Voluntary Report -- FAS internal use only

**Date:** 11/01/2004

**GAIN Report Number:** NO4004

NO4004

**Norway**

**Biotechnology**

**Biotechnology in Food and Agriculture**

**2004**

**Approved by:**

![](media/image1.wmf)Lana Bennett

U.S. Embassy, Sweden

**Prepared by:**

FAS Stockholm

**Report Highlights:**

Current and developing Norwegian legislation and regulations concerning
bioengineered food and feed products coupled with negative public
sentiment and a generally protecionist environment make their sale in
Norway a dim near-term prospect.

Includes PSD Changes: No

Includes Trade Matrix: No

Unscheduled Report

Stockholm \[SW1\]

\[NO\]

# 

# TABLE OF CONTENTS

[EXECUTIVE SUMMARY 3](#executive-summary)

[THE APPROVAL PROCESS 4](#the-approval-process)

[Introduction 4](#introduction)

[Area of Responsibility 5](#area-of-responsibility)

[Living GMOs 5](#living-gmos)

[Non‑Living GMOs 6](#nonliving-gmos)

[Changing Approval Regulations 6](#changing-approval-regulations)

[LABELING, TESTING AND TRACING REQUIREMENTS
7](#labeling-testing-and-tracing-requirements)

[THE MARKETING ENVIRONMENT 8](#the-marketing-environment)

[Consumer Opinion and Awareness 8](#consumer-opinion-and-awareness)

[Farmers' Unions 10](#farmers-unions)

[Food Processing Sector 12](#food-processing-sector)

[Biotechnology Advisory Board 13](#biotechnology-advisory-board)

[RESEARCH AND DEVELOPMENT IN NORWAY
14](#research-and-development-in-norway)

[OUTLOOK FOR THE SALE OF GMOs ON THE NORWEGIAN MARKET
16](#outlook-for-the-sale-of-gmos-on-the-norwegian-market)

[SUMMARY OF CONTACTS 18](#summary-of-contacts)

[REFERENCE APPENDIX 19](#reference-appendix)

#   {#section-1 .unnumbered}

# EXECUTIVE SUMMARY

Although biotechnology food and feed product questions and issues are
perceived to be controversial in the Norwegian marketplace, the absence
of discussion is much more striking than its presence. Apart from small
sectors in Norwegian society that include certain members of the
scientific community and the various government agencies, Norwegians in
all sectors have let it be known that bioengineering is so unwelcome
that it is fair to say the questions are not even being asked.

While there is no general ban of GMO products in Norway and the 1993
Gene Technology Act and the Norwegian Food Law provide the primary and
basic legislation for their regulation, approval and labeling, only four
products have actually received approval for marketing in Norway (one
line of tobacco and three lines of carnations). However, none is
currently grown in or imported into the country. New regulations ‑‑ both
those conceived domestically and those intended to harmonize new EU
regulations ‑‑ continue to be introduced and implemented, with the
likely effect of increasing restrictions even further in the near
future. The implementation and integration of this new Norwegian
legislation and the lifting of the several year moratorium on GMO
approvals at the EU level make understanding the regulatory process a
continually changing challenge.

While Norway is not a member of the EU, it is a member of the European
Economic Agreement (EEA). This relationship obligates Norway to follow
EU food safety standards, unless they directly contravene Norwegian law.
Through the adaptation of the EEA agreement, Norway has the authority to
reject any EU‑approved GMO that does not meet the requirements of its
domestic gene technology legislation and it has done so in at least
eight cases in the recent past. Here, as will be critical in the
approval process, it is important to differentiate between living
organisms and processed foods. In Norway, only EU legislation concerning
GMOs ‑‑ the living organisms ‑‑ is implemented, not the EU legislation
for GM food products. However, there is an ongoing process evaluating a
possible implementation of the EU legislation on GM foods in Norway.

The reasons behind Norway's official reluctance to accept either living
GMOs or modified products are multi‑faceted. One prevalent Norwegian
attitude can be summarized by the statement \"prove to me why I need
this and how I will benefit.\" This innate skepticism or conservativism
may help explain the reason that bioengineered medical products like
insulin and vaccines are accepted but genetically modified tomato paste,
for example, is not. As one person put it, \"tomato paste is not a life
or death issue.\" So, in spite of the fact that many unknowns exist with
all foods and there is no convincing scientific argument against the
safety of GM foods currently being marketed by the U.S., Norwegians
demand an exceptional level of certainty when it comes to GMOs and food.

Another explanation of Norwegian reluctance to accept genetically
modified organisms and foods containing bioengineered ingredients may be
understood within the context of the \"multifunctionality\" of
agriculture. This refers to the non‑monetary, non‑marketplace importance
and benefit of a strong domestic agricultural industry. Norwegians
believe agriculture involves more than the production of commodities for
sale on global markets; they see domestic agriculture as a central
pillar of rural development, biodiversity, national culture and public
welfare. This attitude continues to affect not only the Norwegian
consumer but also the politicians and their policies. Norwegians of all
ages and all political stripes feel that food security (through
maintainance of a certain degree of self-sufficiency) is an important
and relevant issue and many are willing to pay the additional costs to
support this policy.

Another characteristic that may explain Norwegian skepticism about
biotechnology is the fact that Norway perceives itself as a young
country, having received its independence from Sweden in 1905. There are
strong feelings of still‑newly‑found independence and pride in things
Norwegian. Plus, Norway's recently acquired petroleum wealth ‑‑ owing to
discoveries along its continental shelf in 1965 ‑‑ has provided the
Government with the financial luxury of not having to alter its
financial commitments in the form of subsidies or price supports to
farmers and has lulled the country into relative inaction when it comes
to changing its attitudes toward new food or feed technologies.

This broad context helps explain the reasons that imported GM foods and
feed are viewed as undesirable, in spite of the fact that they do not
threaten any domestic Norwegian industry. Norway has made some
controversial economic decisions as in the case of the resumption of the
sale of whale meat, the culling of wolves to safeguard farm animals and
the exploration for and development of the petroleum industry in
environmentally sensitive areas, showing evidence of its willingness to
ignore the international community when its own economic interests are
at stake. However, in the case of GM products, resistance is based on a
completely different and predominantly non‑quantifiable rationale.
Herein lies the challenge for opening the Norwegian market to
bioengineered agricultural products, in the event that the legislation
permits it.

