29.5 1999-2001, $33 2002 for glyphosate tolerant & $17.3 all years for glufosinate tolerant

$60.75 1999-2001, $67 in 2002 glyphosate tolerant, and $44.89 glufosinate tolerant (Carpenter & Gianessi, 2001; Sankula & Blumenthal, 2004)

Herbicide tolerant canola

Canada +10.7 $36.5 $32.4 (Canola Council, 2001)

US +5% $25 1996 & 1997,

$20 1998 & 1999, $22 in 2000

$15.5 all years (James, 2002; Carpenter & Gianessi, 2001; Sankula & Blumenthal, 2004; Marra et al., 2002)

Canada +5% As US No specific Canadian studies, impact qualitatively confirmed by Monsanto Canada (2005)

Argentina +9% As US Nil all years; no specific Argentine studies identified but values confirmed by Trigo (2005); yield impact based on James (2003)

Philippines +25% all years $51 2003 & 2004a $14.5 2003 & 2004 (James, various) Spain +6.3% all years €30 1998 & 1999,

€28 2000, €18.5 2001

€42 (Brookes, 2002)

Insect resistant maize

South Africa Commercial farmers Subsistence farmer

+10.6-11% 1999 & 2000 +32% 2001 +16% 2002

$8-25 depending on seed use per hectare $10 2002

$7-21 1999 & 2000 (Gouse et al, 2005) Small insecticide saving (Gouse et al, 2006)

US 9% 1996-2002, 11% 2003 & 2004

$58.27 1996-2002, $72.84 2003 & 2004

$63.26 1996-2002, $74.1 2003 & 2004 (Carpenter & Gianessi, 2001; Sankula & Blumenthal, 2004; Marra et al., 2002; Mullins & Hudson, 2004)

China +8% 1997-1999, 10% 2000

$42 $261 2000, $438 2001 (Pray et al., 2002)

Australia None $187 1996 & 1997, $118 1998, $105 1999-2002, $191 2003 & 2004

$115 1996, $120 1997, $143 1998, $131 1999, $204 2000-2002, $265 2003 & 2004 (Doyle, 2005; Fitt, 2003; James, 2002)

Argentina +30% $86 $17.47 (Qaim & De Janvry, 2002, 2005) South Africa 24% $63 $21 (Gouse et al, 2003; Ismael et al., 2002; James,

2002) Mexico 3%-37% 1996-2004 $49 1996 and 1999,

$65 1997, $56 1998 $89 1996 & 1999 onwards, $121 1997 & $94 1998 (Monsanto Mexico, 2005; Traxler et al., 2001)

Insect resistant cotton

India 45% 2002, 63% 2003, 54% 2004

$60 2002, $57 2003, $57.3 2004

$46 2002, $40 2003 & $43 2004 (Bennett et al., 2004)

US: GM IR corn rootworm maize

3% 2003 & 2004 $42 both years $32 both years (Sankula & Blumenthal, 2004) Others

US: GM virus resistant papaya

Between 16% and 50% 1999-2004

None 1999-2003, $119 2004

None (Sankula & Blumenthal, 2004)

a Converted to US dollars at prevailing exchange rate.

Source: Table adapted from Brookes & Barfoot, 2005

It is clear from the findings summarised in Table 2 that large commercial farmers as well as

small-scale or subsistence farmers can benefit from transgenic crops. GM crops should however

not be seen as a solve all silver bullet or panacea. GM crops are just another tool in the box of the

farmer to decrease production risk and increase production efficiency in order to produce more

with less inputs and environmental stress.

