EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 15.4.2011 
SEC(2011) 481 final 
  
COMMISSION STAFF WORKING PAPER  
Accompanying document to the 
 
REPORT FROM THE COMMISSION TO  THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 
 
on socio-economic implications of GMO cu ltivation on the basis of Member States 
contributions, as requested by the Co nclusions of the Environment Council  
of December 2008  
{COM(2011) 214 final} 
 
EN 2   EN COMMISSION STAFF WORKING PAPER  
Accompanying document to the 
 
REPORT FROM THE COMMISSION TO  THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 
 
on socio-economic implications of GMO cu ltivation on the basis of Member States 
contributions, as requested by the Co nclusions of the Environment Council  
of December 2008  
The Directive 2001/181 on the deliberate release of geneti cally modified organisms (GMOs) 
into the environment provides th at the Commission should, after 3 years, provide a report on 
the implementation of the Directive includ ing an assessment of the socio-economic 
implications of deliberate releases and placing on the market of GMOs. When submitting its 
2004 report, the Commission noted that there was not sufficient experience to make such an 
assessment. 
In December 2008, the Council invited the Commission and Member States to work again on 
this question. Therefore the Commission launche d a consultation of the Member States on the 
socio-economic implications of GMO cultivation via a questionnaire. 
A report was prepared by the Commission to summarise and analyse the content of the 
answers of the Member States and stakeholde rs to the questionnaire.  This Commission staff 
working paper is accompanying the above-men tioned report, and contains the following: 
– The questionnaire prepared by the Commission about the socio-economic implications of 
the placing on the market of GMOs for cultivation (Annex 1). 
– Non-exhaustive summaries of individual cont ributions of the 25 Member States which 
answered to the questionnaire. These summaries have been reviewed and validated by the Member States, and do not enga ge the Commission. (Annex 2). 
– A review of the available peer-reviewed li terature worldwide on the socio-economic 
dimensions of cultivation of GMOs. (Annex 3) 
                                                
 
1 OJ L 106, 17.4.2001, p.1. 
 
EN 3   EN ANNEX 1  
Questionnaire about the socio-economic implications of the placing on the 
market of GMOs for cultivation 
A – Introduction note 
Article 31.7 (d) of Directive 2001/18/EC1 provides that the Commi ssion should send to the 
European Parliament and the Council a specif ic report on the operation of the Directive 
including inter alia an assessm ent of the socio-economic impli cations of deliberate releases 
and placing on the market of GMOs. These impli cations are defined in Recital (62) of the 
Directive as the socio-economic advantages an d disadvantages of each category of GMOs 
authorised for placing on the market, which ta ke due account of the interest of farmers and 
consumers. In its 2004 report, the Commission not ed that there was no sufficient experience 
to make such an assessment (the Directive became fully applicable as of 17 October 2002 and 
several Member States had not transposed yet so only little experience of its implementation 
was available).  
Moreover Regulation (EC) No 1829/2003, its arti cles 7 and 19, asks the Commission to 
submit a draft of the authorisation decision taki ng into account, together with the opinion of 
the Authority in charge of the scientific assessment, "other legitimate factors relevant to the 
matter under consideration".  
At its meeting on 4 December 2008, the Enviro nment Council adopted conclusions on GMOs 
mentioning among other things the appraisal of socio-economic benefits and risks of placing 
GMOs on the European market for cultivation. In  particular the Council conclusions indicated 
the following:   
The Council:  7. Points out that under Regulation 1829/2003 it is  possible, under certain conditions and 
as part of a case by case examination, for legitimate factors sp ecific to the GMO 
assessed to be taken into account in the risk  management process which follows the risk 
assessment. The risk assessment takes a ccount of the environment and human and 
animal health. Points out that under Direct ive 2001/18/EC, the Commission is to submit 
a specific report on the implementation of the Directive, including an assessment, inter alia, of socio-economic implications of delib erate releases and placing on the market of 
GMO. 
Invites the Member States to collect a nd exchange relevant information on socio-
economic implications of th e placing on the market of GMOs including socio-economic 
benefits and risks and agronomic sust ainability, by January 2010. INVITES the 
Commission to submit to the European Parl iament and to the Council the report based 
information provided by the Member States  by June 2010 for due consideration and 
further discussions. 
                                                
 
1 Directive 2001/18/EC of the European Parliament and of the Council of 12 March 2001 on the 
deliberate release into the environment of genetically modified organisms and repealing Council 
Directive 90/220/EEC 
 
EN 4   EN This possible consideration of socio-economic factors in the author isation of GMOs for 
cultivation has also been raised by several Memb er States in the Environment and Agriculture 
Councils of the last months2. 
In order to respond to the invitation of the Council conclusions of 4 December 2008 and to the 
requirements of the legislation, the Commis sion invites Member States to submit all 
information they would consider releva nt by January 2010 at the very latest.  
In order to help Member Stat es in structuring their respons es, the Commission drafted a non 
exhaustive list of areas and stakeholders wh ich could be concerned. In addition, for each of 
these categories, we have introduced in the a nnex a list of leading questions which could be 
used where considered appropriate.  
When preparing their contribution Me mber States are invited to report ex post  on the socio-
economic impact of GMOs that have been approved in the EU and cultivat ed in their territory. 
Additionally, Member States are also invited to assess ex ante the possible implications of 
GMOs of currently pending approvals as well as those which are under development 
according to the best of their knowledge. One possibl e source of information in that respect is 
that recent report produced by the Joint Research Centre titled "The global pipeline of new 
GM crops" (available at http://ipts.jrc.ec.europa.eu ).  
The submissions must be as explicit and info rmative as possible and supported by evidence 
and data. When feasible, the socio-economic analysis – be it ex post  or ex ante  – should be 
quantified. In case documents are attached, they  should be accompanied by a summary of the 
relevant part and a specifi cation about the argument or topic that is being defended. 
Where stakeholders are consulted at national level (e.g. farmers and consumers), we would 
appreciate it if their responses would be incorporated in your submission in an aggregated 
fashion. The list of stakeholders  consulted, as well as any other pertinent information, may 
indeed be attached to the questionnaire.  
Please note that the contributions must only deal  with "socio-economic implications of the 
placing on the market of GMOs including socio- economic benefits and risks and agronomic 
sustainability" for each category of GMOs. Th ese contributions should cover cultivation of 
GMOs and placing on the market of GM seeds.  
If you choose to fill in the annexed questionnai re, please consider th at answers should be 
broken down by the purpose of the genetic modificat ion (herbicide tolerant , insect resistance, 
etc) if this affects the content of the responses.  
DEADLINE FOR CONTRIBUTIONS: January 2010 
                                                 
2 Environment Council of 2 March 2009, Agriculture Council of 23 March 2009 and Environment 
Council of 25 June 2009 
 
EN 5   EN B - Contact Details 
Member State:   
Name of ministry/ies contact Person/s:  
Contact Address:  
Telephone:       Fax:  
E-mail Address  
 
C – Areas and stakeholders on which  
Member States are invited to comment 
For each question, answers should be broken down:  
- by the purpose of the genetic modification if this affects the content of the responses, 
- between ex ante and ex post considerations. 
1. - Economic and social implications  
Upstream  1.1. Farmers 
For each question, answers can be broken down by the range of relevant agricultural 
stakeholders farmers  
- farmers cultivating GM crops;  - and/or conventional crops; - and/or organic crops; - beekeepers; - seed producers producing GM seeds; - seed producers producing conventional seeds; - seed producers producing organic seeds; … 
Has GMO cultivation an impact regarding the following topics? If so, which one?  
- farmers' revenues (output pri ces and agricultural yields); 
 
EN 6   EN - farmers' production costs; 
- labour flexibility; - quality of the harv est (e.g.mycotoxines); 
- cost of alternative pest a nd/or weed control programmes; 
- price discrimination between GM and non-GM harvest;  - availability of seeds and seed prices; - dependence on the seed industry;  
- farmers' privilege (as established by Article 14 of Regulat ion (EC) No 2100/94 on 
Community plant variety rights) to use farm-saved seeds; 
- the use of agriculture input s: plant protection products, fe rtilisers, water and energy  
resources; 
- health of labour (possible changes in  the use of plant protection products); 
- farming practices, such as  coexistence measures and clustering of GMO and/or non-
GMO production; 
- cost of coexistence measures; - conflicts between neighbouring farmers or  between farmers and other neighbours  
- labour allocation- in surance obligations; 
- opportunities to sell the ha rvest due to labelling; 
- communication or organisation between the farmers; - farmer training; - beekeeping industry.  
Any other impacts you would like to mention:  
1.2. Seed industry 
For each question, answers can be broken down  by the range of relevant stakeholders, 
including:  
 -  plant breeders; 
- multiplying companies; - seed producing farmers;  - seed distributors; 
 
EN 7   EN And/or: 
- GM seeds; - conventional seeds; - organic seeds; 
And/or:  - industrial / arable crops;  - vegetable crops… 
Has GMO cultivation an impact regarding the following topics? If so, which one? 
- employment, turn over, profits;  - the production of seeds (easiness/difficulty to find seed producers, easiness/difficulty 
to find areas to produce these seeds…); 
- marketing of seeds; - the protection of plant breeders rights; - the protection of plant genetic resources. 
Does the marketing of GM seeds have an impact  on the seed industry an d its structure in the 
EU (size of companies, business concentr ation, competition policy)? Please specify per 
sector. 
 - for plant breeders; 
 - for seed multiplication; 
 - for seed producers;  - for the availability of c onventional and organic seeds; 
 - creation/suppression of barriers for new suppliers;   - market segmentation. Any other impact you would like to mention: 
Downstream 
1.3. Consumers 
Has GMO cultivation any impact regarding the following topics? If so, which one? 
 - consumer choice (regarding qua lity and diversity of products); 
 - the price of the goods; 
 
EN 8   EN  - consumer information and protection; 
Any other impact you would like to mention: 
1.4. Cooperatives and grain handling companies 
Has GMO cultivation any impact regarding the following topics? If so, which one?  
- work organisation; - handling and storage; - transport; - administrative requirements on busin ess or administrative complexity. 
Any other impact you would like to mention: 
1.5. Food and feed industry  
Has GMO cultivation any impact regarding the following topics? If so, which one? 
- range of products on offer; - employment, turn over, profits; - work organisation; - crop handling (drying, storage, transport, processing, etc...); 
- administrative requirements on business or administrative complexity;  
Any other impact you would like to mention: 
1.6. Transport companies 
Has GMO cultivation any impact regarding carrie rs (insurance, cleaning,  separate lines...)? If 
so, which one? 
1.7. Insurance companies 
Does the GMO cultivation have any impact regarding insurance companies (e.g. in terms of 
developing new products)? If so, which one? 
1.8. Laboratories 
Has GMO cultivation any impact regarding the following topics? If so, which one?  
- employment, turn over, profits; - feasibility of analyses; - time necessary to provide the results; 
 
EN 9   EN - prices of the analyses. 
Any other impact you would like to mention: 
1.9. Innovation and research 
Do GMO cultivation and the technology spill over have an impact on the following topics? If 
so, which one? 
- investment in plant research, number of patents held by European organisations 
(public or private bodies); 
- investment in research in minor crops; - employment in the R&D centres in the EU; - use of non-GM modern breeding techni ques (e.g. identifica tion of molecular 
markers); 
- access to genetic resources; - access to new knowledge (molecular marker s, use of new varieties in breeding 
programmes, etc.). 
1.10. Public administration  
Has GMO cultivation any impact regarding the actions of the national public administrations 
and the necessary budget (nati onal and local level) for exam ple policing and enforcement 
costs    
Any other impact you would like to mention: 
Economic context 
1.11. Internal market 
Does the placing on the market of GMO seeds ha ve an impact on the functioning of the EU 
internal market on seeds? If so, which one?    
Does it have an impact on the internal markets for services (if so which impact and which 
services), for agriculture products and on workers' mobility? If so, which one? 
Does GMO cultivation have an impact on monopolies? If so, which ones 
(emergence/disappearance)?  
Does it provoke cross-border investment flow s (including relocation of economic activity)? 
Any other impact you would like to mention: 
 
EN 10   EN 1.12. Specific regions and sectors 
Answers can be broken down on the purpose of  the level (national, regional, local) and 
according to region. 
Has GMO cultivation any regional and local impact  in those regions regarding the following 
topics. If so, which one?   
 - agriculture incomes; 
- farms' size;  
 - the farm production practices (e.g. in crease or decrease of monoculture); 
 - the reputation regarding other commerc ial activities of the region/localities. 
Any other impact you would like to mention: 
2. - Agronomic sustainability  
2.1 Agricultural inputs 
Does the cultivation of EU approved GMOs for cultivation have an impact regarding the use 
of pesticides against target in sect pests (i.e. corn borer)?  
Does the placing on the market of GMOs have an impact, and if so which ones, regarding the 
use of pesticides or/and on the patter ns of use of chem ical herbicides? 
2.2. Biodiversity, flora, fauna and landscapes (o ther impacts than the ones considered in 
the environmental risk assessment carried  out under Directive 2001/18 and Regulation 
(EC) No 1829/2003)  
Does the cultivation of EU approved GMOs ha ve an impact regarding the number of non 
agriculture species/varieties? 
Does GMO cultivation have an impact on agricu lture diversity (number of plant varieties 
available, agriculture species, etc?) 
Does GMO cultivation have an impact , and if so which one, regarding:  
- protected or endangered species; - their habitats; - ecologically sensitive areas; 
Does GMO cultivation have an impact , and if so which one, regarding:  
- migration routes;  - ecological corridors;  - buffer zones. 
 
EN 11   EN Does GMO cultivation have an impact , and if so which one, regarding:  
- biodiversity;  - flora;  - fauna;  - landscapes. 
Any other impacts you would like to mention: 
2.3. Renewable or non-renewable resources 
Does the placing on the market of  GMOs have an impact, if so  which ones, regarding the use 
of renewable resources (water, soil…)? 
Does the placing on the market of  GMOs have an impact, if so  which ones, regarding the use 
of non-renewable resources? 
Any other impacts you would like to mention: 
2.4. Climate 
Does GMO cultivation have an impact regarding our ability to mitigate (other than by 
possibly reducing CO2 emissions from fuel co mbustion – see next section) and adapt to 
climate change? If so, which ones? 
Any other impacts you would like to mention: 
2.5. Transport / use of energy 
Does the cultivation of EU approved GMOs have an impact regarding energy and fuel 
needs/consumption? If so, which ones? 
Does the cultivation of EU approved GMOs have an impact regarding the demand for 
transport in general term s? If so, which ones? 
Any other impacts you would like to mention: 
3 - Other Implications  
 
EN 12   EN ANNEX 2  
Non-exhaustive summaries of individu al contributions of the 25 Member 
States which answered to  the questionnaire.  
 
These summaries have been reviewed and valid ated by the Member States, and do not 
engage the Commission 
 
EN 13   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Austria1 
1. ABOUT AUSTRIA  
o No GMO cultivation2. 
o No experimental research activities on GMOs cultivation3. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Austria appreciates the efforts by the Comm ission to collect experiences of Member 
States with regard to socio-economic  effects caused by GMO cultivation.  
o Many questions were difficult due the lack of European experience with GMO cultivation.  
o Consultation of all authorities, agencies, inst itutions involved in GMO issues, as well as of 
all provinces of Austria. 
o Reference is made to the criteria for soci o-economic effects proposed by COGEM in the 
Netherlands. This proposal should be further discussed at EU level. 
o Precautionary measures should be taken in the EU to prevent the unintentional spread of 
GM plants in the environment and the adventiti ous presence of GMOs in other products.  
o Austria is the Member States having (1) the highest share in the “agri-environmental 
program” (more than 90% of Austria’s agricultur ally utilised area); (2) the highest portion 
of organic growing area. 
o A minimum general framework must be guarant eed which allows each farm to maintain a 
GMO-free production (including cr oss-border cultivation areas). 
o Due to the small structure of Austria’s area s under cultivation, “coexistence” of GM and 
non-GM cultivation is for some crops simply not feasible in Austria. 
o Farmers fear of becoming dependent from big seed and crop protection companies.  
o The one-sided orientation of the new tec hnologies does not take account of the many 
regionally specific needs. 
o Politically, Austria thus advocat es a right of self-determina tion concerning cultivation, not 
only vis-à-vis the EU, but also on the part of Austria’s ni ne Federal Provinces, all of 
which are members of the Europ ean Network of GMO free Regions. 
o The answer to the questionnaire is comp lemented by a study entitled "Assessing socio-
economic impacts of GMOs – Issues to consider for policy development". Provided that socio-economic factors are further considered  at European level,  the study recommends 
                                                
 
1 This compilation was prepared by the Commission on the basis of the information provided by Austria, 
and was validated by Austria. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
 
EN 14   EN to: (1) Launch a process for policy development which allows for inputs of a broad range 
of stakeholders; (2) Identify and conduct research on imp act dimensions and possible 
impacts of GM cultivation; (3) Based on the research described above conduct transdisciplinary research on best practice models, approaches, and methods appropriate 
for measuring and assessing the impacts as we ll as the normative baselines and criteria. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o The prevailing mood concerning GMOs (media  and people’s opinion ) is sceptical to 
negative. Major problems in neighbourly relati ons must be expected as well as protest 
campaigns. Wilful destruction cannot be ruled out. 
o GMOs pose the risk of out crossing and c ontamination of other crops as well as the 
resulting questions of liability. Long r unning legal disputes must be expected. 
o 15% of all farming enterprises are organic farmers (19.961) and, thus, faced with the 
problem of coexistence (average).  
o Marketability of the harvested products with traces of GM Os would be jeopardised. The 
same would apply to GM free beekeeping pro ducts, dairy sector a nd livestock (for the 
latter, GM-free protein feed is an increasing problem; soybean is more and more replaced 
by by-product from the production of bio-ethano l from cereals). No legal rules protecting 
GM free producers against such economic disadvantages exist. 
o As regards farmer's production costs, no concrete statements can be made due to the lack 
of experience with GMO cultivation. Herbicides associated to HT crops should generate higher costs for the buyer. There would have no solid proof of actual savings in connection with pesticide use. There are even studies that prove the contrary. 
o Analysis show that breeding progress for yielding maize in the United States (with 
GMOs) and in Austria (without) does not show  benefits for GMOs. Maize yields in 
Austria are even slightly higher than they are in the U.S.A. 
o There are conceivable positive impacts on harvest quality (e.g Bt crops), but these can be 
achieved also by means of conventiona l breeding and control methods.  
o Complete logistical separation between conve ntional/organic and GM  seed/harvest would 
be hardly achievable, thus the cultivati on of GMOs would threaten non-GM farming. 
o Similarly to hybrid maize, contractual obliga tions of farmers concerning the purchasing of 
the GM seed (with the herbicide fo r HT seeds) must be expected. 
o Probably cultivation of GMOs would have no significant change as regards the 
availability of seeds. In the long run GM seeds would be more expensive (license fees to 
the holder of the patent). Though the strategy of the Austrian seed industry to focus on 
GM-free varieties has proved successful, as al l market opportunities can be met with it. 
 