# THE APPROVAL PROCESS

## Introduction

The approval process for genetically engineered products in Norway is
regulated both internally by one main and several additional Norwegian
pieces of legislation, which originated in the Norwegian Parliament, and
is influenced from the outside by directives originating from the
European Commission in Brussels. The approval legislation on GM products
is divided into two parts. One is the Norwegian legislation called the
\"Act Relating to the Production and Use of Genetically Modified
Organisms,\" also known as the Gene Technology Act (GTA) of April 2,
1993. This act is comprehensive and provides the basis for approving
living GMOs, plus general provisions about marking the products that
consist of or contain genetically modified organisms. (See document
appendix) The other part entered into force on January 1, 1999, and
outlines the approval requirements for GM and other novel foods. This
regulation is included in the Norwegian Food Law. GM foods containing
living organisms (e.g. unprocessed soybeans or fresh tomatoes) are not
covered by the authorization demand in Norwegian Food Law but, rather,
by the Gene Technology Act.

When it comes to approvals of GMOs, there is one ministry with
regulatory responsibility, the Ministry of Environment. In addition, the
Directorate for Nature Management in Trondheim and the Norwegian Food
Safety Authority (Mattilsynet) in Oslo and the Biotechnology Advisory
Board are particularly influential. The complicated approval process can
be broken into several paths. The distinguishing feature is whether the
genetically modified organism is living or non‑living. If it is living
and can be field tested in a deliberate release situation (as in
modified flowers or a field crop like corn or tomatoes), it falls under
the authority of the Ministry of Environment for the marketing aspects
and under the Directorate for Nature Management for the field tests. If
it is living but kept in strictly contained facilities (like labs,
greenhouses and bioreactors), it falls within the authority of the
Ministry of Health. Lastly, if it is a produced food product made with a
modified ingredient and is, as such, in the \"non‑living\" category, it
falls within the authority of the Norwegian Food Safety Authority.
Ingredients for GM feed that are not already processed, like whole
soybeans or whole corn kernels, are considered to be living organisms
and, as such, fall under the authority of the Ministry of Environment.

Table One: Authoritative Body and Areas of Responsibility

+-----------------------------------+-----------------------------------+
|                                   | # Area of Responsibility          |
+-----------------------------------+-----------------------------------+
| **Ministry/Authority**            |                                   |
+-----------------------------------+-----------------------------------+
| Ministry of Environment           | Approval for the marketing of     |
|                                   | genetically modified living       |
|                                   | organisms that will involve       |
|                                   | deliberate release; approval for  |
|                                   | genetically modified living       |
|                                   | organisms for food and feed       |
+-----------------------------------+-----------------------------------+
| Ministry of Health                | Approval for contained use of     |
|                                   | genetically modified living       |
|                                   | organisms                         |
+-----------------------------------+-----------------------------------+
| Directorate for Nature Management | Approval for the field testing of |
|                                   | genetically modified living       |
|                                   | organisms                         |
+-----------------------------------+-----------------------------------+
| Norwegian Food Control Authority  | Approval for food products        |
|                                   | produced from a genetically       |
|                                   | modified organism but not         |
|                                   | consisting or containing living   |
|                                   | GMO                               |
+-----------------------------------+-----------------------------------+

## Living GMOs

For those wishing to obtain approval to field test or import and,
presumably market, a living organism such as genetically engineered
seed, the path starts at the Directorate for Nature Management (DN). An
application is submitted to the Directorate, which sends it out to a
public hearing and begins the process of risk assessment. DN chooses
one, and sometimes more, authorities to provide input on the
acceptability of the application and the credibility of the science
therein. Among these authorities is the Norwegian Food Safety Authority
which provides an opinion concerning food and feed safety. This opinion
is based upon a risk assessment performed by an independent scientific
committee. DN's experts would weigh in on environmental issues; the
Biotechnology Advisory Board would provide advice concerning ethical
issues, sustainable development and social benefits. After receiving the
comments and recommendations from these various authorities, the DN does
one of three things. If it is a field test case, DN itself makes the
decision to approve or reject. In other situations, it either makes a
proposal to the Nature Management Department of the Ministry of
Environment or it may request additional information and/or
clarification from the applicant. If it wants more information, a
consultative process is begun between the authority and the company that
filed the application with the intention of resolving the authority's
questions. If the DN is ready to make a proposal, it differentiates
between applications to which it is bound via its political membership
in the EEA and applications that come from a non‑EEA/EU source, like
American applicants for instance. In the EEA/EU case where the item has
already been approved in Brussels, the DN and the Ministry of
Environment send notification to the Government, which meets every
Friday, for its pro forma approval and they send a notice to the
Norwegian media that a particular product has been approved. If the DN
proposes to reject an EEA/EU application, it must publish a
\"regulation\" and not a \"proposal.\" The Ministry of Environment
consults with the Ministry of Health, the Ministry of Agriculture, the
Ministry of Foreign Affairs and the Ministry of Trade and Industry to
derive a consensus position to prohibit the EU product, as is required
under the EEA agreement.

If the applicant is an American company, for instance, submitting the
dossier to Norway for approval in the EU/EEA‑area or in Norway only, the
procedure is quite similar but there is no legal requirement to publish
a regulation. The DN can simply send its recommendation either for
acceptance or rejection to the Ministry of Environment, which issues the
final decision. According to the Ministry of Environment, there have
been eight products that have been rejected and for which regulations
have been written. They are as follows: chicory, three strains of oil
rapeseed, one strain of maize, a test kit with bacteria and two
pharmaceutical products that contained living virus vaccines ‑‑ one for
pigs and the other for rabies. Because each of these applications
originated from the EU, a formal rejection and explanation was required,
the rationale for each of which (except the test kit) is contained in
documents listed in the Document Appendix of this report.

Currently, the only pending applications for living genetically modified
organisms are from EU countries. Three of these applications are for
lines of corn and one is for a line of soybeans. None of these
applications is particularly active at this time.

## Non‑Living GMOs

The second avenue in the approval process is for those products that do
not contain living organisms -- corn oil, for instance. In this case, it
is the Ministry of Health that has the legal authority for approval or
rejection and it has formally delegated this responsibility to the
Norwegian Food Safety Authority (Mattilsynet). An application is
submitted to the Authority, which conducts a risk management assessment
and either provides or denies consent for the processed product. An
independent scientific committee conducts the risk assessment in order
to evaluate human and animal health risks. On a practical level, there
have not been any such products approved for sale in Norway, neither are
there any applications currently under evaluation by the Authority.

## Changing Approval Regulations

On April 18, 2004, the EU implemented Regulation 1829/2003 on
Genetically Modified Food and Feed, and Regulation 1830/2003 on
Traceability and Labeling of Genetically Modified Organisms and the
Traceability of Food and Feed Products produced from Genetically
Modified Organisms. As of this date, any food or feed product produced
with GMOs must be labeled. The threshold for adventitious
(unintentional) presence of approved GMOs in food is set at 0.9%,
meaning if the accidental GMO presence in food is above 0.9%, the
product must be labeled as containing GMOs. The threshold for
adventitious presence of GMOs which are not yet formally approved but
which have received a positive EU risk assessment is 0.5%. If a product
contains a GM ingredient on purpose, that product must be labeled, even
if the presence is undetectable, or detectable and below 0.9%.