6. References

Bennett, R., Buthelezi, T.J., Ismael, Y., & Morse, S. (2003). Bt cotton, pesticides labour and health: A case study of smallholder farmers in the Makhathini Flats, Republic of South Africa. Outlook on Agriculture, 32(2), 123-128.). Bennett, R.M., Ismael, Y., Kambhampati, U., & Morse, S. (2004). Economic impact of genetically modified cotton in India. AgBioForum, 7(3), 96-100. Available on the World Wide Web at www.agbioforum.org. Brimner, T.A., Gallivan, G.J., & Stephenson, G.R. (2004). Influence of herbicide-resistant canola on the environmental impact of weed management. Pest Management Science, 61(1), 47-52. Brookes G. (2002). The farm level impact of using Bt maize in Spain. Frampton, UK: PG Economics Limited. Available on the World Wide Web at www.pgeconomics.co.uk/pdf/bt_maize_in_spain.pdf. Brookes G. (2003). The farm level impact of using Roundup Ready soybeans in Romania. Frampton, UK: PG Economics Limited. Available on the World Wide Web at www.pgeconomics.co.uk/pdf/GM_soybeans_Romania.pdf. Brookes Graham & Barfoot Peter (2005). GM Crops: The Global Economic and Environmental Impact – The First Nine Years 1996-2004. AgBioForum, 8(2&3): 187-196. Brookes, Craddock & Kniel (2005). The EU non-GM market: labelling requirements, market dynamics and cost implications for the EU feed and food supply chains. Prepared for Agricultural Biotechnology in Europe. Available on the World Wide Web at www.pgeconomics.co.uk/pdf/Global_GM_Market.pdf Canola Council of Canada. (2001). An agronomic & economicassessment of transgenic canola. Winnipeg: Author. Available on the World Wide Web at www.canola-council.org. Carpenter, J., & Gianessi, L. (2001). Agricultural biotechnology: Updated benefit estimates. Washington, DC: National Center for Food and Agriculture Policy. Available on the World Wide Web at www.ncfap.org/reports/biotech/updatedbenefits.pdf. CAST (2005). Crop Biotechnology and the Future of Food: A Scientific Assessment, Council for Agricultural Science and Technology, CAST Commentary, October Doyle, B., et al. (2003). The performance of roundup ready cotton 2001-2002 in the Australian cotton sector. Armidale, Australia: University of New England. Doyle B. (2005). The performance of ingard and bollgard II cotton in Australia during the 2002/2003 and 2003/2004 seasons. Armidale, Australia: University of New England. Fabrizzi, K.P., Morónc, A., & García, F.O. (2003). Soil carbon and nitrogen organic fractions in degraded vs non-degraded mollisols in Argentina. Soil Science Society of America Journal, 67, 1831-41.

FAO (2004). State of Food and Agriculture, Agricultural Biotechnology Meeting the needs of the poor? Food and Agriculture Organisation of the United Nations, Vialle delle Terme di Caracalla Rome, Italy Fitt, G. (2003). Deployment and impact of transgenic Bt cotton in Australia. In N.G. Kalaitzandonakes (Ed.), The economic and environmental impacts of agbiotech: A global perspective (pp. 141-164). New York: Kluwer. George Morris Centre. (2004). Economic & environmentalimpacts of the commercial cultivation of glyphosate tolerant soybeans in Ontario (unpublished report). Guelph, Ontario: Author. Gianessi, L., & Carpenter, J. (1999). Agricultural biotechnology: Insect control benefits. Washington, DC: National Center for Food and Agricultural Policy. Available on the World Wide Web at : www.ncfap.org/reports/biotech/insectcontrolbenefits.pdf. GM Science Review Panel - First Report July 2003 GM Science Review Panel - Second Report January 2004 Gouse, M., Kirsten, J.F. & Jenkins, L. (2003). Bt Cotton in South Africa: Adoption and the Impact on Farm Incomes amongst Small-scale and Large-scale farmers. Agrekon, Vol. 42, No 1. pp. 15-28, March IATP (2005). Backgrounder on WTO Dispute: U.S. vs. EC BioTech Products Case. The Institute for Agriculture and Trade Policy, Prepared by Steve Suppan ICTSD (2006). GMO update: WTO biotech case. The International Centre for Trade and Sustainable Development, Volume 6 No.1. Also available on the World Wide Web at www.icstd.org/biores/06-01-20/story3.htm IFPRI (2003). Research at a Glance, Biotechnology and Genetic Resource Policies, Briefs 1-6, Edited by Philip G. Pardey and Bonwoo Koo. IPC (2004a). The Potential Impacts of the Biosafety Protocol on Agricultural Commodity Trade, Prepared for the International Agricultural Trade Policy Council by Nicholas Kalaitzandonakes IPC (2004b). GM Technology: Assessing the Issues Confronting Developing Countries, International Agricultural Trade Policy Council Trade Negotiations Issue Brief, July 25. ISCU (2003). New Genetics, Food and Agriculture: Scientific Discoveries- Social Dilemmas. Prepared for the International Council for Science by G.J. Persley Ismael, Y., Bennett. R., Morse, S., & Buthelezi, T.J. (2002, July). Bt Cotton and pesticides. A case study of smallholder farmers in Makhathini Flats South Africa. Paper presented at the International ICABR Conference, Ravello, Italy. James, C. (2002a). Global review of commercialized transgenic crops 2001: feature Bt cotton. Ithaca, NY: International Service for the Acquisition of Agri-Biotech Applications. James, C. (2002b). Global status of transgenic crops (various global review briefs from 1996 to 2002). Ithaca, NY: International Service for the Acquisition of Agri-Biotech Applications.