                                                
 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 15   EN  
Impacts on downstream operators 
o Austrian consumers clearly advocat e supply with GMO-free products.  
o Segregation should cause additional investme nt, handling and administrative costs for 
cooperatives and grain handling companies.  
o It is becoming increasingly difficult for the food and feed industry to produce guaranteed 
GM-free products. Additional costs from coex istence and segregation amount to up to 
13% of the product turnover for o il mills and the starch industry6.  
o The Austrian food chain has dedi cated itself to offer exclusiv ely products not labelled as 
GM. It avoided the expected high costs of establishing a segregation chain.  
o No insurance available that c overs the admixture risk (for  GM/non-GM growers/actors). 
o Public administration: there is no cultivation thus it is difficult to make a quantitative 
assessment. However, Austria assumes that the precautionary legal regulations will cause 
significant administrative expenditure (speci fic expert knowledge, checking compliance 
with legal regulations on GMO cultiva tion, monitoring on the entire chain). 
Economic context 
o Austria questions whether a complete free intern al market for GM seeds is desirable, even 
though potential impacts are not yet measurable. It must be reckoned that such a case 
would negatively impact the free internal market of GMO-free seeds as well as organic or other GMO-free food and feed products. 
Agronomic sustainability 
o International experiences have shown that presumably higher pesticide application levels 
are necessary due to GMOs. 
o No HT (herbicide tolerant) crop authorised in  the EU, so no conclusive answer is possible 
for the time being as regards the use of herbicides. 
o A study of the Federal Environment Agency  on environmental protection and nature 
conservation in the cultivation of genetically  modified organisms by M. Dolezel (2007) 
concludes that negative effects on biodiversity are to be expected. 
o Effects on the biodiversity of th e soil are yet to be examined. 
o Regions with strong traditions and high-quality  production of typical food, small-scaled 
agriculture, Natura 2000 zones are areas particularly worth being protected. In many of 
these regions local citizens reject GMOs cultivation. 
o Current GMOs have not been  specifically shaped for renewable resources (natural 
resources management, energy consumption, clim ate change, etc), so this question cannot 
even been discussed at theoretical level. 
                                                 
6 Costs and benefits of segregation and traceability be tween GM and non-GM suppl y chains of final food 
products; Science Centre Straubing (Germany) 
 
EN 16   EN Other implications 
o No answer
 
EN 17   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Belgium1 
1. ABOUT BELGIUM  
o The use of GMOs for cultivation is a matte r falling under the competence of the Regions. 
o No GMO cultivation2. One exception: in 2010, a coexistence experiment with Bt-maize 
(1ha of maize MON810) was co nducted to evaluate the Fl emish coexistence measures 
(legislation and sampling procedures).  
o Research activities: Dissemination experime nts resumed in spring 2009, after a suspension 
between 2004 and 20083. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o BE answer consists in (1) a compilation of th e crude contributions of the 12 stakeholders 
involved, including some public se rvices, (2) a report of a wo rkshop organised in Belgium 
on 29 March 2010 on the evaluation of the socio-economic impact of GMOs (available on internet
5). 
o This answer of BE to the questionnaire does not represent the official position of Belgium 
as a whole. 
o In order to properly assess the socio-econom ic impact of GMO cultivation, a specific 
effort should be devoted to the identificatio n of the scope of a lternatives to such 
agricultural practice. A systemic approach  could then compare short and long-term 
impacts of a GMO based agriculture to thos e of existing or othe r potential innovative 
pathways6.  
o For the federal Environment department, so cio-economic criteria  should not bypass 
biosafety criteria. 
o The regional government of Wallonia is in fa vour of a moratorium on dissemination of 
GMOs into the environment and putting on th e market as long as absence of risk for 
health and environment as well as socio-econom ic advantages has not been demonstrated.  
o The federal public service Health, Food Ch ain Safety and Environment organised a 
workshop entitled “Visions on the evaluatio n of the socio-economic impact of Food 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Belgium, and was validated by Belgium. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 http://www.health.belgium.be/eportal/E nvironment/BiodiversityandGMO/GMOs/ 
19061856_FR?backNode=9222  
6 Vanloqueren G., Baret Ph. ( 2009 ): How agricultural research systems shape a technological regime 
that develops genetic engineering but locks out agroecological innovations.  Research Policy 6 : 971-
983 
 
EN 18   EN GMOs“, organised in Belgium on 29 March 2010. The conclusions of the workshop are 
available at www.ogm-ggo.be  
o Boerenbond (syndicate of part of Flemish farm ers) is open to new GMOs for cultivation 
as long as they are thoroughl y evaluated (science-based),  sustainable and socially 
responsible. 
o The Greenpeace contribution covers GMOs  at large, not just cultivation. 
o For the federal Environment department, sustaina bility criteria should  also be developed 
not only for GMOs intended for cultivation in  the EU but also for imported GMOs having 
a direct scope of food/feed/products use. 
3. Overview of the answers to the questionnaire7 
Economic and social implications 
Impacts on upstream operators  
o For the federal Environment department and the federal Development Cooperation 
department, the question of the patenting of the seeds and the interdiction for farmers to 
re-use and exchange bought GM seeds woul d remain an important socio-economical 
issue, to which are linked various  other sustainability issues. 
o For Greenpeace, the more GMOs are cultivat ed, the more conventional and biological 
farmers will have to invest in preventive an ti-contaminations means, as GM farmers are 
not responsible for potential cross contamina tions with their neighbourhood (principle of 
the "polluted-payer"). 
o If contaminated by GMOs, biological maize can loose its label and price premium, and in 
the long run its image can be damaged. The 2 preceding considerations could force the emigration for ex. of sweet maize EU producers who want to produce without GM, says Greenpeace, for which this is paradoxical if the majority of EU consumers are opposed to 
GM food.  
o Following APFACA-BEMEFA (nati onal professional association of feed producers), if a 
better yield is obtained with GM feed cultures (for ex. Bt mai ze ), this could be favourable 
for the livestock sector accepting GMOs and could raise the profits of feed culture 
exporters.  
o Non-GM livestock farmers have  to pay extra costs to guara ntee the provision of non GM 
feed (e.g. non GM Soya from Brazil). Label ling of non GM fed lives tock is therefore 
necessary to justify the premium cost asked to  the consumer, who in majority is opposed 
to GM food in the EU, says Greenpeace, for which it is thus paradoxical that these 
consumers have to pay these extra costs. 
o Greenpeace is opposed to a GM presence tolerance threshold for seeds, as it would lead to 
insidious large scale contamination of all c onventional seeds. The Austrian Seed Purity 
Act should be considered as a model. 
                                                
 
7 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 19   EN Impacts on downstream operators  
o SYNAGRA (national syndicate for cereals and dr ied fruits trade) considers that GMOs 
cultivated in Belgium should not be dealt sepa rately in the food chain, in order to avoid 
supplementary costs in infrastructures and wo rkload. Furthermore, even with segregation, 
cross contamination cannot be avoided. 
o Public authorities (federal E nvironment department and regi onal government of Wallonia) 
report costs to be supported by the public bu dget already in the absence of cultivated 
GMOs on the market: cost of risk assessmen t by the Belgian Biosafety Advisory Council: 
costs of controls of labelling of  products, cost of post monito ring of field trials, costs of 
control of non contamination of conventional se eds, costs of enquiry outside field trials 
(that revealed presence and maintenance in the environment of Wallonia of a GM colza 
not authorized for cultivation). Furthermore, should GMOs be cultivated, all existing monitoring networks should be upgraded and this would take time and involve more 
money. One should therefore antic ipate potential costs that w ould result from too lately 
detected negative environmental and/or health impacts.
 
o The Belgian Federation for Food Industry (FEVIA ) stresses that for the moment the use of 
GMO is limited as much as possible due to consumer's rejection. Should GMOs be 
cultivated in Belgium, the profitability of the sector would be negatively impacted by 
increased logistic, segregation and traceab ility costs along the food production chain. 
However, should GMOs be accepted by consumers, the range of products proposed to the consumers would significantly expand, agricult ure would be more competitive, and the 
food industry more profitable.  
o For Greenpeace, the contamination of bees and thereafter honey is unavoidable when 
GMOs are cultivated close to a hive. 
Economic context 
o No impact observed on the internal market as there is no cultivation for the moment. 
Agronomic sustainability 
o For the federal Environment department, even though some of the problems raised by 
GMOs are common to conventional agriculture , the GM technology s hould do be tter (and 
not just the same as) than conventional agriculture, at the level of environmental ( including climate ) , health and food security  impacts. This view is shared by the federal 
Development Cooperation department.  
o For the federal Environment department, GMOs cultivation in its present state causes poor 
preservation of wild and agricultural bi odiversity due to the monopole of few big 
companies focusing mainly on a few big world trade cultures, and the cultivation of clonal 
monocultures. Sustainability criteria fo r GMOs cultivation should mind taking into 
account international environmen tal and public rights agreemen ts signed by the EU and its 
Member States. This view is shared by the federal Development Cooperation department.  
o Greenpeace considers that cultiv ation of BT maize ends up in much higher contamination 
rate of the soil than with conventional prac tices, due to the con tinuous production of the 
pesticide by the crop. Furthermore, the benefit of the eradication of the primary pest is 
cancelled by the development of secondary pest s, which then have to be fought against 
with additional pesticides. Finally, the exces sive use of BT through BT crops could 
 
EN 20   EN generate resistance, what would be a big probl em for the biological farmers also using BT 
insecticides. 
o Greenpeace considers that HT crops stimulat e higher spraying of target herbicides by 
farmers, who also have to use additional herbicides when resistant weeds appear. 
Other implications 
o As regards climate change, Greenpeace considers th at there is a full portfolio of measures 
more efficient than the use of GMOs to limit the CO2 emissions from the agriculture 
sector. Preserving plant divers ity, rather than promoting m onoculture (of GMOs), is the 
best insurance policy to resist  to the forthcoming increased  drought and extreme climatic 
events. 
o Boerenbond (syndicate of part of Flemish farmers)  considers that ex-a nte evaluation of the 
socio-economic impact is not possible due to the lack of technical and economic 
information to build upon and risks to open a pr ocess against GMOs without any scientific 
base.  
o Following the federal Environment departme nt, some socio-economical impacts could 
already be evaluated once the de stination of the GMO is planne d; this assessm ent could be 
built step by step, being potentially info rmative from the field trial phase on.  
 
EN 21   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Cyprus1 
1. ABOUT CYPRUS  
o No GMO cultivation2. 
o Research activities on GMOs: no field trial notifications between 2002 and 20073. 
o No coexistence rules adopted4. 
2. GENERAL COMMENTS  
No information 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Countries that cultivate GMOs ha ve increased their use of inse cticides but it is difficult to 
assess the risk and gain specific knowledge si nce in the EU only Spain cultivates GMOs 
commercially and no adequate studies have been published. More re search is needed. 
o Specific conditions in Cyprus: fragmentati on of land, small size of  fields and small 
distances between them, high endemic flora, sp ecial climatic conditions. This implies that 
(1) buffer zones are probably not feasible in Cyprus; (2) there is a high risk of 
contamination and implementing coexistence measures will be costly for farmers. In addition, coexistence would request more c oordination between GM growers and other 
farmers but a majority of farmers don't accept GMO cultivation.  
o Potential presence of GM seeds in conventional imported seeds implies addition costs of 
inspection.  
o There is concern regarding the health of the labour resulting from the change in practices 
in the case of GMO cultivation and the use of new chemicals with unknown practices.  
o The seed market is made of small and medi um enterprises. GM seeds would reduce the 
market share of conventional and organic seed s and thus probably have adverse impact on 
turnover, employment and profit of these small companies.  
                                                
 
1 This compilation was prepared by the Commission on the basis of the information provided by Cyprus, 
and was validated by Cyprus. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 22   EN o Price of GM seeds are controlled by multinational companies and can artificially be set 
lower than the price of  conventional seeds. 
o GMOs are not accepted by the majority of the citizens.  
o Plant genetic resources: conventional seeds must  be protected as they will be the base for 
the production of new developed crops.  
o Domination of GMOs will reduce the choice for farmers. 
o Incomes of the farmers who cultivate GM seeds could decrease. Depending on the 
weather or soil conditions, many times more pest icides or fertilizers will be needed for 
GM cultivation, thus increasing the cost. 
o Patent system will reinforce oligopolies 
Impacts on downstream operators 
o Citizens have expressed their pr eference to lower the labellin g threshold for food and feed 
and to have GMO-free products with official  labelling. Labelling should be clearer and 
GMOs placed on other shelves.  
o Risk of mixing for food and feed. Segregation will increase the cost of storing, handling, 
transferring and transporting of  GMOs for the grain companies and transport companies, 
as well as administrative costs. It is difficult if no impossible to manage the two parallel systems, in particular for seeds. In genera l, quality of products will be questionable.  
o If GM feed dominate the market and its pr ice drops, there is a risk to reduce the 
percentage of conventional feed in the market.  
o As far as insurance is concerned, GMOs need to  be handled differently. There is a need to 
provide guidelines so as to be able to deal  with GMO companies and cover the cases of 
contamination.  
o The state laboratories perform analyses for impor ts. In the case of an increase of needs, 
more time will be needed for the results and it  is not possible to say how the prices will 
evolve. There would be an increased need  for more labs and investments in new 
technologies.  
o The research institutes of Cyprus are not involved with GM O research (other priorities are 
set regarding the agricultural sector). 
o Public administration: in the event of GM O cultivation, the administrative costs will 
increase substantially since more monitoring an d control will be needed in various sectors 
of the public administration.  
Economic context 
o It is difficult to evaluate the potential imp act on the internal market but negative impacts 
are foreseen regarding the local seed producer s, as well as the producers of conventional 
and organic products. 
o Unequal competitiveness would rise  and monopolies would increase.  
o Fewer and larger farms will need to be esta blished (coexistence) and monoculture will 
increase.  
o GMO cultivation will possibly affect the goo d reputation of an area. An additional 
negative agrotourism is to be expected (inc luding due to the decrea se of biodiversity). 
 
EN 23   EN Agronomic sustainability 
o As there is no cultivation, it is difficult to  assess the impact of GMO on use of inputs.  
o The use of pesticides will probably have a ne gative impact on other useful insects and on 
the global biodiversity (including faun a and productivity of the soil). 
o New traits could offer advantag es that could lead to the wi despread use of only a few crop 
varieties, meaning a loss of cultivar biodiversity and a higher susceptibility to plant diseases and pests.  
o Bees could be impacted by the change in th eir diet which may ha ve adverse effects on 
their health.  
o Risk of genetic pollution of wild plants through cross-pollination which may pose public 
health problems; create "superweeds" (requiring more toxic pesticides to be managed) and 
threaten extinction for rare plant or change the relatives in a way that could make them 
play a different ecological role, potentially en abling then to out-compete other species.  
o On biodiversity, there is a possibility for adverse impacts on the biodiversity, depending 
on specific conditions. More serious impacts will be observed in protected areas (e.g. 
Natura 2000). The endemic relatives need to  be examined. The decrease of insect 
population will limit organisms whos e diet depends on insects.  
o Small-scale agriculture, natural habitats prot ection and management would be affected.  
o The use of soil will probably be affected (GMO residues may have an impact on 
productivity of the soil) 
o Cultivation of GM plants in order to produ ce biofuels will have negative impacts to 
renewable and non-renewable sources and should not be considered as an alternative.  
o There is no evidence for specific GM crops that  need less water or are tolerant to higher 
temperatures. Conventional crops can be select ed for the specific conditions in order to 
adapt to new climatic conditions of the island.  
Other implications 
o No Answer 
 
EN 24   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation  of the contribution  
by Czech Republic1  
1. ABOUT CZECH REPUBLIC  
o Cultivates MON810 Maize since 2005 (approx. 6,480  ha in 2009)2. 
o Research activities: 11 notifications for field trials between 2002 and 20073. 4 
notifications for field trials in 2008 (according to the SNIF database) 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o 526 stakeholders were consulted, with a 12% answer rate. 
o The Czech Republic welcomes the questionn aire and the discussions on the socio-
economic aspects of cultivation of GMOs. 
o "The views of the consultees are not necessar ily the same as the formal position of the 
Czech Republic's government". 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators 
o For 78 % of respondents, GMOs had a positive e ffect on investment in plant research and 
subsequent rising number of patents. 67 % experienced a positive effect of GMOs on the employment in the R&D centres. 
o 78 % of respondents experienced that the re search on GMOs accelerated the use of non-
GM modern breeding techniques. Balanced  use of GM and non-GM techniques is 
expected in the future.   
o Both GM and non-GM seeds are availabl e, but GM-seeds are more expensive. 
Dependence from major seed industries was experienced by 74% of responding farmers. 
o 90% of responding MON810 growers estimated  yield increase to 10% (or higher, 
depending on pest pressure). 
                                                
 
1 This compilation was prepared by the Commission on the basis of information provided by the Czech 
Republic, and was validated by the Czech Republic. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 25   EN o 77% of responding farmers reported equal or lower production costs, resulting from lower 
(or none) insecticide treatments, lower hand ling and mechanization. 23% reported higher 
costs due to more costly seeds. 
o Quality of harvest: all consultees cultivating GM maize reported higher quality (less 
mycotoxins). 
o 56% of respondents reported neighbouring confli cts or mentioned threat of such conflicts. 
o 77% of responding GM growers reported difficulti es to sell the GM harvest (therefore GM 
harvest is used as a f eed in the own farm).  
o 93% of responding farmers cultivating MON810 experienced reductions in the use of 
insecticides as well as fuel. No change in fertilisers or water resources use was recorded. 
The Czech Beekeeper Union acknowledged th e reduction of use of insecticides. 
o Respondents report significant ga ins in labour flexibility when pest pressure is high (less 
or no need for chemical treatment).  
o For consultees cultivating GM maize, the e ffect of GM crops on livestock is positive – 
production of plants with lower mycotoxin co ntent finally resulting in lower costs for 
veterinary care. No opinion on the issu e was obtained from organic farmers. 
o For 72% of consultees, health of labours improves due to re duced exposure to chemicals. 
28% considered that the difference is mini mal when chemicals manipulation rules are 
respected. 
o Representatives of organic farming consider that small farms cannot cultivate GM crops 
(isolation distances difficult to keep  within and between small farms). 
o For 53 % of consultees, GM maize cultivation has no impact on the beekeeping industry. 
18 % of consultees and the Czech Beekeepers Union were of the opinion that Bt maize 
cultivation would positively in fluence beekeeping due to reduced use of insecticides. 
However, monitoring of long-term pesticide use development in GM crops is necessary. 
o The Czech Beekeepers Union drew the attentio n to a possible consumers' reluctance to 
buy honey products contaminated with GM pollen. 
o If GM cultivation significantly expands, difficulties to find su fficient cultivation areas for 
conventional seeds are expected, and risk of  cross-contamination of non GM seeds during 
growing, harvesting or storage. 
o Some respondents fear a monopoly developmen t by international s eed companies.  
Impacts on downstream operator 
o Lower level of mycotoxin leads to higher qua lity products. However, GMO cultivation in 
higher extent could decrease th e diversity of non-GM products. 
o 80 % of respondents consider that GM crops cultivation had a positive effect on consumer 
information and protection. Obligation for labelling resulted in better consumers' awareness of given products while th e right to choice has being kept. 
o Segregation GM/non-GM complicates organi sation of work and increases costs and 
administrative burden for cooperatives and gr ain handling companies (activity records, 
labelling, controls). 
 
