Required Report - public distribution

**Date:** 8/6/2007

**GAIN Report Number:** GM7034

GM7034

**Germany**

**Biotechnology**

**Annual**

**2007**

**Approved by:**

![](media/image1.wmf)Bobby Richey Jr.

U.S. Embassy Berlin

**Prepared by:**

Dietmar Achilles

**Report Highlights:**

There are signs of progress in the field of biotechnology in crop
production in Germany. A noticeably increasing number of farmers is
showing interest in planting Bt corn varieties. The planting area for Bt
corn in 2007 is estimated at about 2500 ha versus 950 hectares in 2006.
On the other side, NGOs and many politicians are fighting a desperate
battle against the technology. Many politicians claim that research is
ok but commercialization is not needed and not wanted. Amendments are
being considered to the current German law governing field releases of
biotech events and labeling of biotech foods

Includes PSD Changes: No

Includes Trade Matrix: No

Annual Report

Berlin \[GM1\]

\[GM\]

Table of Contents

[**Section I: Executive Summary 3**](#section-i-executive-summary)

[Section II: Biotechnology Trade and Production
3](#section-ii-biotechnology-trade-and-production)

[Commercial Production of Bt corn in Germany
3](#commercial-production-of-bt-corn-in-germany)

[Research on Biotech Crops 4](#research-on-biotech-crops)

[Genetech-free Zones 5](#genetech-free-zones)

[Section III: Biotechnology Policy 5](#section-iii-biotechnology-policy)

[Regulatory Framework 5](#regulatory-framework)

[German Industry Concerns and Requests
6](#german-industry-concerns-and-requests)

[Proposed Changes in the German Genetech and Labeling Laws
6](#proposed-changes-in-the-german-genetech-and-labeling-laws)

[Antibiotic Resistance Marker Genes
7](#antibiotic-resistance-marker-genes)

[Biotech Threshold levels 7](#biotech-threshold-levels)

[Section IV: Marketing Issues 7](#section-iv-marketing-issues)

[Unapproved Biotech Events 8](#unapproved-biotech-events)

[Testing for Biotech Events 9](#testing-for-biotech-events)

[NGO Activities 9](#ngo-activities)

[Cultivation Restriction for MON810 corn
10](#cultivation-restriction-for-mon810-corn)

[Section V: Capacity Building and Outreach
10](#section-v-capacity-building-and-outreach)

[Informational Visits to the U.S. and Speaker Programs
10](#informational-visits-to-the-u.s.-and-speaker-programs)

[White Biotechnology 10](#white-biotechnology)

[Biotech Varieties for Energy Crops
10](#biotech-varieties-for-energy-crops)

[Section VI: Reference Material 11](#section-vi-reference-material)

# Section I: Executive Summary

An increasing number of German farmers are expressing interest in
planting Bt corn varieties since they have a problem with the corn borer
and the biotech industry offers them a solution with a wide range of
advantages. In 2007, about 2,700 hectares were planted to Bt corn, which
is an increase of about 1,600 hectares over 2006. However, research,
production, and consumption of plants and plant products resulting from
genetic enhancement of crops are still controversial issues in Germany.
The scientific community and members of the conservative political
parties have been generally supportive of biotechnology. However, they
are counter-balanced by the Green Party, the Social Democrats and
environment/consumer-related NGOs, which are very proactive and vocal in
expressing their concerns about this technology.

Biotech opponents and skeptics continue to refer to consumer opinion
polls, which show that about 70 to 80 percent of the German population
are concerned about perceived risks resulting from the planting and
consumption of biotech crops. Interestingly consumers predominantly
refer to health risks while organized opponents prefer to refer to
environmental risks resulting from the release to the environment. Small
farmers associations claim that coexistence of biotech crops and
non-biotech crops is impossible. In contrast, advantages resulting from
biotech crops are unfortunately not yet well known among the majority of
farmers.

The political and the industry focus is currently on intensifying
efforts in the field of white biotechnology (basically the use of
organic matter such as enzymes, bacteria, and plant tissue for
industrial purposes, excluding open field planting), providing
opportunities in the field of environmental protection, cost reducing
chemical processes, improved utilization of available limited resources,
and waste reduction. In Germany, white biotechnology is perceived
positively, in part because Germans believe it does not create
unmanageable risks. Another field of interest to the German biotech
industry could be the production of renewable fuels and other products
for non-food use. The industry perceives that such products will receive
a higher level of acceptance since they do not enter the food chain.