James, C. (2003). Global review of commercialized transgenic crops 2002: feature Bt maize. Ithaca, NY: International Service for the Acquisition of Agri-Biotech Applications. James, C. 2005. Executive Summary of Global Status of Commercialized Biotech/GM Crops: 2005. ISAAA Briefs No. 34. ISAAA: Ithaca, NY. Jeremy Smith (2005). EU eyes WTO case to drive policy forward on GMO’s, Truth About Trade and Technology. Also available on the World Wide Web at www.truthabouttrade.org Jooste, A, Van der Walt, WJ, Koch, M, Le Clus, K, Otto, H and Taljaard, P (2004) ‘Possible impacts of Genetically Modified Food Production on South African Exports’, unpublished paper commissioned by South African Department of Science and Technology Marra, M., Pardey, P., & Alston, J. (2002). The payoffs of agricultural biotechnology: An assessment of the evidence. Washington, DC: International Food Policy Research Institute. Mullins, W., & Hudson, J. (2004.). Bollgard II versus bollgard sister line economic comparisons, Jan 2004. Paper presented at the Beltwide cotton conferences, San Antonio. Pray, C., Huang, J., Hu, R., & Rozelle, S. (2002). Five years of Bt cotton in China: The benefits continue. The Plant Journal, 31(4), 423-430. Qaim, M., & De Janvry, A. (2002, July). Bt cotton in Argentina: Analysing adoption and farmers’ willingness to pay. Paper presented at the American Agricultural Economics Association, Long Beach, CA. Qaim, M., & De Janvry, A. (2005). Bt cotton and pesticide use in Argentina: Economic and environmental effects. Environment and Development Economics, 10, 179-200. Available on the World Wide Web at http://are.berkeley.edu/~sadoulet/papers/Argentina_EDE.pdf. Qaim, M., & Traxler, G. (2002, July). Roundup Ready soybeans in Argentina: Farm level, environmental, and welfare effects. Paper presented at the 6th International ICABR Conference, Ravello, Italy. Royal Society (2003). Genetically modified plants for food use and human health – an update. February. Available on the World Wide Web at www.royalsoc.ac.uk Sankula, S., & Blumenthal, E. (2004). Impacts on US agriculture of biotechnology-derived crops planted in 2003: An update of eleven case studies. Washington, DC: National Center for Food and Agriculture Policy. Traxler, G., Godoy-Avilla, S., Falck-Zepeda, J., & Espinoza-Arellano, J.J. (2001, June). Transgenic cotton in Mexico: Economic and environmental impacts. Paper presented at the 5th International Conference on Biotechnology, Science and Modern Agriculture: A new industry at the dawn of the century, Ravello, Italy. Tutwiler & Straub (2005). International Food & Agricultural Trade Policy Council (IPC) Position Paper Nr 14, June 2005. Making Agricultural Trade Reform Work for the Poor. UN (2005). International Trade in GMOs and GM products: National and Multilateral Legal Frameworks. Prepared for the Trade Negotiations and Commercial Diplomacy Branch Division

on International Trade in Goods and Services, and Commodities by Simonetta Zarrilli, United Nations, New York and Geneva. Wolson, Rosemary, A. (2005). Country Study: South Africa, NYU Project on International GMO Regulatory Conflicts, Unpublished Paper.