While it is not yet clear what in the Norwegian legislation itself would
have to be changed, the Norwegian authorities is moving in favor of
integrating these new policies, given their natural preference for
increasing restrictiveness concerning both living and non‑living GMOs.
There appears to be wide‑spread support for a formalized traceability
process. In terms of practical application for the approval process
(labeling and traceability will be dealt with in the next section), the
most significant change anticipated in Norway by the new EU regulation
is that the end to the moratorium on approvals in the EU could, in turn,
mean an increase in the number of applications submitted to the
Norwegian authorities. However, in the event that these new applications
do not meet Norwegian approval standards, the applications will be
rejected according to the Gene Technology Act and the Norwegian Food
Law.

With the EC Directive 2001/18 on deliberate release genetically modified
organisms (GMOs) into the environment, there seems to be an increasing
tendency for the EU approval process to take into consideration the
kinds of criteria that the Biotechnology Advisory Board applies to
Norwegian approvals. Those considerations include sustainability, social
benefit and ethics (see Document Appendix). While the Norwegian
Biotechnology Advisory Board has applied such subjective and ill-defined
standards for quite some time, the fact that new EU legislation has
taken these concerns into consideration is something that has received
broad praise in Norway. It should also be noted that on March 4, 2002,
new Norwegian legislation, resulting from a 1997 Parliamentary decision,
that totally prohibits GM food and feed with functional antibiotic
resistance genes entered into force.

# LABELING, TESTING AND TRACING REQUIREMENTS

GM food and feed products produced in or imported into Norway must be
labeled according to a parliamentary decision from 1995. Labeling
requirements are contained in both the Gene Technology Act (paragraph
15) and in the Norwegian Food Law. The Norwegian Food Law includes
regulations on labeling of GM foods and feeds. The Norwegian labeling
requirements on GM foods entered into force in October 1997, and apply
to all GM foods including genetically modified organisms (GMOs) and food
derived from genetically modified organisms, regardless of whether their
properties or characteristics are different from those of comparable
conventional food. The purpose of the labeling, according to various
interviews sector‑wide, is to meet consumers' demand to know if the
product has been derived from genetically modified organisms, thus
enabling them to make an informed choice. The labeling requirements are
considered to be satisfied if products containing genetically modified
ingredients are labeled as such if the genetically modified component
constitutes more than two percent of the ingredient. Norwegian labeling
requirements on GM feed entered into force in 1999.

Norwegian labeling is required on GM food regardless of whether the DNA
or protein is present. In other words, even though it may be impossible
to test for its presence or absence, it must be labeled. The new EU
regulations represent a harmonization with the Norwegian standards as
regards to labeling. For the past seven years, Norway has also required
process labeling for GM products indicating that the product is derived
from GM food techniques, even though there may be no evidence of it.

With no scientific methods to validate that the product is GMO-free when
no DNA protein is present, the authorities must implement and depend
upon quality assurance systems including documentation control that
identifies GM products or, more accurately, GMO‑free products. This is
where tracing and testing come in. While Norway has no regulations on
traceability, most industry and trade have internal control standards in
place that both promote quality along the food chain and assure the
authorities that the regulations are being followed. These should also
include systems to prevent non‑approved GM products from being
manufactured. The Norwegian Food Safety Authority perform inspection and
random testing of feed, seed and food all along the supply chain. The
samples are analyzed by the National Veterinary Institute, which is the
enforcement laboratory for GMO analyses.

Where analytical methods are not available or are not sufficiently
sensitive, the authorities rely on documentation control. However, no
specific regulation about the kind of documentation that is needed to
demonstrate that the presence og small amount of GM material in a non GM
product is adventitious and technical unavoidable. The Norwegian Food
Control Auhtority is working on guidelines about what is acceptable.

For instance, soy marketed as non‑GM may contain traces of Round‑up
Ready soybeans (RRS), despite extensive efforts to prevent
contamination. Therefore, Norway has established an enforcement practice
where approval of foods with \"unavoidable traces\" of GMOs is not
considered necessary. However, the quantifiable definition of
\"unavoidable traces\" may vary over time, depending upon The Norwegian
Food Safty Authority's evaluation of what levels are \"reasonable\" and
\"satisfactory.\" The currently applied management practice is that the
Authority will tolerate maximum levels up to 0.5% for GM and GMO that
among other things, have positive risk assessment in EU or Norway but
are not yet authorized and 0.9% for GM and GMO that are authorized in
EU, provided that the supplier, producer and importer of a food product
can demonstrate that measures have been carried out.

Since 1999, Norwegian legislation permits the import and use of GM feed
(but not GMO), if it is labeled according to the legislation. Prior to
1999, this was an unregulated area. The Norwegian Food Control Authority
has responsibility over imported and nationally produced feed and
performs random tests. In 2001, 1,100 samples of imported feed materials
and nationally produced feed were taken. About 85 of them, all products
containing corn or soy, were tested for GMO content. Of those tested,
none was found to contain GMOs or GM material above the labeling
threshold; thus none needed to be labeled. However, the Service did
detect some traces and contents in the category of less than two
percent. If these traces are found in whole corn or whole soybeans, the
Authority handles this matter on behalf of the Ministry of Environment,
which has approval authority over living GMOs. Currently, labeling is
required on genetically modified products and packaged items, for
instance ketchup and boxes of genetically modified tomatoes. Upcoming
changes will be made in accordance to the new EU directives. These
changes will be notified to WTO in the autumn of 2004.

The Norwegian consumer is currently requesting increasing amounts of
information on food products in order to make an informed choice and
this demand sometimes goes beyond the requirements of the EU. There is
concern about where a product was raised ‑‑ do sheep graze on lands that
were affected by the Chernobyl disaster? Are crops ‑‑ even those
designated as organic ‑‑ grown in a particularly polluted part of the
Ruhr valley? Are chickens or cows penned or do they roam freely? In
these cases, Norwegians are asking for ‑‑ and receiving ‑‑ information
not just about the product but also about the processes by which an item
becomes a product. The question of whether this increased information
actually influences purchasing patterns will be addressed later in the
section on the Marketing Environment.