In Germany, the regulatory framework for biotech products is set by EU
regulations and directives (see GAIN report E35091), which in their
current form are generally supported by the majority of German
politicians. The European Commission however decided that co-existence
rules would be determined and set by the individual Member States.
Currently the German government is in the process of amending its
genetech law to make it marginally more user-friendly and to define good
management practices for biotech crops. An amendment of the long
disputed liability regulations is not foreseen in the current draft
version.

Currently, there are hardly any biotech-labeled food products found on
German retail shelves. The retail business refrains from stocking
biotech labeled products because they fear that anti-biotech activists
may demonstrate in or outside their stores. Consolidation and
competition in the German retail market is very intense and the prime
marketing tool for the retailers is price. Since profit margins are very
narrow in Germany, retailers try to avoid having any negative
impressions of their products in the market.

# Section II: Biotechnology Trade and Production

## 

## Commercial Production of Bt corn in Germany

Despite political opposition from the Green Party and to a somewhat
lesser extend by the Social Democrats Party and lack of support by
leading German farmers associations, about 70 farmers planted an
estimated 2,700 hectares (3770 acres) of biotech corn varieties on a
commercial basis in 2007. With almost three times as much area as in
2006, there is growing interest in the technology by German farmers.
Originally at the beginning of 2007, farmers had registered about 3,250
hectares for Bt corn planting. Farmers registered more area for biotech
production in order to maintain some flexibility until the actual
planting takes place. When the planting work has been finished they have
to report the actually planted fields to the field register.

Currently the only commercial biotech crop in Germany is corn and the
only biotech trait approved for production is insect tolerance. Not all
of the German corn production regions are affected by European corn
borer infestation and the root worm has not yet arrived on German farm
land. Current farmers' interest in Bt corn planting is predominantly in
regions with large farm sizes, mainly in the eastern third of the
country. Farmers in Southwest Germany are reportedly less interested in
Bt varieties since that region is also a major corn seed production area
and these farmers wish to ensure that their corn seeds are free of
biotech presence.

Since 2003, genetech varieties in Germany have been using the biotech
trait MON810. Previously, varieties containing the trait Bt176 were
used. Since 2005, five corn varieties have been registered with the
German Federal Seeds Register and may be planted to an unlimited area.

In 2004, an extensive coexistence research program accompanied the
planting of about 300 hectares of Bt corn. The goal of this monitoring
program, sponsored by federal research and state funds, was to determine
the extent of the flow of corn pollen into neighboring fields. The
industry intended to prove that biotech corn does not create a
considerable problem for coexistence with non-biotech varieties. The
result of the tests showed that biotech content in corn samples taken
more than 20 meters from the biotech plants were below 0.9 percent, the
threshold which constitutes the need for labeling the harvested product
as biotech. See also
http://www.transgen.de/pdf/erprobungsanbau/ergebnisse_sonderdruck.pdf

To avoid any kind of liability problems for the production of biotech
corn in 2005 and 2006, the German feed milling and grain trading company
Maerka Kraftfutter made the public promise to purchase the corn from
fields neighboring biotech corn fields up to a distance of 500 meters.
The purchase price will be equivalent to normal market prices in the
region, regardless of biotech content. Maerka also markets and processes
domestically harvested biotech corn into commercial feed compounds and
labels these products as 'contains biotech corn'.

## 

## Research on Biotech Crops

In Germany research on biotech crops concentrates primarily on potatoes.
However field releases are also approved for corn, peas, winter wheat,
winter barley, rapeseed, apples and soybeans. A list of these approved
field trial releases is found on following web page:

http://www.bvl-berlin.de/cgi/lasso/fsl/liste_d.lasso?-database=SNIF&-response=&-table=www_summary&-sortField=Aktenzeichen%20RKI&-sortOrder=ascending&-op=bw&land=Deutschland&-maxRecords=20&-search&-skiprecords=120

Field releases for corn are mainly for the testing of stacked trait
varieties. Research on potatoes covers a variety of issues, such as
altering the starch composition and fungus resistance.

Applications for field releases during the past several years
concentrated on potatoes and corn. These are crops, which have a low
out-crossing risk in terms of coexistence. The biotech industry has
pretty much stopped or reduced field studies in Germany with higher
out-crossing potential, such as rapeseed, which have the potential to
create a major controversy with biotech opponents. Despite the efforts
to promote consumer, processor, and environment friendly biotech traits,
anti-biotech activists increasingly focus their destructive efforts on
test fields.