EN 26   EN o The food/feed industry, with the exception of  the organic industry would benefit from a 
wider range of products offered due to GM. Some producers of organic products claimed 
rise of costs for GM-free products marketing. 
o Transport companies would face high segrega tion costs (physical separation, cleaning). 
o No insurance product for GM growers exists, but it could be developed in the future. 
o 60 % of respondents assumed rise in costs for GMO analyses due to increased demand for 
inspections and enforcement by authorities, extension of personal capacities, development 
and/or of new detection me thods provided that areas with GM crops enlarge. 
o Public administration: extra costs would be  faced by the Ministry of Agriculture (co-
existence control activities ~ 11.500 EUR/year) and the Mini stry of the Environment 
(GMO reference laboratories ~ 22.500 EUR in 2009).  
Economic effect 
o 42 % of respondents assumed that placing on th e market of GM seeds did not have any 
significant impact on the EU internal market on seeds (partly due to the very limited - and decreasing - areas sown with GM maize).   
o Recent limited cultivation of GM crops in Europe does not enable a strong business 
competition; therefore an impact on monopolies cannot be quantified.  
Agronomic sustainability 
o Decrease in use of pesticides is anticipated by most respondents, as  pest is spreading 
quickly in new localities of the Czech Republic. Organic farmers predicted increase in 
pesticides use in case of resistance development. 
o According to 77.5 % of consultees, introduct ion of GMOs does not put at risk crop 
varieties as limited to Bt for now. But sound sc ientific assessment of this potential impact 
if GM crops are more cultivated in future should be carried out. 
o Protected species/migration rout es/biodiversity: for a majori ty, there is no more danger 
with GMOs than for conventional crops if  inappropriately cultivated. Ca 21 % of 
consultees considered that ther e is a lack of data to assess any of the mentioned categories 
for the moment. 
o Extensive research carried out in the C zech Republic on impact of Bt on non-target 
organisms demonstrated positive impact on their diversity. 
o No negative impact is anticipated on renewa ble resources. The real problem lies in bad 
farming practice (for both GM and conventiona l crops). Some consider that GMOs could 
also have a positive impact by increasi ng production of plants for biofuels. 
o According to 38 % of consultees, a positive im pact on the use of non renewable resources 
is expected due to less treatment i.e. le ss use of fossil fuels (tractors/production of 
biocides). But no macro scale impact due to the limited surface of cu ltivated in the Czech 
Republic. 
o According to 86 % of consultees GM crops co uld help fighting against extension of pest 
due to warming. 
Other implications 
o No answer. 
 
EN 27   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Germany1 
1. ABOUT GERMANY  
o Cultivation of MON810 Mai ze until 2008 (3371 ha in 2008); cultivation of Amflora2. 
o Research activities on GMOs: 49 field tr ials notified between 2002 and 2007 (apple; 
barley; maize; oilseed ra pe; pea; poplar; potato; Solanum nigrum ; soybean; wheat)3. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o The questionnaire was sent to  25 stakeholders and to al l German Federal Länders. 20 
responses were received (12 from official  institutions, 3 from industry, and one for 
institutions representing farm ers, retailers, consumers, or NGOs, respectively). Germany 
considers that these 20 responses do not al low answering properly to the Commission 
Questionnaire. Therefore the German res ponse was kept general but submitting the 
comments received as additional information. 
o The low experience with cultivation of GMOs in Europe does not allow a proper 
evaluation in the European cont ext of intensive agriculture.  It should be evaluated if 
conclusions from 3rd countries could be transferre d to the European conditions. 
o The evaluation of socio-economic consequen ces of the cultivation of GMOs and the 
definition of criteria should be carried out  separately from the risk assessment.   
o Documentation including socio- economic criteria which coul d be relevant for risk 
management decisions should be considered  for the formulatio n of EU criteria. 
o Socio-economic criteria can be included, in addi tion to the scientific risk assessments, in 
risk management decisions in the context of a European aut horization of GMOs. For this 
the definition of specific criteria is neede d, which needs to be based on a precise and 
complete definition of the elements of these criteria.  
o Socio-economic criteria should consider WTO ru les and basic rights of the Lisbon treaty. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
o The responses were, in most cases not co vering all questions, so that a summary 
representing different views is  not appropriate. 4 answers were  "zero" answers, since no 
information was provided. Some of the answer s were general and some provided available 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Germany, and was validated by Germany. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 28   EN information or reports for further considera tion, covering e.g. non target organisms, risks 
of GMOs, and socio-economic criteria for the evaluation of GMOs. 
o It should be kept in mind that the compilatio n below is necessarily biased due to the 
reduced number of responses and the incomp lete feedback to the survey questions. 
Economic and social implications 
Impacts on upstream operators  
o Competitive disadvantages in the global market for seed producers (they can not use the 
potential of the technology). In particular SM Es can not invest in  green biotechnology 
(high administrative costs for the regulator y processes without a guarantee on the results, 
slow transfer of research results into prax is, increased costs for research field trials 
(security measures), possible destruction of batches in case of micro-contamination. 
o The introduction of labelling thresholds for conventional seeds is urgently needed 
(coexistence is only possible with a thre shold based on technical possibilities). 
o Reduced production costs due to a reduction in the use of pesticides (Bt-maize), more 
secured harvest, better qual ity of the harvest (reduced  presence of mycotoxins). 
o Higher administrative costs for farmers becaus e of regulatory demands (minimal distance, 
crop rotation, etc.).  
o The coexistence between GMO growers and non-GMO growers needs to be considered. 
o The non authorisation of GM plants for feed w ould give considerable disadvantages to the 
animal production sector (about 50% of the agronomical production in Germany). 
o Legal uncertainty regarding GMO residues in honey. Beekeeping in general is not 
considered in the legal framework. 
o Patents on GMOs and living organisms not s upported by farmer associations nor NGOs.  
o Farmer advice not to cultivate GMOs becau se of the negative opinion of consumers. 
Impacts on downstream operators 
o A threshold for non authorized GMOs in feed is urgently needed for the feed industry. 
o An impact on costs for grain handling compan ies is expected (need to separate non-GMO 
and GMO production lines, a nd respective controls). 
o An impact on price of goods could be possi ble but can currently not be predicted.  
o The current labelling is not fulfilling the principles of transparency and clarity. 
o It is considered that the consumer has no free choice regarding products produced with / 
without GMOs, since food stuff produced by/wi th animals fed with GMOs do not need to 
be labelled. This situation is not building confidentiality of the consumers. 
o There are several cases of GMOs  which are exempted from la belling since they are since 
years on the market. These gives an "illusion" of GMO free products.   
o No free choice is given to the consumer in the case of cultivation of GM plants since once 
they are released into the environment they have the potential to reproduce themselves. 
o Effects on food producers are ex pected due to asynchronous authorisation and zero 
tolerance of non-authorised GMOs in Europe. 
 
EN 29   EN o The cultivation of GMOs should only be allo wed if the coexisten ce with conventional 
crops is guaranteed, since otherwise the fr ee choice of the consumer is not guaranteed. 
o Public administration: important cost increas e (implementation/monitoring of cultivation).  
Economic context 
o An impact on the European internal marked is  expected (differences between the Member 
States when transposing the Eu ropean legislation into nationa l legislation are expected). 
o In the case of continuing with the zero-toler ance concept, a reduced availability of feed 
material is to be expected in Europe  (meaning price increase and competitive 
disadvantage for pork and poultry producers). 
o GM-free regions would be accepta ble if created on the basis of  farmers' voluntary choice. 
o To avoid increase of price of consumer products produced using GMOs, GMO growers 
should contribute to a fond covering the cost s of additional administration and labelling. 
o So far there are no insurance products covering situations caused by GMOs. 
Agronomic sustainability 
o The questions of this section were not considered clear. Po tential impact needs to be 
evaluated on a case-by-case basis, depending on the particular GMO.  
o The evaluation of cultivation of GMOs vs . conventional crops needs to be done 
considering the cultivation systems. 
o The buffer zones will lead to  a concentration of production in some regions (GMO could 
only be efficiently cultivated in areas with a big structure). Small structured regions will 
face a competitive disadvantage. Increased cost s are associated with this "buffer zones". 
o Since tolerance to herbicides or resistance to  insects could be achie ved also by traditional 
breeding methods, a change of agricultural management achieved by the use of new 
varieties should be evaluated inde pendently of the techniques used. 
o The non authorization of drought tolerant GM cr ops would be irresponsible (higher yields 
with the same resources and less CO 2 emissions). 
o The legislation in the areas of GMO and natu ral protection (Food Fauna  Habitat Directive) 
is not sufficiently harmonised.  
Other implications 
o Independent and transparent rese arch is needed, in particul ar long term feeding studies 
and studies on environmental consequences.   
o Research should be focused on problem solving and not on methods. 
o The consideration of socio-economic criteria in  the EU authorization process of GMOs is 
not welcomed. This is too "subjective".  
o For guaranteeing free choice of the consum ers, more information should be given, 
including on risks and benefits asso ciated with the use of GMO products. 
 
EN 30   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Denmark1  
1. ABOUT DENMARK  
o No cultivation of GMOs2. 
o Research activities on GMOs: 8 field trial notifications between 2002 and 20073. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o The answer is based on contributions from  the Danish Plant Directorate, Danish 
Veterinary and Food Administration and the National Environmental Research Institute. Relevant stakeholders have contributed too, and Denmark has decided to let the comments 
from stakeholders stand alone. 
o Danish Agriculture and Food Council: GM crops have not yet been grown in Denmark. 
The main reason is the lack of GM crops  with events relevant for the Danish 
agronomic/climatic context. 
o Danish Agriculture and Food Council: A prereq uisite for growing GM crops in Denmark 
is, however, that the freedom of choice is guaranteed for all farmers (GM-growers, 
organic and conventional). 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Greenpeace: The USDA (USA) states that "Currently available genetically engineered 
crops do not increase the yield potential of a hybrid variety. Yield may even decrease if 
the varieties used to carry the HT or insect -resistant genes are not  the highest yielding 
cultivars . Similar results are reported from South America. 
o Greenpeace: Non-GMO growers are sufferi ng many extra costs to prevent GMO-
contamination. The application of the "polluter pays" principle is reversed . 
o Danish Seed Council APVD: GM seeds produ cers may not improve economic output but 
might realize lower input.  
o Danish Seed Council APVD: The farmer mu st have access to seeds from several 
companies.  
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Denmark, and was validated by Denmark. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the ma rket place – final report November 2008 
4 Source: idem footnote 2 
5 more details, please see the full answer at http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 31   EN o Greenpeace: The contamination risk means th at, although farm saved seeds are protected 
by legislation, farmers are in fact forced to use certified seeds to reduce risk of a 
contaminated harvest.  
o Public institutions: Possible impact on fa rmers: reduction of costs and increased 
flexibility.  
o Danish Agriculture and Food Council: Dependence on seed industry and restrictions in 
relation to the use of farm sa ved seeds will probably be of  minor importance in Denmark 
as most farmers is buying certified seeds payi ng a license even for farm saved seeds. 
o Danish Beekeepers' association: Beekeepers fear that GM crops will make biodiversity 
even further decrease, monocultures increase an d have a negative impact on the vitality of 
honeybee colonies. Beekeeping an d honey production is consider ed to be not adequately 
covered in the "co-existence" legislation (GMO grower is no t liable to pay compensation 
in case of damage, no protection for the b eekeeper against non inte ntional presence of 
GMOs in its products). 
o Cooperation of biodynamic consumers/agricu lturalists: Growing more GM crops in 
Denmark and in Europe will put a pressure on third countries which cultivate few or no 
GM crops, and/or third countries where the farmers, the public and the scientists are 
divided over the cultivation of GM crops. Such countries have very weak public 
institutions that are unlikely to be able to securely measure and control the use and 
impacts of the cultivation of GM crops. Furt hermore, certified organic agriculture will 
probably become completely eradicated, since over time the GM traits will spread by natural selection to all non-GM crops. 
o Danish Seed Council APVD: It will strengthen competitiv eness of European Seed 
Industry. The development of new products  is necessary to increase or secure 
employment, turn -over and profits. However, it is pr edicted increasing costs for the 
breeding companies in  the development of GM crops (insurance issues (legal risks), field 
trials, costly risk assessments. Access to further plant breeding also with varieties 
containing patented traits must be secured to keep progress in br eeding in the future, 
respecting breeder's exemption.  
o Danish Seed Council APVD: As regards seed production, identif ication of seed 
production areas with least impact  on production of conventional va rieties can be an issue.  
o Danish Seed Council APVD/Danish Agricu lture and Food Council: Seed production (in 
general) with zero tolerance for adventitious presence is impossible and will be a deterrent for any GMO production in the EU. 
o Danish Agriculture and Food Council: Only big companies will have th e ability to engage 
in GM seed development. However, productio n of organic or conventional seeds opens 
niches for smaller breeding companies.  
Impacts on downstream operators  
o Greenpeace: Food industry avoids using GMOs so consumer choice is largely unaffected. 
o Danish Agriculture and Food Council: Grain handling companies are already handling 
GM products (imported feed). However, th e introduction of GM seeds will add the 
following constraints (coexistence,  checking that GM seeds are only sold to farmers that 
have a licence to grow GM crops). Transport companies mu st prevent spreading and apply 
coexistence legislation. They are, how ever, currently handling imported products 
containing GMOs. 
 
EN 32   EN o Public institutions: Innovation and research: in creasing need for information and trials on 
the potential environmental effects (genetic in teractions, synergy on target and non-target 
organisms).  
o Danish Agriculture and Food Council: Reluctance regarding GM crops has an impact on 
European research, eventually on the number of patents held by European companies and 
also the future access to gene tic resources and tool s (other modern breeding technologies). 
Economic context 
o Public institutions: T he setting of labelling thresholds for accidental presence of GMO seeds 
in conventional seeds is not resolved. In practice the individual Member States are setting 
their own thresholds. This situation harms the trade of seed between Member States.  
o Public institutions: The lengthy approval process and the costs make it difficult for SMEs to 
participate in the development of GM crops and this contributes to the development of 
monopolies. 
o Danish Agriculture and Food Council: it is reasonable to have locally adjusted legislations on 
co-existence.  
Agronomic sustainability 
o Public institutions: Experience from Spain seems to indicate that the cultivation of 
MON810 can result in a decrease  in the use of insecticides. 
o Danish Agriculture and Food Council: A large scale demonstration project showed that 
farmers growing HT fodder beet were very keen on using its properties, experimenting reduced dosage or delayed spraying with herbicides, thus leading to high biodiversity in the 
fields (weeds, insects and birds).
 
o Greenpeace: HT crops increase weed resistance an d increase use of more toxic herbicides.  
o Public institutions: The evaluation of possible effects on biodiversity, fauna and flora should 
be better addressed. Knowledge gaps include: fiel d edge effects, long term effects, landscape 
effects, non-target effects, monitoring programs.  
o Cooperation of biodynamic consumers/agriculturalists: S everal already ex isting challenges 
regarding environment, climate and public hea lth will further deteriorate. By keeping 
GMOs out, it is believed that over time th e livestock production within the EU will 
diminish due to an expected lack of GM-fr ee fodder. This will have a large-scale positive 
impact on climate mitigation, water pollution, water usage, biodiversity and global food 
resources.  
o Public institutions: Future GM-crops (re sistant to drought, temporary flooding, saline 
conditions) constitute a possible adaptive capacit y to climate change (but will at the same 
time pose a pressure on the biodiversity, flora,  fauna, landscape and other environmental 
values).  
o Greenpeace: GMO cultivation does not solve an y problems but creates many more. In the 
context of changing climate, the solution for food security is a multifunctional agriculture 
as outlined by the UN panel on agriculture, IAASTD.  
o Public institutions: Life cycle analyses which make the comparison between the effect of 
cultivation of GM sugar beet, oilseed rape and maize with the cultivation of the conventional 
versions of these crops have shown that GMO cultivation decreased emissions of CO 2 and 
 
EN 33   EN ozone, ecotoxicity, acidification and nitrification, emissions of toxic particulates and a reduces 
in carcinogenicity.  
Other implications  
o Greenpeace: Socio-economic impact is important in addition to risk assessment. The 
Norwegian GMO-legislation provides example of the proper way to include socio-economic 
and sustainability criteria.  
 
EN 34   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Estonia1  
1. ABOUT ESTONIA  
o No GMO cultivation2. 
o Research activities on GMOs: no field tr ials but contained use research ongoing3. 
o No coexistence rules adopted yet4, but planned for adoption in 2011. 
2. GENERAL COMMENTS  
o As GMOs are not cultivated most of the answers are speculative. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on downstream operators  
o Bt maize contains less mycotoxins, quality would rather increase.  
o No impact foreseen on the right for farmers to use their own seeds.  
o Farming practices would change.  
o Implementation of coexistence measures will cost a lot to farmers 
o Conflicts between GM growers and organic farmers or between neighbours can not be 
excluded. Organic farming is very viable and popular.  
o No insurance scheme is foreseen. Compensati on of damages is regulat ed according to the 
Law of Obligation Act.  
o According to coexistence measures, training is  mandatory for GM growers, paid by the 
government and the certificate is valid for 5 years.  
o An additional notification to beekeepers is re quired to avoid any possible contamination.  
Impacts on downstream operators  
o According to a survey among Estonians (2009 ), 43% of the populati on would not buy GM 
products, only 2% agree to buy, rest of them ar e not sure about their preferences. 54% of 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by Estonia, 
and was validated by Estonia. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 35   EN answered people prefer to buy organic food. At  the same time, price of the products is 
generally decisive. 
o According to a survey among Estonians (2009 ), 43% of answered people are in the 
opinion that GMOs have to have an additional special label denoted as GMO. 
o The range or products offered would increase.   
o Cooperatives and grain handling companies: harvests of GMOs and conventional crops 
have to be separated, which implies additional costs and workload. 
o Food feed industry: probably positive effect  on profit but additional costs and workload 
(transport, storage separation) 
o Transport: requirement for cl eaning and separate lines.  
o No insurance scheme is foreseen.  
o Laboratories: increasing number of analysis  enhances the laboratory performance and 
increase profit. Additional workers may be needed.  
o Innovation and research: possible impact on i nvestment in plant research, number of 
patents held by European organisations, in vestment in research in minor crops, 
employment in the R&D centres in the EU ; use of non-GM modern breeding techniques 
(e.g. identification of molecular markers); access to genetic re sources, and expected effect 
on access to new knowledge . 
o Public administration: Severa l costs are foreseen (surveil lance, operating costs of GMO 
register etc…) 
Economic context 
o Possible cross-border investments flows 
Agronomic sustainability 
o Patterns of use of chem ical herbicides would change and the amount of used herbicides 
may rise as well.  
o Supposedly there is no impact on the clim ate in EU. GMOs are not cultivated in 
sufficiently large areas to talk about a ny measurable impact on climate change.  
Other implications 
o No answer 
 