Although it is fair to say that the predominant focus of product
labeling has been for items destined for human or animal consumption,
there is pending Norwegian legislation (that is expected to be approved
in the fall) that would require labeling of GMO non‑food items. This
regulation would apply to, for instance, the three lines of GM
carnations and the one line of tobacco that have already received
approval but have not yet been imported to Norway for sale or
distribution. In addition, it is worth repeating that this evolving and
intricate system of labeling ‑‑ internally in Norway and externally by
the EU ‑‑ is hypothetical since there is no genetically modified food
allowed in Norway.

# THE MARKETING ENVIRONMENT

## Consumer Opinion and Awareness

There are two main consumer organizations in Norway which are useful in
gauging attitudes about biotechnology and GMOs. One is the
Forbrukerrådet or The Consumer Council of Norway while the other is the
Statens Institutt for Forbruksforskning or the Consumer Research
Council. The Consumer Council is charged with formulating opinions
concerning consumer policies and to assist consumers when they have
consumer‑oriented complaints. The Consumer Research Council conducts
research with an emphasis on practical results that can support
consumers' position in the market and to increase the public
authorities' knowledge about consumer issues.

Issues concerning biotechnology and GMOs are subsumed under the general
category of food safety, an issue of high priority in Norway. While
there is evidence of a divergence between attitudes expressed by
consumers in surveys conducted by the Consumer Research Council and the
reality of their consumption patterns, it was confirmed that
biotechnology in general and genetically modified products in particular
are thought of as \"food hazards.\" (See \"Trust in Food in the Age of
Mad Cow's Disease,\" English language summary, pp. 15:22, listed in
Document Appendix.) Norwegians associate biotechnology with highly
advanced industrialized agricultural practices implemented and
controlled by big industry and multi‑national corporations. Not only is
this type of farming perceived to be non‑existent in Norway but it is
also highly undesirable. The Norwegian reality includes the practive of
both large and small-scale farming. In addition, while highly
subsidized, expensive and dependent upon protection against imports,
agriculture continues to play a role beyond that of strict economic
importance to the country. But, attitudes are changing slowly. While
public support has continued to make it possible to subsidize small
farms up in the mountainous areas of Norway, the subsidies have been
reduced as a result of international WTO agreements. Public support for
the Farmer's Party, now called the Center Party, has declined as has the
support for the Social Democrats, Christian Democrats and Left Party ‑‑
each of which is viewed as strong supporters of Norwegian
multifunctionalism. In spite of these trends and the fact that the
multifunctionalist notion forms an integral part of Norwegian policy at
the district level, biotechnology ‑‑ in contrast ‑‑ is seen as something
at the other end of the spectrum. Moreover, during the past seven to ten
years, the number of skeptics has increased to 70 ‑ 80 percent of the
population, which may explain the reason that the topic is not even
debated in communities outside those that conduct research and
development.

The public's level of knowledge and sophistication about biotechnology
and bioengineered products is rather limited. While the few advocates in
the scientific community give occasional interviews to the press, there
are prominent and vociferous detractors in the scientific community ‑‑
as well as elsewhere ‑‑ whose access to the media and impact on public
opinion is acknowledged to have great influence. The public's skeptical
attitude is explained as the result of high profile coverage of food
safety scandals, some but not all of which are biotechnologically
related. For instance, in the late 1990s, the debate on genetically
modified salmon being tested in Canada was played out on the front pages
of Norwegian newspapers and presented as \"monster salmon.\" One
scientist described a contentious situation that arose at the official
dedication of the new biotechnology building at the Agricultural
University in Ås earlier two years ago. Her address included the
prospect that genetically engineered fatty acids could be used to stem
the decreasing supply in fish food, an important Norwegian domestic and
export product. This, in turn, prompted a major media debate. As a
result of increasingly high profile coverage by the Norwegian and
European media of innumerable food scandals from BSE to dioxin to foot
and mouth disease to monster salmon, surveys and focus groups have shown
that \"contentious\" consumers are fed up with these notions of modern
food science and have hunkered down with attitudes of near total
rejection.

The Norwegian Government has been able to shelter the Norwegian consumer
from having to make rational economic choices about agricultural policy,
in part due to the discovery of petroleum along the Norwegian
continental shelf in 1965 and the subsequent revenue accruing to the
Government from its sales. In spite of this, however, that which the
Norwegian consumer says in surveys and focus groups and that which s/he
does in practice are, in many instances, two separate things. A growing
quarter of Norwegian consumers is enticed across the border to Sweden by
cheaper (although perceived to be of as high or higher quality) goods ‑‑
particularly meat, cheese, alcohol and tobacco. Thus, there seems to be
some elasticity when it comes to the price of food. It should also be
noted here that, although Norwegians leave Norway for these purchases,
they are still purchasing items in an EU country and, thus, food safety
concerns are regulated by most of the same legislation that has been
harmonized in Norway.

The level of trust between the Norwegian consumer and the regulatory
authorities is extremely high. The ministries of agriculture,
environment and health along with the Norwegian Food Control Authority
have established a significantly high level of trust between consumers
and themselves. This trust does not extend to producers or retailers, as
it is believed that market forces alone will not produce safe, healthy
food. According to the National Institute for Consumer Research's report
entitled \"Trust in Food in the Age of Mad Cow's Disease,\" two‑thirds
of Norwegians presume that information provided by environmental
organizations is somewhat exaggerated and only nine percent have full
trust in the information on food scandals that is presented by the
media. Most consumers believe that the farmers and the grocery trade and
food industry representatives would not tell the truth, if there were to
be a food scandal in Norway.

## Farmers' Unions

There are two farmers unions in Norway and they are divided by the
political orientation of their membership. Norges Bondelag is the more
traditional of the two groups and many of its members support the Center
Party which used to be known as the Farmers Party. Their membership of
approximately 60,000 is comprised of 34,000 large and small farmers,
with the remainder being students, agriculture professionals and members
of the general public. The other union, whose membership ranges between
5,000 to 10,000, has as its political orientation a more red/green
socialist affiliation. This second union's farmers are all small
farmers. In an annual spring exercise resulting in intervention at the
national level in the agricultural sector, both farmers' unions and the
Government negotiate the level of subsidies to farmers and price
controls for their products. While the Norwegian political system
assigns this central role to the national government, districts also
have some independence when it comes to the support of farmers.

Farmers have, in general, not been particularly receptive to new farming
techniques, neither organic ones nor those that might incorporate
genetic engineering applications. Norwegian farmers are described as, by
and large, traditional and conservative and would not be likely
candidates to agitate for changing the status quo, unless they were to
see some direct financial or qualitative benefit from that change.