## 

## Genetech-free Zones

Aside from the commercial production and research areas for biotech
crops, groups of German farmers have declared about 140 regions in
Germany as biotech-free zones (93 regions in 2006). The total area
covered by these biotech-free zones amounts to about 1.55 million
hectares (861,000 hectares in 2006) with 27,500 participating farmers. A
large number of these regions are located in Bavaria and are primarily
composed of grassland for dairy production. These zones are formed by
the voluntary agreement of farmers to not plant biotech crops in the
particular region. In part these declarations are used for tourism
purposes. Other non-biotech regions were initiated by organic farmers.
There is no legal enforcement mechanism connected to this declaration
that would prevent a farmer from growing biotech plants. Also the
Christian churches are an active NGO opposing genetechnology on
church-owned land.

See: <http://www.gentechnikfreie-regionen.de/>

## 

# Section III: Biotechnology Policy

# 

Leadership for biotechnology policy in Germany rests with the Federal
Ministry for Food, Agriculture and Consumer Protection (BMELV). However,
the Ministries of Economics, Health, Research and Environment are also
involved in the opinion and decision-making process and need to approve
Germany's voting decision in EU committees and councils. This split of
responsibility also applies to Germany's role in the Biosafety and
Biodiversity committees. The German regulatory offices for biotech
authorization and risk assessment are under the political leadership and
supervision of BMELV.

## 

The willingness to promote or at least tolerate the presence of biotech
foods and feeds and the planting of biotech crops is highly dependent on
the political leadership of BMELV. In many public statements, Minister
Seehofer, BMELV, has expressed his support for intensified research on
green biotech but is still extremely reluctant to also promote the
planting of biotech crops.

## Regulatory Framework

The regulatory framework for biotechnology is set by EU regulations and
directives. While regulations directly apply in all EU member countries,
directives have to be transferred and incorporated into national laws.
This incorporation process requires that national laws have to be
crafted or existing laws need to be amended accordingly. Directives
provide the opportunity for member countries to exercise some discretion
and strengthen or weaken the EU requirement without altering the basic
scope of the EU directive.

The German government took advantage of this discretion while crafting
its national genetech law in 1998. In particular, rules about liability,
coexistence, and a public register for fields planted to biotech crops
were originally crafted in a way to discourage farmers and researcher
from growing and developing biotech events in Germany.

Also, under separate regulations Germany allowed beginning in 1998
products to be labeled as "without genetechnology". This label currently
may be used for products derived from conventional seed varieties and
from animals, which were not fed with biotech containing feedstuffs.
Also the use of biotech derived feed additives, enzymes and medicine is
not permitted. A specific threshold level for adventitious and
unavoidable presence of biotechs is not established in the regulation.
The 'without genetechnology' label has not been used often during the
past eight years. Additionally, the 'without genetechnology' label may
not be used for products, for which no varieties have yet been
genetically engineered worldwide, such as oranges or basmati rice among
others.

## German Industry Concerns and Requests

The German biotech industry and plant breeders have expressed strong
concern for a number of years about the current regulations. The
industry has requested to change the access procedures to the **biotech
field register**. The current version of the register is accessible to
everyone through the internet. The industry would like some oversight to
ensure that access to the register is not being used to implement field
destructions. It was proposed that the information for the general
public should only reveal information about the sub-local district where
the field is located.

Another point of clarification that the industry has sought was the
**liability regulation**. The industry requested that only the
mercantile depreciation of the harvested crop, which got in touch with
biotech traits, should be the basis for a possible compensation claim.
Additionally, private contracts detailing that an organic crop is
completely free of biotech traces should not qualify for compensation
demands.

## Proposed Changes in the German Genetech and Labeling Laws

Despite the change in the German government in November 2005 from a
Social Democrats (SPD) and Green Party coalition to a more business
oriented and more conservative coalition of the Christian Democrats and
the Social Democrats, the opposition in the general public and among the
majority of parliamentarians against biotechnology in plant production
has not changed noticeably. Many of the SPD parliamentarians are now
taking the position of the Green party and strongly oppose biotechnology
in crop production using 'Green' arguments. The base argument is that
biotech crops are not sufficiently researched and that they might cause
a hazard to the environment once released.