EN 36   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Greece1 
1. ABOUT GREECE  
o No cultivation of GMOs2.  
o No research activities on GMOs3. 
o No coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Questionnaire has been answered  by various stakeholders.  
o Greece presents a diversity of concerns in case  of GM cultivation. The small agricultural 
plots, the very developed apicu lture as well as the anxiety of  all scale, from farmers to 
consumers are only few of the reasons of this position.  
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Contamination risks for non-GM crop farmers, need for extra contro ls of all seeds, 
coexistence cannot be controlled as the acr eage in Greece is small, farmers will suffer 
from contaminations causing conflicts among neighbours.  
o Beekeepers would not be able anymore to pr oduce safe and quality bee products, organic 
and traditional products, products  of designations of origin. It  is practically impossible to 
apply coexistence measures able to protect bees from GM crops. The same difficulty 
would be raised if field trials were ca rried out. Need for additional analysis.  
o Seed production: need for addi tional measures for seed pr oduction, increasing costs.  
o Use of HT crops may result to an increase in  weed resistance to this herbicide, which 
would imply need for bigger quantities of othe r more toxic herbicides, to which farmers 
will be exposed.  
o Concerns about biodiversity, dispersion of GM  pollen, production of HT weeds, herbicide 
accumulation in HT plants, effects on non-target organisms.  
                                                 
1 This compilation was prepared by the Commission on  the basis of the inform ation provided by Greece, 
and was validated by Greece. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 37   EN Impacts on downstream operators  
o Consumers are not against new technologies in principle (if clear benefits can be 
demonstrated); However, they are against green biotechnology. 
o Offer of new products. 
o GM products would have a lower quality and can acquire lower pri ce, while the non-GM 
product would present a gradua lly decreased diversity and will become ore and more 
expensive. Consumer choice wi ll be significantly limited.  
o Consumers' information on labelling is not  sufficient. Not enough communication from 
the EU and governments.  
o The polluter pays principle is reversed.  
o Seed companies: royalty collection from  seed multiplying companies and seed 
distributors.  
o States revenues from taxa tion of the added value.  
o New employment and investment opportunities (directly or through collaboration with 
public research institutes.  
o Additional financial surcharge in all leve ls (farming, transporting, storing, processing, 
logistical, control system…) 
o GMO cultivation does not take into account ethical-philosophical-religious concerns. 
o The suitable and geographically appropriately located storage capacity for grains in the 
country is considered inadequa te to allow for coexistence. Grain handling installations do 
not have by design the proper st ructure to prevent mixing.  
o Transport: delays and extra cl eaning are also expected to ad d an extra cost but problems 
will remain minimal if procedures are followed.  
o Feed traders consider that there would be signi ficant benefits but there is a need for extra 
attention.  
o Laboratories: more people would have to be  employed, which would increase the cost of 
the final product (in the long term, costs c ould go down due to the economy of scaling 
up). People would need to be sk illed and specialised. Time fo r analysis is expected to 
increase.  
o Public administration: government will have to  allocate funds and important resources in 
order to organize, policing, putting enforcem ent costs and quality control testing.  
Economic context 
o Risk of mono or oligo-po lizing in the seed market. 
o Could lead progressively to an  increase in the size of farm s and decrease the number of 
farmers and monoculture.  
Agronomic sustainability 
o In case of insect resistant plants, possible incr ease of secondary pest s, target insects may 
express resistance to the compound produced by the GMO, GM plants may become susceptible to other pests. In all cases, increase of insecticide use will occur.  
 
EN 38   EN o In case of HT crops: possible increase of sele ction pressure for resistant weed biotypes 
and reinforcement of the use of broad spectrum herbicides. 
o Possible irreversible adve rse effects on biodiversity. 
o Loss of traditional varieties and knowledge. Reducing diversity of cultivars may case 
problems such as higher susceptibilit y to plant diseases and pests.  
o If GM plants pass their new traits on to wild relative, it could make these relatives play a 
different ecological role, po ssibly enabling them to out-compete other species.  
o Insect resistant GMOs may reduce the numbe r of phytophagous and pollen-feeding insects 
in the field, which could have an impact throughout the food chain.  
o Peer-reviewed studies have demonstrated th at the effect of Bt maize are far from 
predictable.  
o Competitive trade advantage of GM cultures would damage biodiversity and result in 
degradation of bee feeding.  
o Recent scientific work has shown that  toxin Cry1Ab has negative effect on 
communication, learning capacity of b ees and feeding collection capacity.  
o Possible impact of GM plants on the e nvironment can be summarized as follows: 
– Transfer of genetic material to sexually compatible plants in the wild; 
– Expression of pollen- mediated toxicity; 
– Effects on microbially-mediated biogeochem ical cycles and soil biotransformation 
and decomposition processes on ecosystem function; 
– Increased persistence in the envir onment through increased survival, 
establishment and invasi veness of GM plants; 
– Adverse effects on non-target organisms; 
– Wider biodiversity implications as a cons equence of specific agronomic practices 
to manage GM plants; 
– Changes in pesticide residue s as a result of changed crop protection practices 
on/or metabolic changes in GM plants. 
o Bt toxin may affect headwater stream ecosystems.  
Other implications 
o No answer 
 
EN 39   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Spain1  
1. ABOUT SPAIN  
o MON 810 cultivated since 1997 (76,057 ha in 2009)2. 
o Research activities: 165 fi eld trials notified between 2002 and 2007 (cotton, grape/plum, 
carrizo citrange, maize, potato, rice, soybean, sugar beet, wheat)3. 
o No coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Spain welcomes the questionnaire, but considers that the collected data  may be of limited 
value as only (Bt) maize is cultivated in Spain (20% of the total cultivated surface). 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Potential for EU research would be significan t if GMOs were better accepted in the EU. 
However R&D on GMOs would affect res earch on conventional/minor crops, as 
multinational will not invest in  this domain spontaneously. Access to technology by SMEs 
will be limited during the patent protection peri od, but afterwards much material would be 
available for research. For the public administ ration and researchers, the current lack of 
visibility on the evolut ion of the European legislation on GMOs and the lack of labelling 
on non GM techniques (e.g. molecular markers)  discourages research in this domain. 
o According to the research in stitutions, for provinces infe sted by corn- borers (Aragon, 
Cataluna), the benefit for the farmer is clear.  An ex ante study estimated that, under high 
pest pressure, MON810 would increase yiel d by 11% (1.500 kg/ha) (Novillo et al., 
2003).Also, another ex ante  study under Spanish conditions proved that Bt-cotton would 
save 15,8 l/ha of insecticide and increase yi eld by 12% more than conventional cotton 
under 1998 conditions (Novillo et al., 1999). 
o An ex post  survey measured that the use of Bt -maize seeds in Spain resulted in gross 
margin increases from 3 to 135 € per hect are depending on the year and areas of 
cultivation (Gómez-Barbero et al, 2008).  
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by Spain, 
and was validated by Spain. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 40   EN o The growing surface planted in Spain –f rom 22.000 ha in 1998 to 76.000 ha in 20096– 
after 12 years of local experience is a strong ex post  indicator of higher farmer revenues. 
o Seed prices are higher, but production costs decrease due to less inputs use and workload.  
o In Spain selling prices of GM and non GM livestock maize are equivalent.  
o For environment protection associations, GM  crops increase the production price of 
conventional/organic crops, and negatively imp act their market price when admixtures 
occur. Furthermore, GMOs do not have market advantage; they are mainly used for local/farm. These associations  also maintain that GMOs require more chemicals than 
conventional crops.  
o In Spain, there are no normative measures in place for co-existence, and according to 
public authorities/seed grower s, with 12 years of experience in Bt maizes no problems 
have been reported so far thanks to appr opriate good farming/co-existence practices.  
o For environment protection associations, co-exi stence is of concern as there are no rules 
of compensations of cross contaminations . If co-existence management costs were 
integrated in the cost chain, levels of use of GMOs by farmers would drop. 
o No problem of availability of GM/non GM seeds according to public authorities and 
innovators. Dependence to the seed industry is similar to conventional/hybrid seeds. 
o No problem identified so far by the beekeepers. 
o For public authorities and i nnovators, Bt maize harvests  contain less mycotoxins. 
o For public authorities and innovators, decrea sed use of/exposition to insecticides helps 
improving worker's health. The benefit would be  less clear with Herbicide Tolerant (HT) 
crops: Glyphosate is less toxic for users, but exposure to pe sticides can remain high as 
more herbicides can be used depending of farming practices.  
o For public authorities and i nnovators, patenting of the cr ops and prohibition of plant 
breeder's right is not perceived as an additi onal constraint or as an additional risk on 
availability of non GM varietie s, compared to hybrid crops.  Furthermore, the European 
seed industry will loose competitiveness if  it is not more involved in GMOs.  
o If there is – still or growing – demand for non GM seeds/products, even in local markets, 
seed producers will have an interest in pr oviding such products to the market place. 
o Since there is no legislation in the EU concer ning the presence of GM seeds in batches of 
conventional varieties, there is disparity in  the criteria and meas ures taken by Member 
states; therefore, a 100% GMO free or ganic farming cannot be guaranteed. 
Impacts on downstream operators 
o For the administration, GMOs contribute  to enlarge consumers' choice (GMOs, 
conventional, organic), decrease prices. Accep tance levels of Spaniards for GM food are 
among the highest of the EU (Eurobaromete r 2005: 74%). However, consumers can be 
misled by the lack of explanation on the fact that GM labels are not risk indications, and by "eco activists" campaigns. Better informa tion would help increasing acceptance levels. 
                                                
 
6 http://www.mapa.es/agricultura/pags/semi llas/estadisticas/serie_maizgm98_06.pdf  
 
EN 41   EN o Environment protection associa tions consider that GMOs hinder the freedom of choice of 
consumer as labelling do not mention when livestock was fed with GMOs, there is no "GMO free" labelling and the legislation i gnores long term health effects of GMOs. 
o Cooperatives and food industry handling GM  and non GM crops will have to cover 
relatively high costs of testing and segrega tion to guarantee the purity of their stocks. 
o The prices of the organic pr oducts will increase due to the segregation measures and the 
difficulty to access to non GM seeds ( ex ante  assessment). 
o Transport companies will have to face higher costs of segregation/ cleaning. The future 
regulation on Low Level Presence (LLP) s hould even more increase these costs. 
o Insurance companies do not propose GM  specific products for the moment. 
o Testing laboratories will perform more analysis with more staff, thus tests will be quicker 
and more efficient. Levels of tolerance thre shold can influence the costs of the tests. 
o For the moment, it is likely that costs of the controls required by disproportionate EU 
regulations may be higher than the financial benefit, therefore the net overall financial 
impact for the society is negative. 
Economic context 
o The divergence between MS on cultivation auth orisation or LLP, de spite the community 
authorisations, affects the internal market for goods. No identified impact on services. 
o The high regulatory costs have left the GM  traits market in the hands of few 
multinationals (for business, but also R&D capacity reasons), which could lead to oligopoly in the seed supply if the GM traits were not shared with other companies, i.e. 
hindering the internal market. 
Agronomic sustainability 
o The use of Bt maize in Spain re sulted in a reduction of 0,54 insecticide a pplications per ha 
(Gomez Barbero et all, 2008). 
o For the public administration, use of HT crops  based on a single herbicide without proper 
stewardship could end-up in increase of herbicides use when weed resistance develops. 
o For the public administration and the res earch institutions, no environmental impact 
should be expected since an a ssessment is performed at EU level. The 8 year experience 
of Spain with MON 810 shows that there is no risk. HT crops can have a positive impact 
when cultivated according to good farming practice. The impact of  cultivation of GM 
crops should be put into the perspective of  the modern cultivation practices, which can 
have harmful effects on the environment/biodiversity.  
o For innovators and public administration, the impact of GMOs on renewable/non 
renewable resources should be positive as plants will need less water/rotations to reach similar yields than conventional plants. Furthe rmore, less needs in insecticides/herbicides 
means less production, transport and r ecycling of these agro-chemicals. 
o Climate change: new GM traits could be more adapted to drier climate conditions. 
o CO
2 emissions: benefit expected due to reduced transport and applications of pesticides, 
and simplified tillage operations. 
 
EN 42   EN o Recent studies for indicate that if EU farm ers could use GM maize, cotton, soya oilseed 
rape and sugar beet varieties successfully used  elsewhere, farmer margins would increase 
by between €443 and €929 million /year (Park, J ., McFarlane, I., Phipps, R. and G. 
Ceddia, 2011. New Biotechnology ). 
o Plant biotechnology has an important role to pl ay in helping to achieve the Millennium 
Development Goals (Yuan et al ., 2011. Plant Cell Rep, 30: 249-265). 
Other implications 
o The balance of socio-economic implications may not be homogeneous for the different 
GMOs, for each GMO across the EU, or even w ithin a Member State. It should be up to 
the individual farmers to decide case by case the convenience to choose among those 
GMOs with a positive Opinion on its cultivat ion by EFSA and Member  State Authorities. 
 
EN 43   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Finland1 
1. ABOUT FINLAND  
o No cultivation of GMOs2. 
o Research activities on GMOs: 2 field trial notifications between 2002 and 20073. 
o No coexistence rules adopted4. 
2. GENERAL COMMENTS  
o The Finnish contribution is a compilation of answers received from the following 
stakeholders: MTT Agrifood Research Finl and; Finnish union of organic farming 
(FUOF); Finnish beekeepers association; Finnish Food and Drink Industry Federation 
(FFDIF); Professor in Microbio logy/University of Helsinki; Finnish Environment Institute 
(FEI), the Finnish Consumer's  Association (FCA), the Seed  Traders Association (STA), 
Finnish Forest Research Inst itute (FFRI), the Sugar Beet Research Centre Finland and 
professors of agro-ecology and plant br eeding of the University of Helsinki. 
o Answering to the questions considered ch allenging (only ex ante assumptions). The 
authorities asked the respondents to assess the potential impact of the first probable GM 
crops in Finland, i.e. potato and sugar beet. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Co-existence issues in the fi eld of potatoes are minimal.  
o Preventing the unintended spread of pollen and seed of GM plants is impossible. Possible 
contamination worries organic beekeepers. The legislation must ensure that the 
preconditions continue to exist for organic production. Beekeepers must have free access 
to information of places where GM-plants are grown.  
o Conflicts with neighbouring farmer s or other neighbours may arise. 
o Bees' health and quality of honey can be a ffected by low nutritional value of GM pollen. 
o Bees could go on non-food GM plants and polle n could be found in ho ney. All GM plants 
entering the market should be accepted for as human food.  
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by Finland, 
and was validated by Finland. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 44   EN o The competitive advantage of Finnish agriculture rests with GMO-free products.  
o Cultivation of GM potatoes may concentrate production further. However, GM production 
may support the visibility of organic farming (s tatus of an alternative mode of production) 
o Plant breeders: new traits via GM in existing varieties may boost the use of certified seeds 
and breeding of new varietie s. But limited access of conventional breeding companies 
may lead to a concentration of the business.  
o GM cultivation could lead to narrow the range of varieties under cultivation.  
o Additional challenge: to have  enough farmers and acreage for seed production as a whole.  
o Only a few plant-breeding organizations have had capacity to develop GM crops. 
Patenting has strengthened this trend. Revision of the criteria of patentability should be 
considered for broadening of the genetic base of crop varieties under cultivation.  
o Biotechnology has made possible deeper analys is of plant genetic resources and their 
improved use for plant breeding.  
o Investments in plant production research are likely to be increased. Focus should be on 
integrated approached to plan t protection, funded by public funds. 
o The availability of genetic resources for breeding is a prerequisite for Finland for all kind 
of breeding because it is not possible to use varieties used in other regions. Private seed 
companies may not develop appropriate varieties for Finland. Public research is necessary. 
Impacts on downstream operators  
o Impact on consumer choice if better quality and larger diversity of  products. Consumers 
must have a chance to make an informed choi ce. Consumers need to get a clear benefit. 
o Link between price, GM-charact eristic of goods and propensity  of consumers to buy them 
is not clear.  
o Cooperatives, grain handling companies, transp ort companies: handling, storage, logistics 
can be a problem.  
o Insurance companies: the fact that no insura nce in the world has developed services for 
GM farmers shows that the risk is too high and fully unknown. 
o Laboratories: controls will increase, thus unit price of analysis will decrease and quality of 
tests will increase. 
o Public administration: need for national enforcement policy, new guidelines, additional 
labours and other implementation costs. 
Economic context 
o Decrease in autonomy of farmers may be a concern but should not over-estimated. 
o Possible cross-border investments flows.  
o If the requirements call fo r rotation, the farm's busine ss becomes non-profitable.  
 
EN 45   EN Agronomic sustainability 
o GM potato has potential to decrea se the use of fungici des but risk of resi stance is possible 
over time. 
o There is an interest in the GM potato to re duce the production costs of seeds (losses due to 
viruses and mycosis are very high). 
o There is a possibility to redu ce the use of herbicides when cultivating HT sugar beet but 
the cultivation of HT rapeseed may in crease the amount of  herbicide used.  
o 2 HT beets were tested6 and demonstrate an economic be nefit in using the HT version. 
The risks and benefits of the GM varieties co uld be considered. Benefits would be: more 
reliable and flexible weed control, use of glyphosate (considered to be a low risk 
herbicide), reduced use of tractor (less fu el use and soil compaction). Risks would be: 
disappearance of other herbicides from the market, acceler ated appearance of HT weeds, 
HT gene moving to weedy relatives and causi ng a more problematic weed development, 
increase of the use of to tal mount of herbicides 
o GMO sugar beet and other GM crops are valuab le steps. It would be extremely important 
to make good evaluations for mi nimizing the environmental risk. 
o HT sugarbeet would diminish the quantity of weeds, which are important for bees, 
butterflies, and used as feed by many birds. 
o Impact of herbicides on ground waters. 
o Crossbreeding between the GM potato and wild relatives is impossible. 
o When cultivating HT crops, less biomass is produced which affects the biogeochemical 
cycle of soils. 
o Cultivation of transgenic potatoes may hinder/complicate crop rotation and increase the 
demand for fertilisers produced w ith non-renewable resources.   
o The efficiency of the use of field and fore st biomass can be improved by plant breeding 
based on new genetic know-how and by boosting the efficiency of production processes. 
Agricultural production requires prevention of  the environmental impacts of modern 
agricultural practices. GM crops  have shown efficiency in the reduction of chemical 
loading and erosion of agricultural environm ents. Crop yields can also be improved.  
o Warming may allow to cultivate rapeseed more northwards but could also increase 
variability of viruses. 
o New 'more adapted varieties should be develo ped. GM techniques are likely to speed up 
selection programs.  
o Organic agriculture would help  improving the state of the Baltic sea. If GMOs are 
expanded, this potential will be lost. 
o Transportation of GMOs is a risk for uncontro lled spreading and admixture. Very strict 
transport conditions are therefore necessary. 
Other implications 
o No answer. 
                                                 
6 1998-2000 
 
EN 46   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by France1 
1. ABOUT FRANCE  
o Cultivation of Bt maize until 20072. 
o Research activities on GMOs: 75 field trial notifications between 2002 and 20073. 
o Coexistence legislative framework adopted4. 
2. GENERAL COMMENTS  
o The French contribution consists in (1 ) an opinion of the High Council of 
Biotechnologies, consisting of an opi nion of its scientific committee  and a 
recommendation of its economic, ethical and social committee , (2) contributions by 
scientists from the Nationa l Institute of Research in Agronomy (INRA) and (3) 
contributions from 43 stakeholders. 
o The format and methodology of the questionn aire was challenged by several respondents. 
o The High Council for Biotechnologies ma de suggestions on the methodology and 
procedures to consider socio-economic factors in the proce ss of evaluation and 
authorisation of GMOs.  
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Seeds producers and growers stre ss that GMOs are effective tools for farmers to better 
manage pest pressure and prepare to the forthcoming climate changes. If properly 
regulated, co-existence s hould not be problematic. 
o For environmental associations and organic pro ducers, co-existence is inefficient in most 
of regions, thus non-GM farmers have to set self-protection measures that impact negatively their production cost. Furthermore, the commercial value of their products can 
be devaluated in case of adve ntitious presence of GMOs. 
o Environmental associations and organic producer stress that apiculture is at heart of the 
problem. Honey can contain GM pollen (with ne gative impact on the marketability of the 
                                                
