Response by the European Commission to comments by WTO Members on GMO foods and feed

Geneva, 26 July 2002

Committee on Sanitary and Phytosanitary Measures
Committee on Technical Barriers to Trade
Response from the European Commission to comments submitted by WTO Members under either or both G/TBT/N/EEC/6 and G/SPS/N/EEC/149

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(Proposal for a Regulation of the European Parliament and of the Council on genetically modified food and feed - COM(2001) 425 final)

I. INTRODUCTION

II. GENERAL COMMENTS

• A. NOTIFICATION UNDER SPS
• B. OBJECTIVE OF THE PROPOSAL
• C. GM FOODS ARE TREATED AS IF THEY WERE INHERENTLY UNSAFE
• D. PROPOSAL MORE TRADE RESTRICTIVE THAN NECESSARY
• E. SEPARATION OF GM FOODS AND NOVEL FOODS
• F. DIFFERENCE WITH NOVEL FOOD REGULATION

• A. SUBSTANTIAL EQUIVALENCE
• B. CHEMICAL MODIFICATION OF A GM DERIVATIVE
• C. PROCESSING AIDS - ENZYMES
• D. SCOPE OF APPLICATION / AUTHORIZATION
• E. RISK ASSESSMENT AND RISK MANAGEMENT
• F. ENVIRONMENTAL RISK ASSESSMENT
• G. ROLE OF COMPETENT AUTHORITIES
• H. "NO RISK" REQUIREMENT
• I. "SHOULD NOT MISLEAD THE CONSUMER" REQUIREMENT
• J. POST-MARKET MONITORING AND MONITORING PLANS
• K. DETECTION METHODS
• L. ROLE OF COMMUNITY REFERENCE LABORATORY
• M. OTHER LEGITIMATE FACTORS
• N. PUBLIC INFORMATION
• O. DECISIONS - TIME FRAME, APPEALS
• P. AUTONOMOUS ACTION OF MEMBER STATES
• Q. 1 % THRESHOLD FOR NON-AUTHORISED GM-MATERIAL

• A. WHAT IS THE RISK BASIS FOR LABELING?
• B. LABELING THE METHOD OF PRODUCTION AND "LIKE PRODUCTS"
• C. LABELING TERM: GENETICALLY MODIFIED OR BIO-ENGINEERED
• D. PRODUCED FROM A GMO, BUT NOT CONTAINING A GMO
• E. LABELING FOR PROCESSING AIDS - ENZYMES
• F. LABELING: RISK OF FRAUD
• G. GM-FREE LABELING
• H. LABELING THRESHOLD
• I. THRESHOLD FOR AUTHORISED AND UNAUTHORISED MATERIAL
• J. ETHICAL OR RELIGIOUS CONCERNS
• K. RISK OF UNEVEN APPLICATION OF LABELING REQUIREMENTS
• L. LINKAGE TO BIOSAFETY PROTOCOL
• M. GM FEED - AUTHORISATION AND LABELING
• N. GM FEED LABELING - UNIQUE CODES

• A. LACK OF ADDITIONAL GUIDANCE
• B. EUROPEAN GROUP ON ETHICS IN SCIENCE AND NEW TECHNOLOGIES
• C. REGISTER OF AUTHORISED GM FOODS AND FEEDS
• D. EMERGENCY MEASURES: CRITERIA - ROLE OF EFSA
• E. EMERGENCY MEASURES: INTERNATIONAL CO-OPERATION
• F. MONITORING AND CONTROL: INTERNATIONAL COLLABORATION
• G. STANDARDIZED TESTING METHODOLOGIES

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