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 cultivation on the basis of Member States contributions, as requested by the Conclusions of the Environment Council of December 2008

The Directive 2001/18[1] on the deliberate release of genetically modified organisms (GMOs) into the environment provides that the Commission should, after 3 years, provide a report on the implementation of the Directive including 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 launched 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 stakeholders to the questionnaire. This Commission staff working paper is accompanying the above-mentioned 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 contributions of the 25 Member States which answered to the questionnaire. These summaries have been reviewed and validated by the Member States, and do not engage the Commission. (Annex 2).

– A review of the available peer-reviewed literature worldwide on the socio-economic dimensions of cultivation of GMOs. (Annex 3)

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/EC[2] provides that the Commission should send to the European Parliament and the Council a specific report on the operation of the Directive including inter alia an assessment of the socio-economic implications of deliberate releases and placing on the market of GMOs. These implications are defined in Recital (62) of the Directive as the socio-economic advantages and disadvantages of each category of GMOs authorised for placing on the market, which take due account of the interest of farmers and consumers. In its 2004 report, the Commission noted 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 articles 7 and 19, asks the Commission to submit a draft of the authorisation decision taking 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 Environment 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 specific to the GMO assessed to be taken into account in the risk management process which follows the risk assessment. The risk assessment takes account of the environment and human and animal health. Points out that under Directive 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 deliberate releases and placing on the market of GMO.

Invites the Member States to collect and exchange relevant information on socio-economic implications of the placing on the market of GMOs including socio-economic benefits and risks and agronomic sustainability, by January 2010. INVITES the Commission to submit to the European Parliament and to the Council the report based information provided by the Member States by June 2010 for due consideration and further discussions.

This possible consideration of socio-economic factors in the authorisation of GMOs for cultivation has also been raised by several Member States in the Environment and Agriculture Councils of the last months[3].

In order to respond to the invitation of the Council conclusions of 4 December 2008 and to the requirements of the legislation, the Commission invites Member States to submit all information they would consider relevant by January 2010 at the very latest.

In order to help Member States in structuring their responses, the Commission drafted a non exhaustive list of areas and stakeholders which could be concerned. In addition, for each of these categories, we have introduced in the annex a list of leading questions which could be used where considered appropriate.

When preparing their contribution Member States are invited to report ex post on the socio-economic impact of GMOs that have been approved in the EU and cultivated 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 possible 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 informative 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 specification 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. These contributions should cover cultivation of GMOs and placing on the market of GM seeds.

If you choose to fill in the annexed questionnaire, please consider that answers should be broken down by the purpose of the genetic modification (herbicide tolerant, insect resistance, etc) if this affects the content of the responses.

DEADLINE FOR CONTRIBUTIONS: January 2010

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 prices and agricultural yields);

- farmers' production costs;

- labour flexibility;

- quality of the harvest (e.g.mycotoxines);

- cost of alternative pest and/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 Regulation (EC) No 2100/94 on Community plant variety rights) to use farm-saved seeds;

- the use of agriculture inputs: plant protection products, fertilisers, 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- insurance obligations;

- opportunities to sell the harvest 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;

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 and its structure in the EU (size of companies, business concentration, competition policy)? Please specify per sector.

- for plant breeders;

- for seed multiplication;

- for seed producers;

- for the availability of conventional 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 quality and diversity of products);

- the price of the goods;

- 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 business 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 carriers (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;

- 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 techniques (e.g. identification of molecular markers);

- access to genetic resources;

- access to new knowledge (molecular markers, 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 (national and local level) for example 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 have 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 flows (including relocation of economic activity)?

Any other impact you would like to mention:

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. increase or decrease of monoculture);

- the reputation regarding other commercial 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 insect 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 patterns of use of chemical herbicides?

2.2. Biodiversity, flora, fauna and landscapes (other 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 have an impact regarding the number of non agriculture species/varieties?

Does GMO cultivation have an impact on agriculture 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.