 
1 This compilation was prepared by the Commission on the basis of the information provided by France, 
and was validated by France. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 47   EN products and by-products) and b ees can be vectors of diffu sion of GM pollen into non-
GM crop fields.  
o Environmental associations and organic producer consider  that GMOs increase the 
dependence of farmers toward seed/agroche mical companies, and make impossible the 
practice of farm-saved seeds. However, conventional maize producers stress that GM 
crops growers are not more dependant than those cultivating conve ntional hybrids. Such 
dependence is the consequence of the poli tical decisions taken at European and 
international levels. 
o Insurance companies do not propose insura nce schemes for adventitious presence of 
GMOs in non-GM harvests.  
o For seed producers, when pest pressure is significant, farmers can increase revenues by 
using Bt crops (less field work/spreading, high er yields, better quality of the harvest). 
However conventional and organic farmers stress  that the increasing price of GM seeds, 
associated to lower yields than announced by producers, can counterbalance these advantages. Furthermore, they consider that monoculture practice in Europe is the initial 
problem: with more annual rotations of cultures,  pest pressure would be much lesser, thus 
conventional crops would remain efficient. 
o In areas with GMOs, shared agricultural materi al will be more expe nsive or less available 
for all farmers, due to the highe r cost and length of cleanings. 
o As regards the cost of co-existence in genera l, reference is made to the study Coex1 by the 
Joint Research Center. Organic farmers and e nvironmental association consider that all 
co-existence costs should be covered by the GMO growers ("polluter pays principle"). 
o Seed producers and the association of maize gr owers underline that, when pest pressure is 
high, Bt maize harvest contai n significantly less mycotoxin than conventional maize. 
However, small and organic farmers stress that, even if the former is true, the mycotoxin rates in conventional crops remain much lower than European norms. 
o Farmers feeding livestock with GMOs have never experienced anim al health problems 
over the last ten years. They call for a bett er management of asynchronous authorisations 
of GMOs worldwide, to improve feed supply. Non-GM breeders highlight the difficulty to 
ensure proper GM-free feed supply as well , and the extra costs of the segregation 
measures, which cannot be valued unless a proper labelling exists. 
o The seed industry declares that they will k eep developing seeds for all markets, i.e. 
conventional, GM and organic. France being th e second exporter of seeds worldwide, GM 
seeds should be grown locally, what would be  possible if the maximum acceptable levels 
of adventitious presence of GMOs in  conventional seeds are not too low. 
o Farmers and environmental associations fear the development of patent protected events, 
which will increase legal uncertainty for fa rmers, who will have difficulties to know 
whether varieties they use are protected or not.  
o Seed producers consider that farmers a nd downstream operators are already well 
acquainted with the management/segregation of  separate varieties along the food chain. 
Inclusion of GMOs should not be a major issu e if adventitious presence thresholds are not 
too low. However, COOP de France underlines that the stricter thresholds for GMOs are 
more challenging. Environment/organic associati ons consider that su ch segregation will 
generate unbearable extra- costs for the non-GM food chai ns and for consumers of non-
GM food.  
 
EN 48   EN o Seed producers and maize growers regret that  France lost all its R&D expertise (public 
and private) on GMOs in the last  ten years (c.f. dest ruction of experiment al cultivations). 
Consequently, young researchers are not attracted by biotec hnologies, and France fully 
depends from innovations developed abroad. 
Impacts on downstream operators 
o Consumers, environment protection and conve ntional/organic prod ucers associations 
claim that consumers do not see any added va lue in GM food. 72% of French consumers 
think it is important to be able to c onsume GM free food. 60% of French consumers 
consider that France should better develop its conventional agriculture rather than GMOs. 
(source: sondage CSA/Greenpeace of 30-31 January 2008) 
o Clear labelling of food is important (GM food stuff and meat/milk from animals fed with 
GMOs). For 71% of French consumers, "G M free" must mean 0% of GMOs, and not 
0.9%). (source: idem above) 
o The increased cultivation of GMOs will have a qualitative and quantitative impact on the 
activity of testing laboratories. 
Agronomic sustainability 
o A micro-economic inquiry performed in 200 8 in 8 farms by AGPM concluded that 
MON810 allows reducing the use of insecticid es. Saving for farmers can be up to 93€/ha, 
depending of the number of applications. 
o Environment and organic associ ation contest the agronomic su stainability of GMOs over 
time, even if results could be positive in the first years. Furthermore, GMOs are associated 
to the intensive monoculture model, whic h agronomic sustainability is negative 
(fertilizers, over cons umption of water). 
o Seed producers consider that HT and Bt users can help limiting the use of renewable and 
non renewable resources (less tillage and spr eading), and sequestrati on of greenhouse gas. 
Environment and organic associations consider that same or better results can be achieved 
thought improved cultivation pr actice of conventional crops. 
Other implications 
o Several respondents underline th e need to address rapidly the challenge of world food 
crisis in the next 40 years. In crease of yields and more sust ainable agriculture practices are 
quoted among the cornerstones to consider , though with diverging opinions on the 
potential role to be played  by GMOs in this context. 
o Several respondents consider that the questionnaire should have taken into account wider 
problematics, such as self-sufficiency in food or agricultural policy of the Member States 
and the European Union. 
 
EN 49   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Hungary1 
1. ABOUT HUNGARY  
o No cultivation of GMOs2. 
o Research activities on GMOs: 26 field trial notifications between 2002 and 20073. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Only estimations of ex ante impacts are in the report, which are considered highly 
dependent of regional/national characteristics of where the GM cultivation takes place. 
o Hungary considers that a new system of eval uation should be set up, inspired by Norway, 
where the impact assessment of a GM rele ase should consider health, environment, 
benefit to society (in both the producing a nd the receiving countries) and promotion of 
sustainable development. 
o The contribution contains two studies: 
- Economical impact of the introduction of  GMOs into the Hungarian Agriculture 
(György Pataki, Réka Matolay);  
- Norwegian assessment guide: Sustainability, Benefit to the Community and Ethics 
in the Assessment of Genetically Modifi ed Organisms: Implementation of the 
Concepts set out in Sections 1 and 10 of the Norwegian Gene Technology Act 
(The Norwegian Biotechnology Advisory Board). 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Surveys of farmers show negative opini on about the benefits of using GMOs. 
o Cross-contaminations are unavoidable (cf inte rnational practices). Extra costs due to 
laboratory test for GMO cont amination will increase pro duction costs and tensions 
between farmers. 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Hungary, and was validated by Hungary. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 50   EN o Experience in Spain shows that organic agricu lture has drastically decreased in regions of 
GMO cultivation. Biotech products do not have added value for consumers therefore support to organic agriculture seems to be  more economically rational in terms of 
agricultural policy. 
o Yields are not improved, according to in ternational studies (including USDA 2006). 
o International experience with GMOs shows adva ntageous effects for large scale farmers. 
However, increase of profita bility cannot be unequivocally  established or proved. The 
decrease of use of pest/weed control materi als tend to reverse af ter 3 years (due to 
resistances), impacting the margin of the farmer's cost. 
o Hungary is the second maize producer in Europe  (food, feed and sowing seed), with 2/3 of 
its export. They get high premiums on th e market due to their GMO free status.  
o Use of GMO can lead to less labour needs. The local populations should be maintained by 
agriculture. The Hungarian fa mily based model of agriculture should be preserved. 
o Seed producers will have to se t up segregation systems. Hu ngary wants to preserve its 
capacity to produce GM-free seeds (clear ma rket advantage on the export market). 
o GM seeds are more expensive and lead to loss of the farmer's privileges (re-plant, 
exchange of seeds), thus loss of incomes. 
o Organic/conventional farmers will have to set up co-existence measures and perform 
purity tests.  
o Co-existence implies establishing buffer zones. This is not possible in Hungary due to the 
land ownership characteristics: small plots, prominence of numerous small families. 
o If adventitious presence is beyond 0,9%, pri ces of conventional/organic goods will drop. 
GMOs can decrease the profita bility of farmers and indus try using non GM materials. 
o There is a need for a study on the impact of GMO cultivation on farmers' revenues, based 
exclusively on European data or estimations. 
o Beekeepers are firmly opposed to GMOs as coexis tence is inefficient (b ees fly up to 6 km 
away).Furthermore, according to a Hungarian  study (Békési, 2006) adverse effects have 
been shown on the chance of the larvae’s survival and the adult bees’ resistance to the Nosema apis  microsporidian parasite. 
o If large scale GMO cultivation is introduce d, demand for conventional/organic seeds will 
decrease. Production of such seeds will also  be more difficult (available land, buffer 
zones, etc), more costly and risky (marketing price in case of adve ntitious presence). 
Overall, loss of profitability of the whol e conventional/organic se ctor, leading to its 
vanishing. Local and traditiona l varieties may disappear which also means that without 
customs the domestic plant breeding institutes will have difficulties to survive. 
o The whole seed business would be concentrated in the hands of very few multinational 
seed companies. Hungary considers this as  an "internal safety  issue for the EU". 
Impacts on downstream operators  
o The majority of the consumers both in Europe  and in Hungary, is not in favour of GM 
based foods.  
o Cost of co-existence will impact marketing price and the profitabi lity of the non GM 
sector. 
 
EN 51   EN o Cooperatives, grain handling companies: Co-existence will increase cost of 
handling/transport. It will be more difficult to produce GM free products.  
o Transport companies: Segreg ation will make the process more complex and slower.  
o GM promotes the model of integrat ed, monopolistic production and marketing. 
o Insurance companies consider this field too ri sky, no products have been  developed so far. 
o Profits of laboratories will increase but th ey will face difficulties with stacked event 
GMOs.  
o Independent research on ri sks is being hampered by obstructive behaviours of the 
industry, and difficulties to access res earch material due to patents. 
o Public administration: management of co-exi stence measures and post market monitoring 
will increase costs for the administration (m ore expert knowledge and staff in controlling 
authorities). If contamination occurs, it generates extra costs due to national compensation 
found, or increased cases taken to Court. 
Economic context 
o Free movement of conventional/organic seed/f ood/feed will be hampered. This will also 
infringe the free choice of farmer s, operators and end consumers. 
o When assessing the impacts of the placing on the market of GMO seeds on the internal 
EU market, its implications on national economies of particular Member States – especially which are the signi ficant producers in the affect ed sector – including Hungary 
should also be taken into account. 
o Dependence of the EU market from few non European multinational has a negative 
impact on the European economy. 
o In a context of export markets not accepting GM  maizes, regions cultivating these crops 
suffer a decrease in the income of farmers and other economic acto rs. This leads to 
decrease in market shares and to a rise in production co sts (segregation and identity 
preservation). 
o Hungarian regions are not affected by the corn borer (so they have no interest in MON810 
or similar Bt maize). Corn borer is not a si gnificant pest, which only appears once in every 
ten years in the southern part  of the country. Even in this case, maize can be protected 
against the pest by using traditional agricultural techniques. 
o GM production requires intens ive farming model. This deepens the dependence on high 
energy and resource use, leads to rising clim ate emissions, and concentrates the lands in 
fewer hands.  
o GM production models require less work ers (increase of unemployment).  
o There is a high risk put on the regional biodi versity in Hungary, which is an important 
economic driver (number of GMO free regi ons is constantly rising in Hungary). 
Agronomic sustainability 
o No local experience, but international data de monstrates that GMOs lead to higher use of 
weed/pest control inputs. 
o Introduction of GMOs endangers the agricultur al and natural ecosystem. Hungary is one 
of the zones with high biodiversity in Europe, therefore does not accept to take any risk 
 
EN 52   EN where consequences cannot be anticipated be forehand. It is well know n that the European 
Union gained a significant environmental c ontribution with the accession of Hungary. A 
price can basically not be put on the economic va lue of this asset, a lthough it also appears 
in several sectors besides agricu lture (for example, tourism). 
o Several research publications showed that the MON810 GM maize could cause 
remarkable damages in the population of Peacock  butterfly which is protected in Hungary. 
o Extensive cultivation of uniform, high yieldi ng crop varieties can cause the replacement 
and loss of traditi onal crop varieties. 
o GMOs cultivated intensively are dependent on high energy and resources use. Therefore 
GM cannot be considered as a sustainabl e farming method. Furthermore, intensive 
agriculture affects th e quality of soils, water and groundwater. Moreover, additional CO 2 
gas emission can come from usi ng crop protection products and/or artificial fertilizers, or 
tillage. 
o Emerging of weeds tolerant to herbicides l eads to more herbicides use (glyphosate and 
older chemicals). 
Other implications 
o No answer 
 
EN 53   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Ireland1 
1. ABOUT IRELAND  
o No cultivation of GMOs2. 
o Research activities: 1 notifi cation between 2002 and 2007 (potato)3. 
o No coexistence rules4. 
2. GENERAL COMMENTS  
o The Irish policy is based on the objective in the Renewed Programme for Government 
(October 2009) to declare the Re public of Ireland free from th e cultivation of GM plants. 
o Ireland would favour modification of the regul atory framework to allow Member States 
greater autonomy in decision-making on the cultivation of GM crops and the 
strengthening of environmental risk assessment procedures.  
o A significant artisan food sector has emerge d in recent years, in response to strong 
consumer demand for locally produced, hand-crafted food products.5  
o The Irish contribution summarises the 53 co mments received by the Department of the 
Environment, Heritage and Local Government . The submissions can be categorized as 
follows: academic R&D; agribusiness R&D;  beekeeper; consumer; farmer; organic 
farmer; Government agency; industry repr esentatives and interest groups/NGOs.  
o The contributions indicate a predominantly negative attitude to GMOs among the public. 
A number of respondents felt that Ireland w ould benefit economically and socially by 
maintaining a GM free position and by mark eting agricultural produce accordingly. 
o The Environmental Protection Agency (EPA) suggested that EU Member States should 
include an assessment of soci o-economic implications prior to a decision on GM crop for 
cultivation, as is th e case in Norway.  
o IGFA considers that it should be left to the normal worki ng of the market to recognise and 
translate the socio-economic f actors through supply and demand. 
o The lack of inclusion of a stand-alone “ human health” category was queried by several 
respondents, indicating a wish to  see separate processes in terms of environmental risk 
assessment and health risk assessment, as  part of the authorisation process. 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by Ireland, 
and was validated by Ireland. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 Food Harvest 2020: A Vision for Irish Agri-food and Fisheries , http://www.agriculture.ie/  
 
EN 54   EN 3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE6 
Economic and social implications 
Impacts on upstream operators  
o According to a study carried out by Teagasc7, late blight potato is a major problem in 
Ireland (annual losses estimated at 15 million€ per annum). Currently, under Irish climatic 
conditions, in order to protec t the potato crop, this pathog en requires as many as 14 
fungicide applications during the planting season to ensure  adequate protection. Net 
benefit to the grower using b light resistant GM potatoes has been estimated to be above 
198€/ha. 
o The study carried out by Teagasc also concl uded that there might be a positive economic 
impact with little social impact if certain GM crops were cultivated by Irish farmers. 
o Multiple respondents on behalf of farmers and the farming sector felt the current GMO 
model is of benefit primarily to very larg e-scale mono-culture type production and that 
this was not a model of production which w ould prove suitable for the Irish market. 
o Most farmers and farmer representative groups  are opposed to GM crops and feel that 
their business would be nega tively impacted by GM cultivation. Respondents feel that 
GM-free status offered far more economic potential and would allow Irish farmers to 
access higher value markets. However some tillage farmers respondents feel limited by the current GMO policy while having to  compete against imported GM products. 
o According to the Irish Cattle and Sheep Fa rmers Association’s, GM seeds are more 
expensive (Source: DG Agri, 2000). 
o Organic farmers feel their business would be negatively impacted (coexistence, additional 
costs, damage to Ireland's organic strate gy, lack of availabili ty of GM-free feed. 
o Beekeepers feel that consumer perception of Irish honey would be severely damaged if the 
end product was perceived to be GMO c ontaminated. Respondents query the legal 
protection available to beekeepers to protect against financial loss due to the reduced marketability of their product or for the es tablishment of beehives in GMO cultivation 
areas. 
o Conventional and organic seeds: additional measures would be required to protect against 
GMO contamination and there would be increa sing costs associated with the protection 
and certification of geneti c purity of seed lines.  
o The Agricultural Science Association noted that the glyphosate resistance of GMO crops 
increases the flexibility of timing and reduces  the number of applicat ions required. This 
could allow for increased labour flexibility. 
o Cost of coexistence is difficult to quantify due to the lack of experience. Comments 
received suggest that it would seem appropriate that GM cultivators would bear responsibility for the cost of  any co-existence measures. 
                                                
 
6 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
7 Flannery, M. et al, An Economic Cost-Benefit Analysis of GM Crop Cultivation: An Irish Case Study, 
AgBioForum, 2004, Vol. 7, No. 4, p. 149-157   
http://www.gmoinfo.ie/index.php?option= com_content&task=view&id=76&Itemid  
 
EN 55   EN o When considering social aspects, most farmers focused on the problem of cross-
contamination. ICSA in particular underlined  that agricultural la nd use of Ireland and 
farming practices are not conducive with coexis tence due to the interconnections of Irish 
agricultural systems. This could thus result  in disputes between neighbouring farmers. 
o The Agricultural Science Association believes th at the issue of farmer training is critical 
in preventing widespread di sharmony and is highlighted in the Irish coexistence 
guidelines.  Training would be required for producers and also for their neighbours. 
o The ICSA consider that, from a farmer’s point of view, the implicati ons of seed patenting 
is disturbing. The right to produce your  own seed must not be undermined.  
Impacts on downstream operators 
o Several NGOs and consumer respondents argued that an increase in GM crops would have 
a negative impact on consumer choice, espe cially if coexistence is impossible.  
o Where non-GM sources of soya and maize (use d as animal feed) carry a significant price 
premium (Benbrook, 2009) this could mean that  production of Irish li vestock products is 
at a disadvantage relative to international competitors. 
o The Irish Grain and Feed Association considers that all stakeholders in the feed/food chain 
must have equal access to the best  available scien tific technology.  
o Public administration: checking complian ce with legal regulations and additional 
administrative requirements will incur si gnificant administrati ve expenditure.  
Economic context 
o The Irish Grain and Feed Association feels th at the EU system favours the large players 
due to increased cost and complexity. This has discriminated agai nst smaller indigenous 
players and fostered market dominance by the largest private seed companies.  
o The Irish Grain and Feed Association consid ers that intellectual property rights are a 
corner stone of the EU competitiveness agenda and apply to all agricultural stakeholders.  
Agronomic sustainability 
o This question cannot be answered conclusive ly based on Irish data (no GMO cultivation). 
o According to IGFA, it is the informed application of the correct agronomic practice for 
different conditions that deliver sustainabili ty. No single technology can deliver alone.  
o Farmers could use fewer chemicals (Spanish  experience). The ongoing revision of the EU 
Plant Protection Products (PPP) legislation se eks at reducing PPP a pplication rates. The 
use of blight resistant potatoes through traditional or GM breeding techniques may have to replace the use of PPP. 
o The EPA refers to post market monitoring pl ans in Spain over a ten year period that 
concluded that no adverse effects on non-target  arthropods or soil micro-organisms have 
been observed in relation to the use of Bt crops.  
o HT crops: 1) Potential advantages: enhanced flexibility in weed control, use of less 
persistent herbicides and less frequently, facilitate low or no tillage cultural practices 2) Potential disadvantages: emergence of HT weeds populations (not linked to the GM 
characteristic), potential gene flow to related weed species. 
 