Food Retail Sector

The Norwegian food retail sector is comprised of four main players. None
of these major retailers has much incentive ‑‑ either legally or
financially ‑‑ to take the lead in introducing genetically engineered
products, if there were ever to be any approved, into the Norwegian
marketplace. This stems from two main factors: (1) consumer reaction is
perceived to be critical and (2) media reaction is also perceived to be
predominantly negative. In order for the sale of a genetically modified
product to be successful, these anticipated negative responses would
have to be offset by either a significantly lower price for the same
quality good and/or evidence of greater sustainability, social benefit
and ethical development. Given that approximately one‑quarter of the
Norwegian population travels across the border to Sweden in order to
purchase cheaper meat, cheese, tobacco products and alcohol, there is
evidence of price elasticity on consumer purchasing patterns. These
trans‑border purchases account for approximately ten percent of the
consumer market's total.

Norwegian food retailers are keenly aware that the European food
scandals of the 1990s have increased the levels of frustration of the
Norwegian consumer and that Norwegian consumers want proof of quality.
This is one of the reasons that documentation from suppliers is so
important to the retailer. In the event that random tests cannot or do
not validate food safety, the perception is that the documentation
system does, even though it cannot provide guarantees. Encouraged by
increasingly influential print and electronic media that bring food
safety issues to the receptive public's attention, retailers are
approached by consumers and critics when there are any perceived
problems. At that point, the retailer can turn to its numerous suppliers
and producers to request quality assurance certificates and attempt to
rectify the problem. Retailers include in their contracts with their
suppliers an assurance that they will guarantee (and label) any product
with a modified ingredient of more than two percent. Retailers conduct
random tests of the products they sell. In the event of a questionable
result, they have and do pull products off the shelves. However, in most
cases where there is a questionable result, the retailer, the supplier,
SNT and MATFORSK (the Norwegian Food Research Institute) work
cooperatively to obtain an explanation and to resolve the problem out of
the limelight. Testing, of course, contributes to the high price of food
in Norway although Norwegians spend only 12% of their household budgets
on food, compared to their EU neighbors who spend approximately 15%.

The possibility of a future replete with genetically modified raw
materials and products is of great concern to long‑range company
profitability. However, this concern does not appear to be coupled with
a long‑term strategy for dealing with or resolving the issue. Many in
the retail and production sectors view this future scenario as
presenting tremendous challenges (not opportunities) for Norway from the
ministerial level on down to the consumer. While the recent
centralization of the Norwegian inspection authorities as well as the
increasing sophistication of tests is believed to facilitate
responsiveness and access to information, it is clear that concern about
\"stemming the GMO tide\" lurks just under the surface for both
retailers and producers. It remains to be seen how the system will want
to and be able to respond to the increasing spread of genetically
modified primary ingredients.

Feed Manufacturing Sector

The Norwegian feed manufacturing sector includes the import of soybeans
for soymeal, crude oil and refined oil. The meal and crude oil is used
in compound feeds, mostly for animal consumption. Until 1997, Norway's
sole soybean crushing company, Denofa, imported half of its requirments
from the United States, with the rest coming from South America. The
change came in 1997 when some of its main customers who manufactured
butter substitutes heard about GMOs and did not want them in their
products. Denofa tried to convince the U.S. suppliers to eliminate their
genetically modified soybeans (rather than to try to convince their
customers of the safety of the product) and, when that failed, the
company eliminated U.S. soybeans from its supply. At that point,
however, it should be noted that Denofa did not really know whether the
soybeans were ‑‑ or were not ‑‑ genetically modified.

After Denofa moved away from U.S. suppliers, it turned for two growing
seasons to Canada, where Round‑up Ready soybeans were not yet widely in
use. After the spread of genetically modified soybeans across Canada,
Denofa moved its procurement to Brazil, where they were able to purchase
significant amounts of land and control the growing, harvesting,
transportation and shipping process from farm to their processing plants
in Norway. Given that genetically modified soybeans are classified as
living organisms, there is a zero percent tolerance, according to the
1993 Gene Technology Act. The company was able to provide its guarantee
for GM‑free soy products as a result of an extensive internal control
system that tests for the presence of GMOs in the seed, in the plants
during the growing season, on the trucks that take the beans to the
silos, in the silos, in the containers and at their processing plants.
More recently, however, Denofa has moved away from contract growing on
few large farms in Matto Grosso to procurement from a variety of smaller
farmers in the region. This was due to the price demands being exacted
by their farmer contractors. Inspection done at Denofa's receiving
warehouses in Matto Grosso prior to purchasing are indicating an
increasing presence of bioengineered varieties from supposedly GM-free
fields in this area and, as a result, increased rejections of truckloads
of soybeans by Denofa. The company provides a closed system for which
their customers are willing and do pay a premium. Because the company is
of a relatively small size, it was able to make a business decision
about five years ago to grow and process only GMO‑free soybeans. Denofa
has expanded its crushing capacity to about 400,000 MT to accommodate
and expanding market for their soy products. Their market has grown to
include 30,000 to 40,000 tons of meal for pet food and an additional
supply to Nestlé, both of which the company representative attributes to
the company's commitment to GMO‑free soybeans.

As long as there are customers willing to pay a high price for these
goods, the prospects for this company, and its GMO‑free soybeans, are
good. Although half of the meal is sold to the domestic market, half is
shipped to a Europe that may be increasingly open to the presence of
GMOs. Given that European companies have quite a choice of soybean
product suppliers, the risk of an increasingly smaller market for their
higher priced goods is a realistic long‑range concern. Additionally,
Denofa's more recent difficulties in procuring GM-free soybeans from
Brazil have spurred Denofa to lobby for an increase in Norwegian
tolerance levels.

Another policy decision that will affect the feed market is that, from
July 2002, Norway opened its markets to feed product imports from the
least developed countries. Given that Norwegian law will govern imports
grown in environments with different uses of pesticides and,
potentially, GMO seed, it remains to be seen how this will play itself
out.

## Food Processing Sector

The Norwegian food processing sector is dominated by one company called
Orkla ASA, which is a conglomerate of many other companies. It is one of
Norway?s largest listed companies and has annual sales of more than USD
4 billion. The three areas of concentrated activity include branded
consumer goods, chemicals and financial investments. Approximately 60%
of the Group's 18,500 employees are employed in Norway. With annual
sales of approximately USD 3 billion, branded consumer goods is Orkla's
largest area of activity. Orkla Foods itself is divided into seven
divisions: Stabburet, Procordia Food, Beauvais, Felix Abba, Orkla Foods
International, Abba Seafood and Orkla Food Ingredients. The company is a
leading developer, producer and marketer of pizza/pies, sauces, snacking
products, ready meals, fruit and berry products, pickled vegetables,
seafood, potato products and baking ingredients. Sixty percent of these
products are sold to the grocery market under Orkla Foods' own brands,
with the catering sector, the food industry, exports and tax‑free sales
accounting for the remainder. The Nordic market accounts for 90% of
operating revenues and is home to 31 of the company's 41 production
plants. Most operations outside the Nordic region come under a separate
division, Orkla Foods International and the company is looking to
southeast Asia and China to expand its activities in the branded
consumer goods areas, primarily food and beverages. For the purposes of
entering the Asian market, Orkla operates from its subsidiary in
Singapore, Orkla Asia Pte Ltd.

