Subject: EC-Biotech Dispute
Date: 10:55 AM 4/5/04
Dear Mr. Zoellick,
The Organic Trade Association (OTA) supports the EU's decision to delay consideration of approvals for genetically engineered organisms (GEOs) until its regulatory system is in place as the most appropriate course of action, and does not approve of the U.S. complaint against that decision.
The Organic Trade Association is a membership-based organic business association with over 1400 members representing all sectors of the organic industry throughout North America. Please find OTA's positions on genetic engineering in agriculture below.
GEOs have been defined by OTA and the National Organic Standards Board as synthetic materials and are prohibited for use in organic production.
OTA calls for a moratorium on GEOs in agriculture. (Please note: OTA has not taken a position on GEOs in animal vaccines; see the preamble to the National Organic Program Final Rule, 7 CFR 205, for relevant language.) This technology has the potential to cause unintended and damaging effects on the environment and on human health (see, for example, Jeffrey M. Smith's "Seeds of Deception." More independent research and regulation are necessary before any more GEOs are allowed in the food system. As long as GEOs continue to be allowed, organic producers are at risk of contamination from background levels of GEOs.
OTA supports mandatory labeling of all agricultural GEOs and their products. The Organic Trade Association supports the consumer’s right to know, and to choose foods based on environmental, personal health, religious, dietary or other preferences. Labeling of products grown from GEO seed or stock or made with ingredients and byproducts of GEO crops is necessary to making these choices at this time.
OTA recognizes that Bt crops are especially harmful to organic agriculture as their use will inevitably lead to insect resistance, and Bt is the most widely used biological control in organic agriculture. (Note that StarLink was developed as a second-generation Bt crop, for when the first generation has stimulated widespread resistance; see link below for reference.)
OTA rejects adopting a zero-tolerance policy at this time, on the grounds that obtaining a zero level of GEOs may not be possible in the US due to widespread contamination. This contamination is more widely spread than many realize. OTA notes that the EU has a tolerance level of 1%, but OTA does not support setting a tolerance level. OTA stresses that organic production is a process guarantee, and notes that just as there are trace amounts of persistent synthetic pesticides in much of our food, so there may be background levels of GEOs in North American food, due to the high percentage of genetically engineered crops grown here.
For further information about the damaging effects of Bt, please see:
APHIS: Environmental Impact Statement for GEOs
among other comments at:
Thank you very much.
Associate Policy Director, Organic Trade Association
P.O. Box 547, Greenfield, MA 01301
Phone: (413) 774-7511, ext. 14; Fax: (413) 774-6432
The Organic Trade Association is the membership-based organic business association representing all sectors of the organic industry throughout North America. OTA's mission is to encourage global sustainability through promoting and protecting the growth of diverse organic trade.