EN 56   EN o The herbicide programme used on GM oilseed rape and sugar beet had a negative effect 
on biodiversity (fewer weeds la ter in the season for organi sms at higher trophic levels 
(e.g. farmland birds) compared to conventiona l management. This is not seen for HT 
maize.8  
o GM varieties did not deplet e the soil of weed seeds.9  
o The EPA considers that Post Market Monitori ng plans performed by  the notifiers should 
be audited by authorities.  
o Teagasc underlines that the adoption of HT  crops must be completed with a weed 
management strategy.10  
o Teagasc considers that GM crops relevant to Ir ish agriculture would not  pose a risk to bee 
populations as the traits are not insect targeting. However, according to the Banner 
Beekeepers Association, in mono-crop areas, bees could have a poor diet. 
o The Teagasc CINMa index has highlighted that the use of crops with increased nitrogen 
use efficiency would reduce nitrogen app lication by 40%, signifi cantly reducing runoff 
into water and air. 
o Bioremediation (use of GMOs to remove toxi c pollutants from the environment) was cited 
as possibly having a positive environmental impact, based on international examples. 
o The EPA and Teagasc underline that when cul tivating HT crops, less weed biomass would 
be produced which could affect the biogeoche mical cycles of soils. However, using GM 
blight resistant potato would decrease the nu mber of PPP applications and thus the 
compaction of soil.  
o The EPA considers that GM crops could ha ve a positive impact on energy requirements 
and fuel consumption by using less fuel resulting from minimum tillage cultivation and lower amounts of Plant Prot ection Products applications 
o The EPA considers that GM O technology could positively impact climate change via: 
o Carbon sequestration (reduci ng the amount of ploughing in  conventional tillage). 
o Reduced fertilizer use and N
2O (nitrous oxide) green house gas emissions. 
o Produce crops to improve the climate impact of ruminants.  
o Possible need for more specialized forms of transportation to avoid admixtures. 
Other implications 
                                                 
8 The Farm Scale Evaluations;  
http://webarchive.nationalarchives.gov.uk/200803 06073937/http://www.defra.gov.uk/environment/gm/f
se/ 
9 Botanical and rotational implications of genetically modified herbicide tolerance in winter oilseed rape 
and sugar beet (BRIGHT Project); http://www.hgca.com  
10 Hurley et al. (2010), Effects of  Weed Resistance Concerns and Resi stance Management Practices on the 
Value of Roundup Ready® Crops, Journal of Agrobiotechnology, Management and Economics, Vol.12, 
Article 5. 
 
EN 57   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Lithuania1 
1. ABOUT LITHUANIA  
o No GMO cultivation2. 
o No Research activities on GMOs. 
o Coexistence rules adopted3. 
2. GENERAL COMMENTS  
o The Ministry of Environment of Lithuania provided an extensive study on the socio-
economic implication of GMOs which are author ised in Lithuania. In this document, two 
kinds of GM products were analysed: food and feed. The conclusions of this study are not 
directly relevant in the c ontext of this exercise.  
o The socio-economic implications  of GMO cultivation were no t analysed. Research on GM 
products in Lithuania is primarily focuse d on public opinion, labelling procedure and 
cultivation opportunities. There has been little research into  the economic aspects of the 
use of these products on a national level.  
o The study analyses:  
o The place of GMOs in the food and feed markets 
o The impact of GM food and feed on the social environment (in the EU and in 
Lithuania, controls, public attitude, a ttitude of business representatives) 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Lithuania, and was validated by Lithuania. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: idem footnote 2 
 
EN 58   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Luxembourg1 
1. ABOUT LUXEMBOURG  
o No cultivation of GMOs2.  
o Research activities: information not available3. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Introductory statement in which Luxembourg supports the inclusion of socio-economic 
criteria in the authorisation proce dure of GMOs at European level. 
o Luxembourg does not grow GMOs, so they have  no ex post experience  to report, and in 
general they had difficultie s answering the questions. 
o Luxembourg welcomes the socio-economic criteria proposed by the Dutch COGEM. 
However, implementation details should be discussed at European level. 
o Freedom of choice of farmers and consumers is an important socio-economic criterion. 
Farmers favour GMO free cultivation in L uxembourg, so co-existence measures are 
necessary, even though not always sufficient. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Farmers of Luxembourg have no economic intere st to cultivate: Bt or HT GM are not 
useful; anticipated problems to market the harvest in a str ongly anti-GMO market; 
Liability in case of adventiti ous presence of GMOs in conve ntional/organic seeds remains 
an issue. 
o Yields and quality of the ha rvest are not expected to in crease. GM crops prices are 
expected to be low due to the reluctance of the Luxemburguese market towards GMOs. 
Conventional crops should obtai n a premium, however they ar e also at risk of being 
devaluated in case of adventitious presence of GMOs.  
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Luxembourg, and was validated by Luxembourg. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 59   EN o Furthermore, co-existence measures will incr ease the production costs, hence impact the 
gross margin of farmers. Co-existence will al so interfere with farming practice such as 
rotations. Thus cost of co-existence measur es must be supported by the GMO growers. 
o GMO growing might disturb the cooperation between farmers since it would no longer be 
possible to share machineries due to segregation needs. 
o GMO seeds are more expensive, so probably they will not lower the production costs. 
o Occurrences of GMOs will incr ease the cost of production of conventional and organic 
seeds due to co-existence measures and management of adventitious presence. 
o The farm saved seeds are limited due to the patents linked to the GM crops.  
o Organic farmers can be negatively impacted  by adventitious contamination (loss of 
organic labels, organic premium) and costs of preventive measures (co-existence, controls, 
analysis) 
o Co-existence measures are inefficient to pr otect beekeepers of GM contamination of the 
honey. Thus, the honey would be almost impossibl e to market. Beekeepers are particularly 
vulnerable regarding (vol untary and unintentional) dissemination of GMOs. 
o The quality of harvest shoul d increase for Bt maizes. 
o Impact on health of workers is not demonstrated  as reduction in agricultural toxic inputs is 
not obvious. 
o Costs of alternative pest/weeds control pr ogrammes are well known, but no data are yet 
available on the cost of GMO resistance management.  
o GMOs reinforce the concentration of the seed  sector into few majo r actors, generating a 
loss of diversity, while sustainable agricu lture needs a wide variety of seeds. 
o The growing of GMOs risks to increase the cost of seed multiplying companies, seed 
producing farmers and seed distributors due to segregation measures (for GM, 
conventional and organic actors). 
Impacts on downstream operators  
o A large majority of consumers are opposed to GMOs. 
o Segregation will increase costs fo r all actors of the food chain. 
o Laboratory tests are already expensive due to inadequate testing methods and high costs of 
the reference materials. The increase of GMOs  authorisation will increase testing costs. 
o Public administration: if more authorisations are granted, public admi nistrations will have 
to increase control measures.  
Economic context 
o More GM crops will lead to less diversity of varieties and species used by farmers, 
marketed by few major seed companies. 
Agronomic sustainability 
o No local data, but based on international stud ies Luxembourg denies the benefit of GMOs 
in term of reduction of agricultural input s (even increase of pesticides use). 
 
EN 60   EN o Loss of diversity due to concentration of  the seed industry, affecting negatively 
biodiversity, including animals (migration r outes, ecological corridors). Furthermore, 
possible negative effect on non-target organisms. 
o Current GMOs do not demonstrate clear-cut positive effect on use of renewable and non-
renewable resources. 
o Due to segregation measures, transport of agricultural raw material will increase. 
Other implications 
o No answer 
 
EN 61   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Latvia1 
1. ABOUT LATVIA  
o No GMO cultivation2. 
o Research activities: no field tr ial notification between 2002 and 20073. 
o Coexistence rules have been adopted4. 
2. GENERAL COMMENTS  
o LV Ministry of Agriculture funded a study in 2007 on "Economic evaluation on growing 
of GM crops in Latvia". Findings are spread in the contribution, following the questionnaire's categories. 
o A public questionnaire “For or Against GMO in  Latvia” was organized by the Ministry of 
Environment of Latvia during the period of December 10, 2008 – March 10, 2009. There 
were 37.440 respondents
5:  
- 95% of all the respondents are against GMO cultivation;  
- 94% of all the respondents are agai nst GMO ingredients in fodder;  
- 96% of all the respondents are ag ainst GMO ingredients in food; 
- 91% of all the respondents are for GMO free zone. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE6 
Economic and social implications 
Impacts on upstream operators  
o Cost of co-existence measures, theoretically  calculated, would be high and would over 
costs the potential benefits of GM  cultivation. Main reasons are: 
- small size of the fields 
- conflicts with neighbours and neighbouri ng countries would be unavoidable and 
serious - Insurance companies don't want to insure GM crops 
- less opportunities to sell the harvest due to labelling 
- high risk for beekeeping industry in  case of GM rape seed crops 
                                                
 
1 This compilation was prepared by the Commission on the basis of the information provided by Latvia, 
and was validated by Latvia. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 total population of Latvia by Eurostat data at 1 January, 2009: 2.261.294 inhabitants 
6 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 62   EN o Based in the above mentioned study, potential  losses are linked to the following business 
activities (be it professional or amateur): organic farming, seed farming and seed 
production centre for highest class of seeds (e specially for cruciferous), beekeeping, rural 
tourism. 
o Regarding the possible damages of GM cr ops, comparison is made with Heracleum 
sosnowskyi Manden. 
Impacts on downstream operators 
o Impact on consumer information and protection is mentioned.  
o Potential impact on laboratories is mentione d, especially regarding the price of the 
analysis. If the number of GMO samples signif icantly increases, it will cause employment 
growth. This will imply more need for training and expensive new equipments.  
o Seed testing laboratories, working on conven tional seeds quality, would face additional 
costs to ensure purity and coexistence. Prices would increase.  
Economic context 
o So far, no impact of GM seeds on the seed market (less importance of GM seeds due to 
climatic conditions).  
o Regarding the internal market for services, there could be an impact for State plant 
Protection Service involved in control and mon itoring of coexistence conditions in Latvia.  
o Following potential impacts are mentioned: fa rms' size, increasing monoculture, loss of 
reputation for other activities in the same region. 
o Based on the 2007 research project, the largest losses are expected in  the Vidzeme region 
(27,6%) and Kurzeme region (26,2%). In these regions, the expected losses exceed 50% 
of all potential losses in organic farmi ng in the country, which may result from 
uncontrolled spread of GM products.  
Agronomic sustainability 
o There is no GMO cultivation, so no impact on the agricultural inputs.  Thought theoretical 
impacts are mentioned in some cases (potential to reduce use of pesticides or/and patterns 
of use of chemical herbicides.  
o Potential impacts on biodiversity are mentioned for number of agriculture 
species/varieties, agriculture diversity, protected  or endangered specie s and their habitats, 
ecologically sensitive areas, migration route,  ecological corridors, buffer zones, flora, 
fauna and landscapes.  
o Latvia is considered as one of the riches t European countries regarding biodiversity 
resources. GMO cultivation may have negative impact on biodiversity.  
Other implications 
o No answer 
 
EN 63   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Malta1 
1. ABOUT MALTA  
o No GMO cultivation2 
o No Research activities on GMOs3 
o coexistence rules: no information available4 
2. GENERAL COMMENTS  
o Maltese authorities envisage th at, should GMO cultivation take  place, a number of socio-
economic impacts would occur, most not ably affecting the agronomic sector. 
o Maltese agriculture is quality oriented. Gove rnment and private sector are engaged in 
efforts and initiatives (including funding) that promote and encourage quality schemes 
including organic production. 
o It is recognised that GMO cultivation would je opardise these investments due to the fact 
that it is very difficult to apply co-existen ce measures in the context of the Maltese 
agricultural landscapes (inten sive and mixed cropping, sma ll-scale agriculture, high 
density of fields in close proximity). 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o In general and as a result of targeted consul tations on the subject, th e public and relevant 
stakeholders have repeatedly expressed thei r opinion that Malta should remain GMO-free.  
o Extensive consultation would need  to be carried out with the relevant stakeholders on the 
envisaged impact of GMO cultivation and, theref ore, Malta is not in a position to provide 
any feedback at this stage.  
Impacts on downstream operators  
o Extensive consultation would need  to be carried out with the relevant stakeholders on the 
envisaged impact of GMO cultivation and, theref ore, Malta is not in a position to provide 
any feedback at this stage.  
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by Malta, 
and was validated by Malta. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 64   EN Economic context 
o Specific regions and sectors: see general comments. 
Agronomic sustainability 
o EU-approved GMOs for cultivation are MON 810 maize and Amflora potato. Maize is not 
viable in Malta (lack of water) and there is no maize relative. However, EU-approved 
GMOs which do not have approval for cultiva tion may have an impact on non-agricultural 
species/varieties. Authorisation of GM oilseed rape could compromise the wild genetic pool of Brassicaceae (22 varieties of Brassicaceae, most of which are f ound in the wild 
and have a flowering period with overlaps with GM oilseed rape). 
o GM crops are an intensive monoculture sy stem with no tillage and no crop rotation; 
therefore agriculture dive rsity would decrease considerably in an area.  
o The Maltese islands have 46 national and in ternational ecologically sensitive areas 
dispersed in a territory of 316 km
2. GMO cultivation would be either in or in the vicinity 
of one of these areas. Therefore an impact on protected fauna or wild flora would be 
inevitable (hybridisatio n with wild stock, increase herbic ide use, degree of monoculture, 
decrease in crop rota tion, in tillage).  
o Maltese landscapes are known for their colourfu l nature due to the fact that fields are 
mostly less than one hectare and surrounded by rubble walls to reduce erosion and mark 
field boarders.  
o Thus multiple ownerships occur in a large agri cultural area unlike in the rest of Europe 
where such a large area woul d be owned by a single farmer. The colours mentioned earlier 
are made up of the variety of crops that w ould be found in a multiple owned area (farmers 
growing different crops). If GMO cultivati on would take place, to be viable, farmers 
would have to grow the same crop (with the farmers on the borders growing refuge plants). This would destroy the landscape and biodiversity a nd affect the flora and fauna 
of the area. 
o Considering renewable and non renewable resour ces, climate, transpor t and use of energy, 
extensive consultations w ould need to be carried out with the relevant stakeholders on the 
envisaged impact of GMO cultivation and, theref ore, Malta is not in a position to provide 
any feedback at this stage.  
Other implications 
o No Answer. 
 
EN 65   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation  of the contribution  
by the Netherlands1 
1. ABOUT THE NETHERLANDS  
o No cultivation of GMOs2 
o Research activities on GMOS3: 59 notifications betw een 2003 and 2007 (carnation, 
potato, apple, maize). 
o Coexistence rules adopted4 
2. GENERAL COMMENTS  
o NL answer consists in (1) a filled in questi onnaire, (2) a report by the advisory committee 
on GMO (COGEM) on socio economic aspects of GMOs, (3) a report by the agricultural 
economic institute (LEI) on economic effects of the EU GMO policy. 
o COGEM report: COGEM was requested to draw up socio-economic criteria for the 
application of GMOs in agriculture, includi ng sustainability aspe cts. COGEM considers 
that sustainability relates to social, economic and environmental aspects. It is not a static 
concept, but a dynamic one, which depends of  the context (e.g. society, culture and 
religion), time, knowledge, tec hnological capabilities, etc.  
o Using conventional agriculture as a frame of  reference, COGEM suggests the following 
nine criteria as "building blocks" for an assessment framework on the socio-economic and 
sustainability aspects of GMOs: 
1. Benefit to society - increase in yields, ha rvest security and other forms of general 
benefit to the society;  
2. Economics and prosperity - contribution/impr ovement of local and overall prosperity 
and of the economy;  
3. Health and welfare – pres erve/improve, for workers, the local population and 
consumers;  
4. Local and general food supply;  
5. Cultural heritage – if desired, specific elem ents of cultural herita ge or local customs 
should be preserved;  
6. Freedom of choice – both consumers and pr oducers should be able  to choose between 
GMO and GMO-free products; 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by the 
Netherlands, and was validated by the Netherlands. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: information provided by the Ministerie van Economische Zaken, Landbouw en Innovatie of the 
Netherlands. 
 
EN 66   EN 7. Safety – in terms of both personal health and the environment;  
8. Biodiversity - does not a) lead to a reduction in the agro-biodiversity of the 
agricultural environment and wher e possible strengthens it, and b) damage protected 
or vulnerable biodiversity;  
9. Environmental quality - The production a nd processing of GM crops means that a) the 
quality of the soil, surface water and groundwater, and air,  does not deteriorate and, 
where possible, is improved and b) the emission of greenhouse gases along the entire 
chain (development, production, processing and transport) re mains neutral or declines 
relative to conven tional agriculture. 
o Several elements are already part of existin g European assessment/regulatory frameworks 
(e.g. environmental quality, freedom of choice). Th erefore, the criteria relevant for socio-
economic evaluation of cultivation of GM crops in  Europe that are not yet existent are: (1) 
Benefit to society, (2) economics and prosper ity, (3) Cultural heritage. COGEM notes that 
for the operationalization of the criteria it woul d be desirable that the indicators used to 
measure the criteria: a) are objectively measur able, and b) can be estimated in advance. 
Such indicators are not yet read ily available for all criteria. 
o In an accompanying letter, the Dutch authoritie s indicate that it is important that when 
considering cultivation of ge netically modified crops in the EU Member States, these 
three themes, which cannot be assessed on the basis of the current regulations, can be 
taken into account. By giving Member States the possibility to decide on cultivation of 
GMOs on their own territory, Member States can  gain experience on these themes, if they 
so wish. To be able to a pply the criteria in practice, objectifiable and measurable 
indicators must be developed for use with th ese criteria. Furthermore, WTO compliance is 
important.  
o The COGEM report also points out that all 9 cr iteria are relevant for cultivation outside 
Europe followed by import into Europe. Howe ver, COGEM indicated that, in view of 
trade relations, as well as politically and le gally, it is much more complex to draw up an 
assessment framework for sustainability of import than for cultivation in the EU. 
o COGEM also notes that the intr oduction of an assessment of th e sustainability aspects of 
GM crops could raise questions concerning the sustainability of certa in conventional crops 
and cultivation methods which at present, ar e not assessed in this way. COGEM points out 
that the rejection of a GM crop on the basi s of socio-economic arguments, while these 
equally apply to conventional crops that are not subject to such criter ia, could be met with 
incomprehension. 
o The report by the Agricultural economic institute (LEI) on economic effects of the EU 
GMO policy concludes that asynchronous EU approval of GM crops coupled with the 
operation of a zero tolerance threshold for th e presence of GMOs not yet approved in the 
EU causes trade disruptions. This problem will increase with the more widespread cultivation of GMOs outside the EU and can damage the competitive position of European 
industry and lead to loss of employment. 
o "GMOs in European Agriculture and Food production", report of the conference 
organised in The Hague (25-26 Nov 2009). 
 