The company publishes two policy papers that concern modern gene
technology. Orkla?s position is a restrictive one in which it is bound
by national legislation and official requirements in the GMO area and is
influenced by consumer attitudes. It acknowledges in the first policy
paper that modern gene technology offers greater possibilities for
giving plants, animals and microorganisms new properties and by
transferring genes between organisms which have traditionally been
unable to exchange genetic material, it is possible to create
genetically modified organisms (GMOs) with new properties that simplify
cultivation and breeding or provide improved end products for consumers.
However, Orkla has a restrictive policy regarding the use of modern gene
technology in the production of food because a clear majority of
consumers in its main markets do not accept the use of genetically
modified raw materials. (From Orkla ASA \"Policy on Modern Gene
Technology,\" adopted by the Orkla Group Executive Board on 17 December
2001.)

In an attempt to clarify Orkla's policy on GMOs, the \"Policy on the Use
of Modern Gene Technology in the Production of Food,\" paper, also from
17 December 2001, states that this approach applies to all Orkla's food
producing companies with respect to raw materials and products that are
to be used in the production of food. It elaborates with six points.
First, the food companies are to use raw materials, ingredients,
additives and flavorings that are based on traditional production
methods. \"Traditional production methods\" are defined as methods
whereby the plant, animal or micro‑organism is produced, developed and
improved without the use of modern gene technology. They are to have
adopted a restrictive policy regarding the use of modern gene technology
in the production of food. If a food company is considering marketing
and selling products that require GMO labelling, this matter must be
discussed by the Board of Directors of the business area concerned
before a decision is made. The food companies are to be responsive to
the attitudes of customers and consumers to the use of modern gene
technology in the production of food, and comply with national
legislation and official requirements in the GMO area. They are to
require suppliers to establish verified systems for separation,
documentation and analysis in order to make it possible to assure the
origin and quality of products, for example the absence of contaminating
GMO material. As far as technically possible and financially feasible,
food companies should avoid using processing aids (including enzymes
which are classified as processing aids), extraction agents or solvents
that are produced with the help of modern gene technology, even though
the end products do not have to be GMO labelled. Similarly, the food
companies make efforts to avoid the use of substances originating from
micro‑organisms that have grown on substrates containing material from
genetically modified organisms. Lastly, food companies are to support
suppliers in their efforts to supply raw materials, ingredients, etc.,
which come from animals fed on feed that is produced using only
traditional production methods.

Orkla states that it is monitoring developments, both with respect to
customer and consumer attitudes to modern gene technology and with
respect to the potential and hazards that new genetically modified
organisms may present in the future and, if Orkla is to change its
restrictive policy on the use of modern gene technology, raw materials
and production methods that are based on such technology must: (1) have
proved to be safe from the point of view of health and the environment,
(2) be accepted by large customer and consumer groups and (3) lead to
products that offer significant advantages for customers and consumers.

## Biotechnology Advisory Board

The Norwegian Biotechnology Advisory Board, authorized under the 1993
Gene Technology Act, is an independent body consisting of 24 members
plus six observers. Members are chosen from eight different
organizations across Norwegian society: one trade union representing the
employers, one representing employees, the National Research Council, an
organization representing the handicapped, the Consumer Council,
non‑governmental organizations (including environmental organizations),
one of the two farmers' unions (they switch off) and one of the two
fisheries organizations (they also rotate). The six observers, who may
ask questions and make comments but not vote, represent six different
government ministries: Agriculture, Fisheries, Health, Commerce,
Environment and Administration. The Advisory Board has the
responsibility for coordinating responses on health issues during the
approval process as well as for issues of sustainable development,
social benefit and ethics. Its advice is targeted at the Ministries of
Health and of Environment, in particular, and, while there is no formal
advisory role with SNT, a close working relationship exists. Because its
members are chosen for their personal skills and scientific background
and are often engaged in public debate, they are frequently brought in
on the GMO issue when members of the Norwegian Government meet with
their EU counterparts. The Board advises the Government about questions
it should ask of the EU in an attempt to influence the legislation and
to obtain clarification on various points of concern. Once the EU has
made a change in policy, the Norwegian Government has thirty days to
either approve or reject it. The Board perceives itself to be quite
influential due to its expertise.

In terms of the Board's decision‑making process, it provides
recommendations and not consensus decisions. Individuals and groups sign
particular position papers and these differences of opinion are
forwarded as such to policy makers. A split decision in early 2000 about
an application to approve genetically modified blue carnations provides
an illustrative example. The Board took split positions concerning the
sustainability of blue carnations, as it found it easy to argue that
blue carnations are not socially beneficial. However, this decision was
extremely difficult to quantify. (See attached document in Norwegian of
guidelines from the Biotechnology Advisory Board for work in this field.
These guidelines are also used by the Ministry of Environment and the
Directorate for Nature Management.) Thus, while agreement was reached
about the lack of social benefit, one group accepted the idea of
approval while the other did not. Ultimately, the Ministry of
Environment approved the application, (at the time of the approval, the
carnations would not have to have been labelled as being genetically
modified because they are not for human consumption) but, to date, they
have not been marketed in Norway.

While the Biotechnology Advisory Board used to concentrate its GMO
expertise in the fields of health and even environmental risks, it has
recently broadened its focus to include ethical and social issues.
Norway has been out in the forefront on these types of considerations
and, believes has effectively influenced the adoption of these types of
considerations by the EU.

Environmental Groups

Three main environmental groups in Norway are: (1) Naturvern Forbundet
(Nature Protection Society), (2) Natur og Ungdom and (3) Bellona. While
environmental groups have suffered a series of defeats recently ‑‑
including in the areas of petroleum extraction, whaling and wolf culling
‑‑ they do not seem to have biotechnology issues high on their agenda.
One reason for this attitude may be explained by their view that the
general population is in solidarity with their cautious position. Thus,
there is not really any battle to fight in Norway concerning these
issues and they direct their efforts to more domestically contentious
problems.

# RESEARCH AND DEVELOPMENT IN NORWAY

When evaluating the research and development activities in the
biotechnology area in Norway, it is important to examine the fields of
research and the type of governmental support. It appears that there is
quite a bit of research being conducted in order to \"safeguard the
country from GMOs.\" Risk assessment techniques are being developed that
will produce testing systems to facilitate the detection of genetically
modified organisms with increasing sophistication. It is here, however,
within the scientific community, both at the university and at the
policy level, that there appears to be the most activity on the GMO
front.