However, the 2005 coalition contract between the Christian Democrats
Party and the Social Democrats states that the new government is
generally supportive of research in biotechnology and wishes to
guarantee fair opportunities for the production of conventional,
organic, and biotech seeds. To implement this pledge the German
government released a strategy paper in February 2007 for an amendment
to the German Genetech law. The paper stated that it is the intent of
the government to promote research and commercialization of biotech
crops. This paper discussed several areas where amendments might be
considered to the current genetech law including: coexistence, liability
and the field register. After substantial interagency discussion, a
compromise proposal was sent to the German Bundestag which, if pass and
implemented, will only marginally improve the prospects for introducing
biotech events in Germany.

The most controversial portion of the proposed rules is the required
minimum distance between biotech fields and fields planted to
conventional or organic varieties. The intended protection distance is
proposed at 150 meters to conventional corn varieties and 300 meters to
organic corn. The draft regulation also proposes some flexibility if
neighboring farmers agree on shorter distances. The option for
coverseeds as an alternative for the distance requirement is not
foreseen in the current draft regulation. BMELV claims that such cover
plantings are not effective.

The coalition compromise for the genetech law amendment foresees that
the existing high level of transparency of the biotech field register
will remain in place despite an increasing number of field destructions.
Also the strict liability rules are not intended to be made more
practical for farmers and researchers.

Parliamentary action on these proposed amendments is expect later in
2007.

Separately, Minister Seehofer has proposed an amendment of the 'without
genetechnology' labeling law to ease the conditions for the use of the
'without genetechnology' label on food and feed stuffs. As with the
current regulation, food and feedstuffs, including milk and dairy
products, eggs and meat and processed products containing such
ingredients, could apply this label if the ingredients originate from
animals, which were fed with non-biotech feeds. However, the new
'without genetechnology\' labeling proposal, unlike the current
regulation, would allow the use of feed additives and enzymes and
medicine derived from biotechnology. With this move the government
intends to counter growing criticism that animals fed with biotech crops
do not need to be labeled as biotech livestock products. It is argued
that the eased 'without gentechnology' label would provide the consumer
with an improved option to chose. Some agricultural industry groups have
challenged this proposal indicating that it will likely confuse
consumers rather than help in making informed choices.

## Antibiotic Resistance Marker Genes

The biotech trait Bt176, has been banned for use as a seed in Germany.
The German government argues that the presence of an antibiotic
resistance marker gene in Bt176 has the potential to pose a threat to
public health and to the environment. Although the German research
community disagrees with this negative evaluation, Germany voted in
Brussels against lifting the ban for Bt176.

## 

## Biotech Threshold levels

The EU labeling directive sets a labeling threshold for unavoidable
adventitious presence of EU-approved biotech events in food and feed at
0.9 percent. This also applies to organic products. A threshold level
for adventitious biotech content in seeds has not yet been set, which
actually translates into a zero tolerance for biotech content in
conventional or organic seeds. The German government has not developed a
position about their preferred biotech threshold level. The biotech
strategy paper of February 2007 says that it should be as low as
possible but still practical for the seeds industry. A number has not
been mentioned.

If traces of EU approved biotech events are found in seeds, these seeds
need to be labeled as containing biotech or these seeds cannot be
marketed. According to EU rules, also fields adventitiously planted with
these seeds need to be recorded in the biotech field register. Since
this is not possible because the farmer normally does not know about the
adventitious biotech presence in his seeds the regional supervising
authorities usually require that these crops be destroyed. Not yet EU
approved biotech events are totally prohibited in seeds.

# Section IV: Marketing Issues

Biotechnology in crop production is a highly contentious issue in
Germany as in most other EU countries. Opinion polls provide widely
varying results. Opponents to biotechnology often point to polling
results that show that about 70 percent of the German population is in
opposition to this technology. Other polls, if questions are asked
differently, come to the result that about 83 percent of the people
interviewed did not see any problem in biotech-labeled products being on
food retail shelves.

Recent polls amongst farmers in northern and eastern Germany revealed
that farmers operating large farms are quite interested in using the new
technology. In Mecklenburg-Vorpommern, a northeastern German state, 35
percent of the questioned farmers said that they would consider planting
biotech crops, 43 percent rejected the idea and 19 percent were
undecided. About 47 percent of the farmers operating farms of more than
1,000 hectares (2,500 acres) support the technology. Interestingly, 48
percent of the farmers expect that biotech varieties will be the future
in plant breeding. Only 22 percent believe that biotech crops will not
succeed.