EN 67   EN 3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o NL has no experience in cult ivation of GMOs: only ex-ant e estimations of the socio-
economic consequences of GMOs. In the future farmers could be interested by GM potatoes (Amflora and another multiple fungi  resistant trait currently developed). 
o Several studies conclude that socio-eco aspects of gm crops  should be assessed on a case 
by case basis, taking into account the specific ch aracteristics of the GMO event, but also 
aspects like the cropping system, use of good farming practice or the climate or region 
where the cultivation takes place. 
o GM, conventional and organic growers alread y agreed on co-existence measures, which 
will be formalised by the Dutch product board for arable products. Co-existence measures are of vital importance to avoid economic damages for the non GM producers. 
o Seed industry: experience with imports show high co sts for checking potential 
adventitious presence of GMOs in s eeds and segregating distribution lines. 
Impacts on downstream operators  
o There is no GMO cultivation so no impact. 
o For food containing GMOs, EU labelling requ irements guarantee freedom of choice for 
consumers. 
o If GMOs come to the market, limited extra administrative requirements to be expected: 
obligation for the farmer to register the place of cultivation and for th e industry to register 
which GMO will be processed and when (by using existing traceability systems). 
o Furthermore, measures will be necessary  to avoid mixture of GMOs and non GM 
commodities during storage, transport or processing. 
o No GMO specific insuran ce product for the moment. 
o Laboratories: no current experience, but future  development would result in an increase in 
demand of GMO analysis. 
o Innovation and research: no or very few research  in GMOs by public players in NL. SMEs 
are discouraged by the very high development/authorisation costs. 
o Difference in definition of GMO between the EU  and the USA is mentioned as a source of 
legal uncertainty, hence decrease in invest ment and development of new seeds which 
stunts innovation and can negatively impact progr ess in the field of sustainability. Seed 
producers would need more clarity on th e status of new breeding techniques. 
o Public administration: no costs related to cultivation for the moment. Focus on contained 
use, field trials and imported GMOs. 
                                                 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 68   EN Economic context 
o No impact observed on the internal market as no cultivation for the moment. 
Agronomic sustainability 
o Since there is no commercial cultivation of  GMOs in the Netherlands, there are no 
observed impacts in the Nether lands on the mentioned topics. 
o As regards climate change, possible future cultivation of GM potatoes could lead to 
cheaper and more environmenta lly friendly starch production. 
Other implications 
o No answer 
 
EN 69   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Portugal1 
1. ABOUT PORTUGAL  
o Cultivation of MON810 Maize (4851 ha in 2008)2. 
o Research activities on GMOs: 11 field tr ials notified between 2002 and 2007 (Maize)3. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Portugal received 14 answers to the questionnaire (Public ad ministration, farmers, seed 
industry, consumers, cooperatives and grain handling companies, food and feed industry, 
insurance companies). These answers we re sent as such to the Commission. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Farmers cultivating GM maize report in aver age an improvement of the productivity, even 
if pest pressure is limited. Lower use of pes ticides allows smaller exposure of workers to 
chemicals, larger flexibility of operators in other tasks.  
o Farmers cultivating GM maize do not repor t neighbourhood conflicts  after 6 years of 
cultivation, and segregation of harvests to ma intain their integrity has been set up without 
major difficulties. For farm structure, especia lly in regions of sma ll farms, farmers have 
adopted the culture of the "production area s" which is under the current legislation. 
However this solution is extr emely complicated to admini ster, although being the only 
solution to the cultivation of GM corn in certain areas.  
o Organic farmers, although not having yet expe rienced neighbouring with GM fields, are 
concerned by the risk of conflicts when this will happen. Furthermore, they claim for strict 
coexistence rules, and effective compensa tion schemes in case of contamination of 
fields/harvests. Furthermore, the farm-s aved seeds practice should be preserved.  
o According to the association of farmers (ANP ROMIS), the cultivation of corn varieties 
containing the MON810 event can be justified on ly in areas where traditionally there are 
attacks from corn borers. 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Portugal, and was validated by Portugal. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 70   EN o The Ministry of Agriculture (DGADR) menti oned that the cultivation of BT maize only 
represents around 3,8% of the total maize area. In Portugal farmers who wish to cultivate 
GM maize must fulfil with national coexisten ce legislation that includes the following 
obligations: participate in specific training cour ses, register the cultivation parcel, inform 
by written notification a bout their intent to cu ltivate GMO, apply meas ures of coexistence, 
among others. As mentioned before there is co existence legislation in place in Portugal. 
According to this legislation the Agricultural  central and regional services have performed 
inspection and controls activities, with no additional costs to the GM growers. 
o The seed industry referred to international st udies to contribute to the questionnaire. As 
regards Portugal specifically, over the period 2005-2007, yields would have increased by 
12,5%, ensuring in 2007 a net increase in gross margin of 143,94$/ha, and an impact of 
farm income at national level of 610.000$ (source: Brookes 2008). 
o According to organic farmers, in the Alente jo regions part of the farmers cultivating 
GMOs left this production due to lack of interest. 
o Farmers cultivating GM maize and the Ministry  of Agriculture report that GM and non 
GM crops are sold the same price, and that th ere are no particular diffi culties to market the 
products. However, GM seeds are more expensive.  
o The feed and meat sector would gain competitiveness, as GM crops could make Portugal 
produce more corn and be less dependent on third countries.  
o Control and monitoring program made by th e Ministry of Agriculture (284 farmers 
inspected in the last 5 years). Main outcome s are: better quality of the harvest (less 
mycotoxin), increased production, reduction of insecticide use (i ncluding less exposure of 
rural workers), and higher cost of the seeds.  Globally, the economic balance is considered 
positive.  
o According to the Ministry of Agriculture, th ere are no direct impacts on other production 
systems (organic, conventional, beekeeping). 
o Creation of GM production zones, which are the results of voluntary associations of 
farmers (cf. coexistence rules, all the pr oduction will be labelled as containing GM 
varieties). 
Impacts on downstream operators 
o The Portuguese market would be adaptable to  handle GM and conventional grains. Grain 
handling companies have been ab le to opt to be suppliers of  GM labelled grains, non-GM 
labelled grains or both of them, through grain segregation when necessary. 
o No impact on consumer choice, inform ation and protection is expected.  
o Grain handling companies would face ad ditional costs for handling, storage, 
administrative requirements and traceability. Se gregation at port di scharge and warehouse 
storage level between GMOs and non-GM cerea ls increases the costs more than 50%.  
o Public administration: enforcement and impl ementation of legal pr ovisions require the 
implementation of monitoring and control prog rams and the availability of specialized 
experts and laboratory infrastruc tures (financial implications). 
Agronomic sustainability 
o Organic farmers are concerned by the risk of de veloping resistance to the Bt toxin, as they 
have a very limited choice of pe sticides that they can use. 
 
EN 71   EN o Environmental benefits: less use of pesticides namely insecticides. 
Other implications 
o No answer 
 
EN 72   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Romania1 
1. ABOUT ROMANIA  
o Cultivation of GMO since 2007 when Roma nia joined the EU: 7146 ha of maize 
MON810 in 20082 and 3243 ha of maize MON810 in 2009. Romanian farmers cultivated 
GM soybean line MON 40-3-2 between 1999 and 2006. 
o Research activities on GMOs: 42 field trial authorizations between 2007 - 20093. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o The contribution contains inputs from th e Ministry of Agriculture and Rural 
Development, the National Authority fo r Consumers Protection, the National 
Environmental Guard, the National Sanitary Veterinary and Food Safety Authority, the 
Public Health Institute Bucharest, Monsan to Romania, Pioneer Hi-Breed Romania, 
Syngenta Agro SRL and Europabio. Despite the fact that many NGOs are strongly 
involved in this issue, they did not send any contribution.  
o The Romanian authorities stressed the following: "We can say that overall, this is not a 
relevant and/or balanced position for Romani a to reflect the opi nion on socio-economic 
advantages and disadvantages of each catego ry of GMOs authorized, more like an 
opinion of GM industry and of th e authorities mentioned above."  
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
Impact underlined by th e control authority:  
o Conflicts between farmers and be tween farmers and neighbours.  
Impacts revealed by the companies acting in the field of GMOs (no answer from other 
stakeholders):  
o Main impacts of GMOs: increased labour flex ibility, lowers production cost (saving time, 
energy, insecticides), increased income, better quality of  the harvest (no production losses 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Romania, and was validated by Romania. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 73   EN due to insects attack, less mycotoxins and less pesticides residues), improved health and 
safety for farmers (reduced use of insecticides).  
o GM, conventional and organic growers of mai ze have co-existed (with good farming and 
co-existence practices). 
Impact on downstream operators  
Impact underlined by the control authorities:  
Public administration: o carrying out inspections to the GMO cultivator s and users in order to check the way there 
respect the regulations on pr otection of the envi ronment (National Environmental Guard); 
o official control of traceability and label ling of GM food and feed include significant 
number of qualitative and quantitative analysis  and a number of samples to be taken by 
official inspectors (National Sanitary Veterinary and Food Safety Authority); 
o The costs are supported from the state budget. 
Impacts revealed by the companies acting in the field of GMOs and public authority for 
environmental protection:  
o No impact on insurance mechanisms in Romania, as there is no such a product developed 
by the insurance companies.  
Economic context 
o Respondents concluded that the placing on the market of GMO seeds has an impact on the 
internal market. This issue is to be assessed. 
Agronomic sustainability 
Impacts underlined by th e control authorities:  
o Contradictory answers on the impact on the number of non agriculture species/varieties 
and on agriculture diversity, due  to the different results of the specific studies on 
agricultural biodiversity made by the Ministry of Agriculture and Rural Development and 
the on-site observations of th e National Environmental Guard.  
o No impact on the use of pesticides  against target insect pests.  
o No negative effects on migration routes , ecological corridors, buffer zones. 
Impacts revealed by the companies acting in the field of GMOs:  
o Reduction of greenhouse gas emissions.  
Other implications 
 
EN 74   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of  the contribution by Sweden1 
1. ABOUT SWEDEN  
o GMO cultivation: Amflora potato2. 
o Research activities on GMOs: 24 notifica tions between 2002 and 2007 (Apple/pear; 
Arabidopsis thaliana; linseed/flax; maize;  oilseed rape, poplar, potato, sugar beet)3. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o The contribution is constituted of a general st atement and answers to the questionnaire. It 
elaborated with the input of the 118 stake holders. The answers to the questionnaire are 
exclusively ex ante answers, based on stakeholder's input an d review of the literature. 
o The Swedish authorities state that the Eu ropean regulatory framework allows for 
socioeconomic considerations to be ta ken into account on a case-by-case basis but 
consider that a general application of these criteria is unlikely to make the process easier, more consistent or foreseeable. Transparen cy of the decision process may also be 
negatively affected.  
o The regulatory framework should be based on sound science and precau tionary principle. 
The scientific evaluation of the safety of the GMO must not be compromised.  
o A balancing act between the interests of di fferent agricultural sector in the EU is 
considered to be politically very complicated and costly.  
o Compliance with EU regulation and WTO should  be taken into consideration if socio-
economic considerations are to be taken with in the EU-process. Indirect socio-economic 
effects on developing countries need to be considered.  
o A free choice for farmers and consumers to c hoose conventional, GM or organic products 
alike is an important guid ing principle for Sweden. 
                                                
 
1 This compilation was prepared by the Commission on the basis of the information provided by Sweden, 
and was validated by Sweden. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
 
EN 75   EN 3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators 
o Decision to plant GM crops pertains to the farmer, who will assess its impact. Factors to 
consider are variation of bio tic and abiotic challenges (climat e, pest/weed pressure); cost 
of seeds; cost of biocides. 
o Farmers could benefit from use of GMO crops  through the more secure and sometimes 
higher yields that has been de monstrated. The profitability for the farmers depends on the 
natural variation of biotic and abiotic challenges of the year as well as the cost of seed compared to the cost of the pesticides replaced. 
o The benefits of the potato late  blight resistant are highlighted: less need for pesticides. 
o Analysis done by the Swedish Agricultural Board anticipates higher profit for farmers 
using GM rapeseed, maize, potato and sugarb eet (decrease of use of chemicals). For 
rapeseed, arbitration should be made between mechanical weed contro l (high carbon foot 
print) and chemical weed control (associated with HT rapeseed).  
o It is likely to have a price premium for non-GM crops. However, experience in Spain 
(maize) and worldwide (rapeseed) show that this is not always the case. Canadian GM 
rapeseed is sold at higher price than c onventional because it c ontains fewer weeds. 
o GMO patenting model prohibits the cultivation of farm saved seeds (which is otherwise 
possible in the EU under certain conditions). This  can be seen as negative and costly for 
farmers. From the Competent Authority's perspe ctive, this is good as all products must be 
withdrawn from the market when  the authorisation expires. 
o Organic farming: Problematic to maintain the zero tolerance regarding GMOs, risk to 
loose the organic certification and price prem ium. Price controls/inspections may increase. 
o Beekeepers: Honey will contain GM pollen and there is some legal uncertainty concerning 
this. 
o Use of insect resistant seeds demonstrated less mycotoxin quantitie s in harvests, what 
benefits both farmers and consumers, and pos sibly less pesticides residues. However, it 
may be of economic interest to cultivate corn instead of pasture, wh ich would increase the 
use of pesticides all in all. 
o Three Swedish authorities pointed out that gr owing glyphosate tolerant  crops (sugar beets, 
oilseed rape and corn) has possible positive effects on health because more dangerous 
substances are replaced by a lesser dangerous one (Jordbruksverket 2007). 
o Swedish seed industry is relatively small and is  integrated to multinationals. This industry 
is hindered by the lack of a thre shold for adventitious presence of GM seeds in seed lots.  
                                                
 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 76   EN Impacts on downstream operators 
o Consumers have a negative attitude towards GMOs6. There is a perceived high 
willingness to pay for GM-free products acco rding to a multiyear survey between 2001-
2007 in Stockholm. However, a study on actual pur chase of strawberries showed that at a 
lower price, consumers are willing to buy GM-s trawberries if not trea ted with pesticides. 
Another Nordic study shows that acceptance of GMOs can be influenced by fat content and taste
7. A general survey on attitude showed that gene technology is welcomed when 
impacting allergies and reducing the use of chemicals in agriculture. 
o Cooperatives and grain handling companies: la belling and traceability of GM-food incur 
costs. Costs of keeping production lines separate d are only sustainable for large quantities.  
o Most of feed companies are GM free, due to  policies of farmers and food industries. All 
food industries except pork industry have voluntary GM exclusion policies in place. 
o Food and feed industry: soy is the most im pacted (Sweden is dependent on imports for 
feed). As GM-soy cultivation increases worl dwide, GM-free soy pr ices increase and 
choice decreases. Furthermore, due to asynchronous approvals, there will be a price premium for EU-authorised GMO soy co mpared to GM soy not authorised. 
o Transport companies: avoidi ng adventitious presence imp lies high segregation costs. 
o So far no insurance company has proposed a product targeted on GMO cultivation. 
However some companies have exempted da mages on biological diversity from their 
agricultural liability insurances. No information on existence of insurances for organic farmers who lost organic label. The "Tort"  liability act is applicable for economic 
damages suffered by farmers due to GMO cultivation. 
o Research is more and more done outside the EU because of opposition to GMOs. The cost 
for development, patent protection and author isation of GMOs can only be afforded by 
major breeding companies. Moreover, future decision on what falls into the GMO regulatory framework will have a larg e impact on research and innovation. 
o Public administration: 10 agencies are i nvolved in GMOs but current cost was not 
assessed. If GMO cultivation increases, cost would increase for administration and information to the public. 
Economic context 
o Sweden highlights the worldwide competition context with third countries having more 
relaxed approaches on GMOs, hence c ontributing to impact negatively the 
competitiveness of the EU agricultural sector (e.g. asynchronous approvals).  
o GMO market is monopolistic but no difference with the current seed market. 
o If socio-economic criteria are introduced in the regulatory framework, it could hinder 
internal market by having diffe rent national criteria applied. 
o In regions with traditional/s mall scale production, GM-crops are assumed to have negative 
effect on brands and image. 
                                                 
6 72% - Eurobarometer 2008 
7 Study on cheese: Lähteenmäki, et al. 2002 
 
EN 77   EN Agronomic sustainability 
o The assessment of agronomic sustainability and negative impacts on the environment are 
dealt with in the risk assessment of GM Os, according to the current legislation. 
o Agricultural input: effects on the use of pest icides, crop growing patterns, fertilizers, 
tilling, water needs should be analysed for an estimation of input.  
o Impact on biodiversity will depend on crop and trait and there is no general science based 
information on how Sweden's biodiversity could be impacted. 
o Impact on renewable and non renewable resources is difficult to estimate. The current GM 
crops will not be cultivated on a large sc ale in Sweden. The potential of the next 
generation may be higher such as vegeta ble oil for technical use or plastics. 
o CO 2 emissions of the Swedish farming s ector represent 12% of the total CO 2 equivalent 
emissions. Technologies that could change the tilling practice and the soil microflora may 
positively impact the field capacity to act as a carbon sink (more research is needed). 
Crops designed to improve the climate impact of ruminants are of interest. 
Other implications 
o No Answer 
 
EN 78   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Slovenia1 
1. ABOUT SLOVENIA  
o No cultivation of GMOs2. 
o No research activities on GMOs3 related to plants. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o Answer elaborated with the input of the 39 stakeholders consulted (NGOs, associations, 
industry, insurance companies, inst itutes, faculties, and government) 
o Regarding the discussion on socio-economic crit eria, reference is made to the work done 
by COGEM. The presented themes and associat ed criteria amongst others could serve as 
starting point for discussion in the EU.   
o No cultivations of GMOs in Slovenia, so the answers are assumptions, based on 
stakeholders' input and review of the literature. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o Prices and yields could be im pacted. Possibly: higher yield,  higher input prices, possible 
loss of income in the "organic" farming sect or and potentially also  in "conventional". 
o Possible impact on farmers' production costs:  reduction of costs by reduction of pesticide 
use and consumption of fuel, increase of  costs because of higher input prices. 
o Possible impact on labour fl exibility: increased flexibility and labour saving.  
o Quality of the harvest: improvement of the grai ns quality from reductions in the levels of 
mycotoxin, no GMOs with improved nutritional va lues (whereas organi c grown fruits and 
vegetables are richer in  beneficial components). 
o Possible appearance of resistant weeds in case of cultivation of HT crops which could 
imply an increase of the amounts and th e toxicity of herbicides used.  
o Prices discrimination between GM a nd non GM products can be expected.  
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Slovenia, and was validated by Slovenia. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 79   EN o Farmers should have possibility to  choose their type of production.  
o Contamination of non-GM crops could hinder farm er's privilege to use farm saved seeds. 
o Farming practice (incl. co-existence measur es): Lend holding and parcel structure are 
exceptionally dispersed and fragmented. Hence high risk of cross co ntamination, with 
consequences on liability and marketability of the harvested products (in particular 
organic products). 
o Coexistence measures are not yet applied in  practice. A compensation fund is envisaged, 
and it will be filled with special fees for unintentional presence of GM crops in other 
products. 
o Considerable conflicts between neighbourin g farmers are anticipated because land 
ownership is highly fragmented. The le gislation envisages an agreement among 
neighbouring farmers with the GM crop production.  
o Freedom of choice for consumers should be respected.  
o Farmers' training is foreseen in the coex istence legislation (for GM farmers).  
o Beekeeping is an old tradition, beekeepers are sceptical on coexisten ce, marketability of 
contaminated honey could be jeopardized.  
o Long tradition of seed production, almost self sufficient for cereal s eeds but not for maize 
and rapeseed. A priori, producti on of GMO would not be interesting for SL producers, 
who are too small to cope with the constraint s related to GMO, in particular isolation 
distances, separate mechanisation for cultivation, transport and storage. 
o More controls would be necessary on conven tional seeds to ensure absence of cross 
contamination. 
Impacts on downstream operators  
o Consumers advocate for non GM products, fr eedom of choice must be preserved. 
o Food and feed industries, transport companie s must design their production process to 
allow segregation and traceability between GM and Non GM. 
o Laboratories: the cost of monitoring would incr ease due to coexistence measures and need 
for constant improving or introducti on of new detection methods.  
o Innovation and research: no experience. However,  it is presumed that investment would 
increase if the attitudes towards GMOs we re more relaxed amongst Europeans. On the 
other hand, absence of GMO could stimulat e research investment in conventional 
practices. 
o Public administration: costs would rise up (management of the authorisations, co-
existence and possible registration of GM O free areas, compensation fund, research 
projects…) 
Economic context 
o No experience, but increased demand fo r agriculture insp ection should happen. 
o Possible impact on the size of the farms, production practices , influence on reputation of 
regions.  
 