Several reasons underlie this activity. Firstly, because of the
increasing use of GMO technology worldwide, Norway's scientific
community needs to have the competence to judge that which is happening
in the field. This is important in order to enable the scientific
community to make informed decisions. The Norwegian scientific community
wants to ensure that it is not left behind. Another reason identifies
the possibility of a shift in attitude by the general public and, in
particular, a radical and sudden shift. With the global geographic area
of GMO production already larger than the whole area of Norway, members
of the research and development community more readily and realistically
prepare for the eventual presence and even acceptance of GMOs in Norway
in a way that is more proactive than that which is found in most other
segments of the population.

Several new research programs have been established that have
biotechnology components. One, with several biotechnology projects, is
called \"Biologisk mangfold, dynamikk, trussler og forvaltning.\"
Another is \"Etikk, samfunn og bioteknologi.\" The Ministry of Health
and the Ministry of Environment support the newly established
\"Institutt for genokolgi\" in Tromso, which does research on the health
and environmental effects of gene technology. The National Research
Council has, within the past few years, funded the FUGE or functional
genomics project to the tune of NOK 100 million. This program, which
commenced in 2002, but with funding for five to ten years, has its own
board and is independent of the National Research Council. The program
was funded for three reasons. It was stated that basic research has
totally changed as a result of advances in gene technology and it is
important for Norwegian institutions to be part of that changing reality
and not be left behind. There have also been advances in medicine as a
result of genomics that have been widely beneficial and accepted in
Norway and this type of research needs to be supported. Lastly, the
importance of the Norwegian fishing industry requires scientific
participation in changes in aquaculture and marine science.

The implementation of FUGE was credited to what have been described as
\"major changes in attitudes over the past year or two, even at the
political level.\" On June 5, 2001, the Prime Minister took the
initiative to host an international conference at the University of Oslo
on biotechnology and the implications of a biotech society. The
conference drew a crowd of several hundred participants and received
\"pretty positive\" press coverage. In addition to the FUGE program, the
National Research Council supports, among its six different areas of
interest, programs that examine the genome of salmon (funded at NOK 10
million yearly (about US\$ 1 million)), the identification of
genetically modified proteins and genes (with consideration given to soy
protein) and the ethics of research.

Other evidence of activity and ongoing research and development in the
field of biotechnology in Norway can be found, for example, in the new
biotechnology building that opened two years ago at the National
Agricultural University. It now houses members of the chemistry,
genetics and microbiology faculty. But, while the climate for biotech
research may be seen to be improving over the recent past, work on GMOs
is done somewhat surreptitiously and without drawing attention to
itself. As a matter of fact, while the National Research Council will
fund certain biotechnology projects, those openly containing GMO aspects
are bound to \"run into hassles\" at the approval level. Scientific
research into GMOs ‑‑ both living and non‑living ‑‑ is governed by the
same approval process as is discussed above. For experiments dealing
with living GMOs and for which deliberate release and field testing is
part of the research proposal, approval must be sought according to the
Gene Technology Act from the Ministry of the Environment. For research
on non‑living GMOs or those which would be tested in laboratories and
greenhouses, the Ministry of Health and the SNT determine the approval.

It should be emphasized that several members of the scientific community
expressed the idea that Norway cannot afford to be left behind either
the rest of Europe or the rest of the world as others continue to make
advances and discoveries in the field of GMOs. That is an attitude
acknowledged not only by the European Commission but also by quiet but
powerful players within the Norwegian production sector. This researcher
learned of a professor at the Agricultural University whose current
research with lactic acid and microbes includes genetic modification ‑‑
something that is understood but not openly discussed by the dairy
monopoly for fear of bad press and negative consumer reaction. However,
the diary industry continues to support this type of research that will
permit it to be a player in a changing market, if and when that happens.
That having been said, this researcher spoke with scientists who have
made conscious decisions to shy away from the use of GMO techniques in
their research, choosing to work with gene therapy and other traditional
types of biotechnology techniques rather than run the risk and hassles
of confrontation with authorities, the media and public opinion.
However, this is one sector more receptive to GM technology and should
continue to be carefully monitored for changes.

# OUTLOOK FOR THE SALE OF GMOs ON THE NORWEGIAN MARKET

In order to assess the outlook for the sale of GMOs on the Norwegian
market, it is important to differentiate between short‑ and long‑term
potential, as each tells a completely different story. In the immediate
future, increasingly restrictive legislation concerning tracing and
labeling as well as other regulations on zero percent tolerance of
antibiotic resistance genes already in place, making the possibility of
a liberalization of attitudes legally more difficult. The increasing
emphasis upon \"soft\" criteria in the production and labeling process
will also complicate any import potential. Harmonization with the EU ‑‑
in some cases where restrictive Norwegian recommendations have
influenced EU legislation ‑‑ will also limit the liberalization
prospects in the short term. However, in the long term ‑‑ and that may
be for a period of between ten and twenty years in the future ‑‑ the
continuation of restrictive attitudes will likely be tempered by the
growing reality of a world increasingly filled with engineered crops and
a decreasing probability of limiting their introduction, development and
growth into both the Norwegian and the even larger European market. A
sustained long‑term engagement with the scientific community and a
transparent public relations campaign about genetically engineered
products with clear, direct benefit to consumers provided at a lower
price than the traditional product could go a long way to change
Norwegian attitudes and, ultimately, legislation. However, without a
change in legislation, even those Norwegians whose attitudes are
receptive to bioengineered products will be prevented from having access
to them.

While prospects for the short term are very limited, long-term prospects
are more promising and several different strategies could be successful.
The first strategy would involve getting approval for and introducing a
trial, successful product that contains GMO material. This product must
have either or both direct qualitative superiority over an existing
product or a significantly lower price. In a Norwegian radio program
aired two or three summers ago, there was a report from Trondheim on a
test of transgenetic strawberries. Norwegian shoppers were offered the
same quantity of regular and transgenetic strawberries at the same
price. While the report detailed general curiosity about the
bioengineered strawberries, consumers made no purchases. However, when
faced with the direct and personal financial benefit when the price on
the transgenetic strawberries was dropped to half that of their
traditionally grown counterparts, all the cheaper transgenetic
strawberries sold. Norwegians devotion to multi‑functionalism must be
lapt in mind. Thus, inconsistencies apparent in reconciling those
non‑quantifiable attitudes with real temptations for cheaper prices
cloud the prospects for anticipating consumer buying patterns.