Since the implementation of EU labeling regulations for biotech foods in
April 2004, an NGO reportedly found a number of food items on the German
retail shelves containing biotech or biotech-derived products, which in
most cases were incorrectly labeled. Activists have also visited
restaurants and take-away food places where they found biotech soyoil,
which was not labeled on the menu. The activists 'convinced' the
restaurant owners and the retailers to switch to other non-biotech
products or take the products off the shelf. The products found were
imported candy bars containing biotech cornstarch and soybean products,
such as soyoil, tofu, and bean sprouts.

To avoid biotech labeling of processed food items, the German food
industry switched from biotech-origin ingredients to non-biotech
alternatives. This substitution was most prevalent for soybean oil,
which was replaced with European rapeseed oil. Because of rising demand
for rapeseed oil in biodiesel production, rapeseed oil has become the
most expensive vegetable oil in the EU. Even sunflower oil is lower
priced than rapeseed oil. Due to the relatively high cost for rapeseed
oil, the domestic food processing industry has begun to reconsider
whether they should return to use lower-priced soybean oil, which would
require a biotech label. However, such a step needs to be carefully
researched and negotiated with the retail sector.

Food sales in Germany are predominantly driven by price. As a result,
generic products, which are generally more affordable, are increasingly
replacing branded products. In view of this intense competition, retail
companies wish to avoid placing biotech labeled products on their
shelves.

## Unapproved Biotech Events

On several occasions in the past years, unauthorized biotech products
had been detected on the German retail market and at the ports of entry.
Most notable papayas, longgrain rice and corn gluten feed. Competent
authorities forced the importer of the papayas to destroy these
products, which came from genetically modified plants that were bred to
be disease resistant. Since January 2005, all incoming papaya shipments
from Hawaii must be tested for biotech presence before they can be
marketed. The rice containing marginal traces of an unapproved biotech
trait had to be taken from the shelf. This action cost the involved rice
mills millions of Euros although the European food safety authorities
had frequently confirmed that the rice is safe for human consumption.
Domestic rice millers have switched to alternative suppliers from
Uruguay, Thailand and other countries. However, the rice millers have
indicated an interest in returning to the U.S. rice market when they
have the assurance that the imported rice meets EU approval.

The presence of traces of the biotech event Herculex RW in corn gluten
feed (CGF) is also causing problems for German / European feed
importers. German feed processors complain that they cannot obtain any
CGF or distillers dried grain (DDG) from ethanol production in the
United States, which reportedly sells at significantly lower prices than
European feed grains. International traders seem to hesitate to take the
risk to handle corn based feeds, which might contain traces of not yet
approved biotech events.

## Testing for Biotech Events

Germany has a decentralized system for testing and controlling the
illegal entry of biotech products into Germany. The control authority
with the competence to ensure that no unauthorized biotech product
enters the German retail market is with the 16 German states (Laender).
The Laender establish their own monitoring and sampling plans. Since the
experts know what kind of products potentially contain biotech events
they specifically sample for these products. Sampling is primarily done
at the wholesale and the processing level.

## 

## NGO Activities

The German green-based NGOs have undertaken intensive efforts to keep
biotech crops out of the fields and biotech food products off the
shelves. NGOs met with German food processors and retailers to request
commitments to keep their retail shelves and production plants
biotech-free. Reportedly the majority of food processors did not sign
such commitments. Companies committing themselves to avoid biotechs are
predominantly those dealing with organic products. Since the German food
processing industry has replaced biotech ingredients with other
non-biotech products, such as EU rapeseed oil, NGOs have recently been
focusing on the dairy industry. NGOs would like to obtain commitments
from the dairy companies that they will require their supplying farmers
not to use biotech containing feeds. To ensure that small restaurant and
catering places are not using biotech vegetable oil NGOs send around
biotech scouts requesting information from the restaurants what kind of
vegetable oils they are using.

Due to the long list of field destructions the seeds and biotech
industry as well as research institutes lost their patience with the
'activists' and now take them to court with the intent to claim
financial compensation for the complete damage, not only the value of
the lost crop. Damages can easily add up to several million dollars.

The most recent biotech discrediting approach of NGOs is a study where
they took samples from many different corn plants off the fields and
tested them for the concentration level of the Bacillus thuringensis
toxin. The finding that the toxin level can vary significantly from
plant to plant is used as an argument that a targeted application
against the corn borer is not possible. Reports like this are welcome by
the community of biotech opponents.