EN 80   EN Agronomic sustainability 
o Agricultural inputs: lack of experience. 
o Lack of experience on impact on biodiversity. However, possible crossing appearance of 
GM crop-wild hybrids which may become agricultural weeds and compromise weed 
management system and invade natural hab itats, changing their biodiversity value and 
replace wild genes (genetic assimilation) and reduce diversity of recipient population. 
Lower fitness of these plants may drive wild population to extinction (demographic 
swamping). Contrary higher fitness may lead to increased invasive ness replacing wild 
populations and other species, while gene fl ow from GM crops may contaminate seed 
pools and reduce seed quality to be expected.   
o No Answer 
o GMOs could help lowering level of gr eenhouse gas emission (reduction of fuel 
consumption, use of no-till and reduced-till farming systems). 
Other implications 
o No Answer 
 
EN 81   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation of the contribution by Slovakia1 
1. ABOUT SLOVAKIA  
o Cultivates MON810 Maize since 2006 (875 ha in 2009)2. 
o Research activities: 1 notification for field trials between 2002 and 20073. 
o Coexistence rules adopted4. 
2. GENERAL COMMENTS  
o The exercise of data collection is co nsidered important by the authorities. 
o Difficulties to answer due to the limited expe rience of Slovakia with GMO cultivation.  
o No study on socio-economic impact has been performed so far. However, two impacting 
elements could already be identified: 
- Obligation of labelling generates more  expenses for each product produced from 
GMOs, and the consumers will not buy the product. 
- Some processing companies have very low adventitious presence thresholds 
(0.02%), so conventional producers near to  GMOs fields have problems to sell. 
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators  
o No answer 
Impacts on downstream operators 
o No answer 
Economic context 
o No answer 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by 
Slovakia, and was validated by Slovakia. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 82   EN Agronomic sustainability 
o No answer 
Other implications 
o No answer 
 
EN 83   EN Socio-economic implications of GMO cultivation 
Non exhaustive compilation  of the contribution 
by United Kingdom1 
1. ABOUT THE UNITED KINGDOM  
o No cultivation of GMOs2.  
o Research activities: 6 field tria l notifications between 2002 and 20073. 
o No coexistence rules adopted4. 
o The Government has changed since the contri bution was sent. UK agreed to transmit their 
contribution in the context of a request fo r access to document, on the condition that a 
disclaimer makes clear that the contributio n represents the views of the previous 
Government.  
2. GENERAL COMMENTS  
o General statement by the authorities of the United Kingdom: 
- GM applications should be assessed case by case based on the scientific evidence , then 
the normal operation of the market decides whether a GMO is successful or not. 
- Differing views on GMOs in the United Kingd om: Contrary to Northern Ireland and 
the central UK Government, Scotland and Wales are opposed to the cultivation of 
GMOs. 
- The idea of allowing national decision making process and a more explicit 
consideration of socio-economic factors ha s potential attraction. But many risks too, 
so considerable work would need to be done to ascertain the nature of any models for 
EU or Member States decision making. 
- The United Kingdom has no experience with commercial cultivation on their territory, 
so no first hand evidence of associated socio-economic impact. .  
- However the impact of not adopting the GMO technology should al so be considered: 
This has potentially deterred research and innovation in the UK, limiting private sector 
investment and employment opportunities in  the crop biotechnology research base.  
- Lack of research and investment can hamper the development of potentially beneficial 
new technologies which could have an impact on developing countries. 
o The UK undertook a written consultation of stakehol ders, asking their opinion on the 
possibility of including socio-economic f actors in the decision making process, the 
impacts which could be assessed, and the expected impacts associated with GMO 
                                                 
1 This compilation was prepared by the Commission on the basis of the information provided by the UK, 
and was validated by the UK. 
2 Source: Commission report published on 2 April 2009 on the coexistence of genetically modified crops 
with conventional and organic farming ( http://ec.europa.eu/agriculture/gmo/coexistence/index_en.htm ). 
3 Source: Research project DG Envi ronment Analysis of field trials management in Member States and 
prevention of accidental entry into the mark et place – final report November 2008 ( http://www.gm-
inspectorate.gov.uk/reportsPublications/documents/EUPARTBreview_finalreport_Dec2008.pdf ) 
4 Source: idem footnote 2 
 
EN 84   EN cultivation. 12 organisations re sponded (which may not repres ent the whole spectrum of 
stakeholders). 
- Answers were polarised regarding inclusion of socio-economic in the decision making 
process and possible ways forward. Organisations who believe that the use of GM crops 
could be beneficial, including industry, trade and conventional farming representatives, 
were generally concerned that it would be inappropriate to extend the regulatory regime 
beyond safety considerations. Such a requirement would be disproportionate and 
inconsistent with other tec hnologies, would breach Intern al Market and international 
agreements, and results would be subjective. Organisations including NGOs and 
beekeepers who mainly viewed GM crops as a potential threat or problem called to take 
into account public opinion and the impact of GMOs on the seed/agricultural chain, personal well-being and happiness, cultural id entity, physical health, level of political 
trust and civic engageme nt, and the community.  
- The short paper is complemented with the report "A way forward for GMO cultivation 
in Europe?" by the Chatham House Institute. 
This report was produced after an informal 
workshop discussion involving a key group of UK stakeholders and representatives from 
the Netherlands, Austria and the Commission.  
3. OVERVIEW OF THE ANSWERS TO THE QUESTIONNAIRE5 
Economic and social implications 
Impacts on upstream operators 
o No answer 
Impacts on downstream operator 
o No answer 
Economic context 
o No answer 
Agronomic sustainability 
o No answer 
Other implications 
o No answer 
                                                 
5 For more details, please see the full answer at  
http://ec.europa.eu/food/food/biotechnology/index_en.htm  
 
EN 85   EN ANNEX 3  
Review of the available scientific literature worldwide on the socio-
economic dimensions of cultivation of GMOs 
Publications listed below are peer-reviewed ar ticles, official reports from governmental 
organisations or agencies/instit utes, official international and national statistics, and 
conference proceedings in which scientists pr esented results from their research that 
were not published elsewhere. 
This review of literature is extracted from  the final report of the Commission funded 
project "Assessment of the economic perfor mance of GM crops worldwide" (Ref. 
ENV.B.3./ETU/2009/0010).  
This report is available at http://ec.europa.eu/food/food /biotechnology/index_en.htm  
 
Acquaye, A.K.A., and Traxler, G. (2005). M onopoly power, price discrimination, and access 
to biotechnology innovations. AgBioForum, 8(2&3), 127-133 
Acworth, W., Alasebu, Y., Curtot ti, R. (2008). Economic impacts of GM crops in Australia, 
Research Report 08.4 prepared for the Australi an Government Department of Agriculture, 
Fisheries and Forestry, Canberry, May.  
Ahuja, S.L. (2007). Indian GM cotton experi ence in 2005. Inte rnational NGO Journal. 2(4), 
78-81. 
Andersen, M.N., Sausse, C., Lacroix, B., Caul, S. and Messean,A (2007). Agricultural studies 
of GM maize and the field experimental in frastructure of ECOGE N. Pedobiologia. 51, 175-
184. 
Azadi, H. and Ho, P. (2010). Genetically modifi ed and organic crops in developing countries: 
A review of options for food security.  Biotechnology Advances Volume 28(1), 160-168. 
Bambawale, O.M., Singh, A., Sharma, O.P., Bhosle, B.B., Lavekar, R.C., Dhandapani, A., 
Kanwar, V., Tanwar, R.K., Rathod, K.S., Patange , N.R. and Pawar, V.M (2004). Performance 
of Bt cotton (MECH-162) under Integrated Pest management in farmers’ participatory field 
trial in Nanded district, Central I ndia. Current Science. 86(12), 1628-1633. 
Barfoot, P., and Brookes, G. (2007). Global imp act of biotech crops: Socio-economic and 
environmental effects, 1996- 2006. AgBioForum, 11(1), 21-38. 
Barrett, C., Moser, C., McHugh, O., and Barison, J. (2004). Better technology, better plots, or 
better farmers? Identifying cha nges in productivity a nd risk among Malagasy rice farmers. 
American Journal of Agricult ural Economics, 86(4), 869-888. 
Barwale, R.B, Gadwal, V.R., Zehr, U., a nd Zehr, B. (2004). Prospects for Bt Cotton 
Technology in India. AgBioForum, 7(1&2): 23-26. 
 
EN 86   EN Benbrook C. (2001). Do GM crops mean less pesticide less? Pesticide Outlook 12(5), 204-
207. 
Benbrook, C. (2003). Impacts of genetically engi neered crops on pesticide use in the United 
States: the first eight years. Benbrook Consulting Services.  
Benbrook, C. (2009). Critical Issue Report: The First Thirteen Years.  The Organic-Center. 
Bennett, R., Buthelezi, T.J., Ismael, Y., and Morse, S. (2003). A case study of smallholder 
farmers in the Makhathini Flats, Republic of  South Africa Outlook on Agriculture, 32, 123-
128. 
Bennett, R., Ismael, Y., Kambhampati, U. and Morse, S. (2004). Economic impact of 
genetically-modified cotton in  India AgBioforum, 7, 1-5. 
Bennett, R., Ismael, Y., Morse, S. and Shanka r, B. (2004a). Reductions in insecticide use 
from adoption of Bt cotton in South Africa: impacts on economic performance and toxic load 
to the environment. Journal of Agricultural Science, 142, 665-674 
Bennett, R., Ismael, Y. and Morse, S. (2005)  Explaining contradictory evidence regarding 
impacts of genetically modified  crops in developing countrie s: varietal performance of 
transgenic cotton in India. Journal of Agricultural Science. 143, 36-41 
Bennett, R. M., Kambhampati, U., Morse, S.  and Ismael, Y. (2006a) Farm-level economic 
performance of genetically-modified cotton in India Review of Agricultural Economics, 28, 
59-71.  
Bennett, R. M., Morse, S. and Ismael, Y. (2006b). The economic impact of genetically 
modified cotton on South African smallholders: yield, profit and health effects Journal of 
Development Studies, 42, 662-677.  
Bernard, J.C., Pesek, J.D. and Fan, C. (2004). De laware farmers' adoption of GE soybeans in 
a time of uncertain US adop tion. Agribusiness 20(1), 81-94. 
Brethour, C., Mussell, A., Mayer, H. and Ma rtin, L. (2002) Agronomic, Economic and 
Environmental Impacts of the Commercial Cultivation of Gl yphosate Tolerant Soybean in 
Ontario. (George Morris Cent re, Guelph, Ontario, Canada. 
Brookes, G. (2002). The farm level impact of using Bt maize in Spain. PG Economics Ltd. 
www.pgeconomics.co.uk.  
Brookes, G. (2003a). The farm level impact of using Bt maize in Spain. Crop Biotech Brief, 
3(3). 
Brookes, G. (2003b). The farm level impact of using roundup ready soybeans in Romania. PG 
Economics, August 19, 2003. 
Brookes, G., Aniol, A. (2005): The farm level imp act of using GM agronomic traits in Polish 
arable crops, www.pgeconomics.co.uk. 
Brookes, G. (2005a) The farm-level impact of  herbicide-tolerant soybean in Romania. 
AgBioForum. 8, 235-241 
 
EN 87   EN Brookes, G. and Barfoot, P. (2006). Global im pact of biotech crops: Socio-economic and 
environmental effects in the first ten year s of commercial use. AgBioForum, 9(3), 139-151. 
Available on the World Wide We b: http://www.agbioforum.org. 
Brookes, G. (2007). The benefits of adopting gene tically modified, insect resistant (Bt) maize 
in the European Union (EU): first resu lts from 1998-2006 plantings. PG Economics Ltd. 
www.pgeconomics.co.uk  
Brookes, G., and Barfoot, P. (2009). Global imp act of biotech crops: Income and production 
effects 1996-2007. AgBioForum, 12(2), 184-208.  
Brookes, G. (2008). The impact of using GM in sect resistant maize in Europe since 1998. 
International Journal of Bi otechnology 10 (2/3), 148-166.  
Bryant, K.J., Nichols, R.L., Allen, C.T., Benson, N.R., Bourland, F.M., Earnest, L.D., 
Kharboutly, M.S., Smith, K.L., Webster, E.P. (2003): Economic and Ma rketing: Transgenic 
Cotton Cultivars: An Economic Comparison in Arkansas, The Journal of Cotton Science 7, 
pp. 194-204. 
Bryant, K.J., Reeves, J.M., Nichols, R.L., Gr eene, J.K., Tingle, C.H., Studebaker, G.E., 
Bourland, F.M., Capps, C.D., and Groves, F.E. (2008). Valuing Transgenic Cotton 
Technologies Using a Risk/Return Framewor k. Journal of Agricultural and Applied 
Economics. 40(3), 767-775. 
BVL (2010). „Standortregis ter“ of the Bundesamt fü r Verbraucherschutz und 
Lebensmittelsicherheit, http://apps2.bvl.bund.de/stareg_web /bundeslandStatistic.do?year=2008. 
Carew, R. and Smith, E.G (2006). Assessing the Contribution of Genetic Enhancements and 
Fertilizer Application Regimes on Canola Yield and Production Risk in Manitoba. Canadian 
Journal of Agricultural Economics. 54,215-226. 
Carlson, G.A., Marra, M.C., and Hubbell, B. (1998). Yield, Insecticid e Use, and Profit 
Changes from Adoption of Bt Cotton in th e Southeast. Beltwide Cotton Conference 
Proceedings 2, 973-974, National Cotton Council, Memphis, TN. 
Carpenter, J.E. (2001). Comparing Roundup Ready and Conventional Soybean Yield 1999. 
National Center for Food and Ag ricultural Policy, Washington DC. 
Carpenter, J.E., and Gianessi, L.P. (2001). Agricultural Biotechnology : Updated Benefits 
Estimates. Washington D.C.: National Cent er for Food and Agricultural Policy.  
Carpenter, J. (2010). Peer-reviewed surveys i ndicate positive impact of commercialized GM 
crops, Nature Biotechnology, 28(4), pp. 319-321.  
Cattaneo, M.G., Yafuso, C., Schmidt, C., Hua ng, C., Rahman, M., Olson, C., Ellers-Kirk, C., 
Orr, B.J., Marsh, S.E., Antilla, L., Dutilleul, P.  and Carrièr, Y. (2006) Farm-Scale Evaluation 
of the Impacts of Transgenic Cotton on Biodivers ity, Pesticide Use, and Yield. Proceedings of 
the National Academy of Sciences of the United States of America, 103, 20, 7571-7576 
 
EN 88   EN Consmüller, N., Beckmann, V., Schleyer, C. (2009). The Role of Coordination and 
Cooperation in Early Adoption of GM Crops : The Case of Bt Maize in Brandenburh, 
Germany, AgBioForum, 12(1), pp. 45-59. 
Contini, E., Sampaio, M.J.A, Avila, A.F.D. ( 2003). The lack of clear GMO regulation: its 
impact on researchers and farmers in Brazil.  International Journal of Biotechnology 2005 - 
Vol. 7, No.1/2/3 ,. 29 – 45. 
Crost, B., Shankar, B., Bennett, R., and Morse, S. (2007). Bias from fa rmer self-selection in 
GM crop productivity estimates: evidence from I ndia data. Journal of Agricultural Economics 
58, 24-36. 
Degenhardt, H., Horstmann, F., Mulleder, N. (2 003). Bt maize in Germany: experience with 
cultivation from 1998 to 2002, Mais 2/2003.  
Demont, M., and Tollens, E. (2001). Uncerta inties of estimating the Welfare Effects of 
Agricultural Biotechnologies in the European  Union, Working Paper 2001/58, Department of 
Agricultural and Environmental Economics, Katholieke Universiteit Leuven. 
Demont, M., and Tollens, E. (2004). First impact of biotechnology in the EU: Bt maize 
adopton in Spain. Ann.appl.Biol. 145, 197-207. 
Dillehay, B.L., Roth, G.W., Calvin, D.D., Krat ochvil, R.J., Kuldau, G.A., and Hyde, J.A. 
(2004). Performance of Bt Corn Hybrids, their Near Isolines, and Leading Corn Hybrids in 
Pennsylvania and Maryland. Agronomy Journal 96, 818-824.  
Doss, C.R. (2006). Analyzi ng technology adoption using microstudies: limitations, 
challenges, and opportunities for impr ovement. Agricultural Economics 34, 207-219. 
Dwan, K., Altman,D.G., Armaiz, J.A., Bloom, J., Chan, A., Cronin, E., Decullier, E., 
Easterbrook, P.J., Elm, E. von., Gamble, C., Gher si, D., Ioannidis, J.P.A., Simes, J. and 
Williamson, P.R. (2008). Systematic Review of  the Emperical Evidence of Study Publication 
Bias and Outcome Reporting Bias. PLoS ONE. 3(8), 1 – 31. 
Ervin, D.E., Batie, S., Welsh, R., Carpenter, C., Fern, J..I., Ri chman, N.J., and Schulz, M.A. 
(2000). Transgenic crops: An environmenta l assessment. Policy Studies Report No.15 
Arlington, Va., USA: Henry, A.. Wallace Center for Agricultural and Environmental Policy, 
Winrock International.  
Falck-Zepeda, J.B., Traxler, G and Nelson, R.  (2000). Rent creation and distribution from 
biotechnology innovations: the case of Bt cott on and herbicide-tolerant soybean in 1997. 
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