The last suggested long term strategy requires the application of
science (and specifically genetic modification) to address the kinds of
problems experienced by Norwegian farmers due to cold climate farming.
If genetic modification could solve daily and seasonal problems by
increasing frost tolerance or shortening the growing season of a
product, particularly if there were to be a price advantage, there might
be a willingness shown by some of the larger and more mechanized farming
operations to apply these techniques.

While none of these strategies is guaranteed to pry open the Norwegian
market to GMOs, each is bound to whittle down the steadfast
determination held against GMOs that is typically found across the
spectrum of Norwegian society. A sustained effort to tackle different
components of Norwegian society in ways that meet their individual
concerns could, particularly in an global environment increasingly
penetrated by genetically modified organisms, prove successful in the
long run.

# SUMMARY OF CONTACTS

The Norwegian Food Safety Authority (Mattilsynet)

Ullevålsveien 76\
0454 Oslo\
Tel: +47-23 21 68 00\
www.mattilsynet.no

Directorate for Nature Management (Direktoratet for naturforvaltning)

Tungasletta 2

7485 Trondheim

Tel: +47 73 58 05 00

www.naturforvaltning.no

Ministry of the Environment (Milj¢verndepartementet)

P.O. Box 8013 Dep 0030

N‑0030 Oslo

Tel: +47 22 24 90 90

www.miljo.no

Ministry of Health (Helsedepartementet)

Postboks 8011 Dep. 0030

N‑0030 Oslo

Tel: +47 22 24 90 90

http://odin.dep.no/hd/engelsk/index‑b‑n‑a.html

# REFERENCE APPENDIX

Document 1: The Act Relating to the Production and Use of Genetically
Modified Organisms (Gene Technology Act) Act No. 38 of 2 April 1993,
published by the Ministry of Environment

Document 2: The Act Relating to the Production and use of Genetically
Modified Organisms (Gene Technology Act), Act No. 38 of 2 April 1993
(den engelske oppdateringen av endringene fra 1996 og 2002 er ikke
gjennongått av autorisert oversetter. Sist endret av Amy 5 mars 2002).

Document 3: Proposition No. 8 to the Odelsting (1992 ‑ 93) Concerning
the Act relating to the production and use of genetically modified
organisms (Gene Technology Act), Official Translation from Norwegian,
published by the Ministry of Environment. (This document preceded the
1993 Gene Technology Act and provides the rationale for the Act.)

Document 4: Regulations Relating to the Transport and Import of
Genetically Modified Organisms, laid down by Royal decree on 13 November
1998 pursuant to section 10, third paragraph, of Act no. 38 of 2 April
1993 relating to the production and use of genetically modified
organisms, the Gene Technnology Act from the Ministry of Environment.

Document 5: Relevante vedtak og forslag fra Stortinget på
genteknologiområdet (in Norwegian) from the Ministry of Environment.

Document 6: Current Developments on GM foods and feeds per 16.05.2001.

Document 7: Circular Regarding the Norwegian Regulations Relating to the
Labelling of Foodstuffs Interim Guidelines on the Labelling of
Genetically Modified Foodstuffs and Food Ingredients, 4 July 1997,
Circular no. 4039, SNT.

Document 8: Retningslinjer for helserisikovurdering av ny mat
(Guidelines), May 1998, SNT.

Document 9: The Norwegian Food Control Authority, A Brief Presentation,
SNT.

Document 10: Omsetning av Genmodifiserte Organismer, Prosedyrer for
behandling av s¢knader fra EU med virkning for E¥S‑området (in
Norwegian), from the Ministry of Environment, 2 revisjon, 26 September
2000 (Procedures for Processing GMO applications from the EU).

Document 11: Genetically Modified Chicory Lines RM3‑3, RM3‑4 and RM3‑6,
approved for marketing pursuant to Council Directive 90/220 EEC, Basis
for the Norwegian Decision to Prohibit Marketing, published in August
2000 by the Directorate for Nature Management

Document 12: Genetically Modified Oilseed Rape Line MS1Bn x RFIBn
approved for marketing pursuant to Council Directive 90/220 EEC, Basis
for the Norwegian Decision to Prohibit Marketing, published in August
2000 by the Directorate for Nature Management

Document 13: Genetically Modified Maize Line Bt176 approved for
marketing pursuant to Council Directive 90/220 EEC, Basis for the
Norwegian Decision to Prohibit Marketing, published in August 2000 by
the Directorate for Nature Management

Document 14: Genetically Modified Vaccine against pseudorabies,
nobi‑porvac aujeszky live, approved for marketing pursuant to Council
Directive 90/220 EEC, Basis for the Norwegian Decision to Prohibit
Marketing, published in August 2000 by the Directorate for Nature
Management

Document 15: Genetically Modified Vaccine against rabies, raboral V‑RG,
approved for marketing pursuant to Council Directive 90/220 EEC, Basis
for the Norwegian Decision to Prohibit Marketing, published in August
2000 by the Directorate for Nature Management

Baerekraft, Samfunnsnytte og Etikk I vurderinger av genmodifiserte
organismer: Operasjoinalisering av begrepene I Genteknologilovens (in
Norwegian), working document concerning guidelines for ethical,
sustainable development and social benefit considerations during the
approval process, published by the Biotechnology Advisory Board.

Document 16: Temahefte/Baerekraft, samfunnsnytte og etikk I vurderinger
av genmodifiserte organismer: Operasjonalisering av begrepene I
Genteknologilovens, Bioteknologinemnda (guidelines for the evaluation of
sustainable development, social benefits and ethics in the approval
process, The Biotechnology Advisory Board).

Document 17: Tillit Til Mat I Kugalskapens Tid, En Komparativ
Kartlegging, med fokus på forbrukertillit og matsikkerhet I Norge,
England og Belgia (in Norwegian). Trust in Food in the Age of Mad Cow?s
Disease, English Summary, Rapport nr. 5‑2000 by Lisbet Berg, published
in October 2000 by SIFO, Statens Institutt for forbruksforskning (The
Consumer Research Council).

Document 18: \"Consumers and Food Safety Policies in the Nordic
Countries,\" by Lisbet Berg and Unni Kjoernes, in Eating Patterns: A Day
in the Lives of Nordic Peoples, Unni Kjoernes, editor. Report 7, 2001.
The National Institute for Consumer Research, Lysaker, Norway.

Document 19: GMO‑mat: Helsemessige konsekvenser ved bruk av
genmodifiserte naeringsmidler og naeringsmiddelingredienser. Innstilling
fra et ekspertutvalg oppnevnt ved kongelig resolusjon 19 januari 2000.
Avgitt til Sosial‑ og helsedepartementet 2 oktober 2000, (in Norwegian)
co‑authored by Askild Holck, MATFORSK.