Another venue of biotech criticism are recent legal claims of beekeepers
against biotech farmers claiming that biotech corn contaminates the
honey and makes the honey a biotech product which is not approved in the
EU. Final court rulings are still outstanding.

Field destructions increasingly focus on research plots and variety
tests. Opponents are aware that these actions can have great impact on
the future of biotech crop development in Europe. In 2006, 26 field
destructions were recorded in Germany. This compares to only 7 cases in
2005. During the short 2007 field season, already two fields have been
destroyed and demonstrations have been announced for mid July.

Christian churches have taken a strong position against biotechnology in
plant production. This results in the condition in land rental contracts
the operating farmers commits himself not to grow any biotech crops on
church owned land or to refrain totally from biotech crops if only part
of his land is rented from the churches.

## Cultivation Restriction for MON810 corn

In late April 2007, BVL released an order against Monsanto to ban the
sales of MON810 corn variety seeds until Monsanto provides an extended
plan detailing how potential environmental impacts are to be monitored.
The order claims that new information or new interpretation of existing
material justified cause for the implementation of an extended
monitoring plan focusing on potential impact on the environment. To date
no final monitoring plan for MON810 has been accepted by BVL and it is
unclear what the impact for the 2008 planting will be.

The order sends out a signal to the biotech skeptics that there might be
something problematic with the new seeds and more research is needed
before biotech crops can be planted. Interestingly, the German competent
authority Bundesamt fuer Risikobewertung (Federal Office for Risk
Assessment) came to the result that none of the studies referenced in
the order have proven that MON810 has potential for being harmful to the
environment.

# Section V: Capacity Building and Outreach

## Informational Visits to the U.S. and Speaker Programs

Since 1997, the FAS Office in Germany has sent numerous groups of policy
makers, scientists, representatives of consumer organizations, farm
leaders, journalists and other interested parties to the United States
to learn about the U.S. system for regulating gene technology.

In addition to these trips to the United States, FAS Germany has
organized a number of speaker programs for U.S. biotech scientists and
farmers to inform interested parties in Germany about the experience in
the U.S. with biotech crops. The Agricultural Minister Counselor of the
FAS Office in Germany participated in a number of podium discussions and
seminars on biotechnology.

Most helpful for the success of biotech crops in Germany appears to be
farmer to farmer contacts on national and international levels. On June
16, 2006, 23 farmers from Northern Germany formed a Working Group of
Innovative Farmers (InnoPlanta AGIL) -- www.innoplanta.de. These farmers
are convinced that this technology will be a key technology of the
21^st^ century and play a growing role in world food production,
renewables development, energy, health, and environment. Most welcome
for German farmers is also the exchange of experience with knowledgeable
North American farmers because this tells them that there are not only
the promises of the offering seed companies but also the positive
results for the farmers and the environment.

## White Biotechnology

During the past year, politicians of almost all leading German political
parties expressed their support for white biotechnology. Even the Green
Party claims that this is a field of research and development, which
provides great opportunities to the German economy without expressing
noticeable risk to the environment and to health. As a result, this
branch of the German biotech industry seems to be faring better than
green biotechnology.

## Biotech Varieties for Energy Crops

The recent rise in commodity prices have generated second thoughts about
the 'need' for biotech varieties. It is frequently heard that the
application of biotech crops in the production of crops for industrial
uses such as biofuels could be tolerated. However, this discussion is
still at initialy stages.

# Section VI: Reference Material

  ---------- ------------ ------------------------------------------------
  Report No. Date         Title

  GM7033     07/27/2007   Biotech Law Coalition Compromise

  GM7017     03/30/2007   Green Party Campaign against Biotech

  GM7012     03/16/2007   Lawsuit against Biotech Wheat Field Test

  GM7010     03/16/2007   Green Party Steps up Anti-Biotech Rhetoric

  GM7008     03/07/2007   Proposal for German Genetech Law Amendment

  GM7006     02/16/2007   Biotech Corn Planting Intentions for 2007

  GM7003     01/23/2007   Biotech Outreach to Germany

  GM6047     12/05/2006   German Genetech Law Amendment Proposal

  GM6046     11/28/2006   Biotech Wheat Field Test Approved

  GM6042     11/07/2006   Biotech Situation

  GM6032     08/25/2006   LLRice601 Reaction in Germany

  GM6021     06/26/2006   Biotech Annual
  ---------- ------------ ------------------------------------------------