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 combustion – 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 terms? If so, which ones?

Any other impacts you would like to mention:

3 - Other Implications

ANNEX 2

Non-exhaustive summaries of individual contributions of the 25 Member States which answered to the questionnaire.

These summaries have been reviewed and validated by the Member States, and do not engage the Commission

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Austria[4]

1. About Austria

o No GMO cultivation[5].

o No experimental research activities on GMOs cultivation[6].

o Coexistence rules adopted[7].

2. General comments

o Austria appreciates the efforts by the Commission 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, institutions involved in GMO issues, as well as of all provinces of Austria.

o Reference is made to the criteria for socio-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 adventitious 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 agriculturally utilised area); (2) the highest portion of organic growing area.

o A minimum general framework must be guaranteed which allows each farm to maintain a GMO-free production (including cross-border cultivation areas).

o Due to the small structure of Austria’s areas 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 technologies does not take account of the many regionally specific needs.

o Politically, Austria thus advocates a right of self-determination concerning cultivation, not only vis-à-vis the EU, but also on the part of Austria’s nine Federal Provinces, all of which are members of the European Network of GMO free Regions.

o The answer to the questionnaire is complemented 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 to: (1) Launch a process for policy development which allows for inputs of a broad range of stakeholders; (2) Identify and conduct research on impact 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 well as the normative baselines and criteria.

3. Overview of the answers to the questionnaire[8]

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 relations must be expected as well as protest campaigns. Wilful destruction cannot be ruled out.

o GMOs pose the risk of out crossing and contamination of other crops as well as the resulting questions of liability. Long running 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 GMOs would be jeopardised. The same would apply to GM free beekeeping products, dairy sector and 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-ethanol 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 conventional breeding and control methods.

o Complete logistical separation between conventional/organic and GM seed/harvest would be hardly achievable, thus the cultivation of GMOs would threaten non-GM farming.

o Similarly to hybrid maize, contractual obligations of farmers concerning the purchasing of the GM seed (with the herbicide for 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 all market opportunities can be met with it.

Impacts on downstream operators

o Austrian consumers clearly advocate supply with GMO-free products.

o Segregation should cause additional investment, 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 coexistence and segregation amount to up to 13% of the product turnover for oil mills and the starch industry[9].

o The Austrian food chain has dedicated itself to offer exclusively products not labelled as GM. It avoided the expected high costs of establishing a segregation chain.

o No insurance available that covers 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 (specific expert knowledge, checking compliance with legal regulations on GMO cultivation, monitoring on the entire chain).

Economic context

o Austria questions whether a complete free internal 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 the 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, climate change, etc), so this question cannot even been discussed at theoretical level.

Other implications

o No answer

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Belgium[10]

1. About Belgium

o The use of GMOs for cultivation is a matter falling under the competence of the Regions.

o No GMO cultivation[11]. One exception: in 2010, a coexistence experiment with Bt-maize (1ha of maize MON810) was conducted to evaluate the Flemish coexistence measures (legislation and sampling procedures).

o Research activities: Dissemination experiments resumed in spring 2009, after a suspension between 2004 and 2008[12].

o Coexistence rules adopted[13].

2. General comments

o BE answer consists in (1) a compilation of the crude contributions of the 12 stakeholders involved, including some public services, (2) a report of a workshop organised in Belgium on 29 March 2010 on the evaluation of the socio-economic impact of GMOs (available on internet[14]).

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-economic impact of GMO cultivation, a specific effort should be devoted to the identification of the scope of alternatives to such agricultural practice. A systemic approach could then compare short and long-term impacts of a GMO based agriculture to those of existing or other potential innovative pathways[15].

o For the federal Environment department, socio-economic criteria should not bypass biosafety criteria.

o The regional government of Wallonia is in favour of a moratorium on dissemination of GMOs into the environment and putting on the market as long as absence of risk for health and environment as well as socio-economic advantages has not been demonstrated.

o The federal public service Health, Food Chain Safety and Environment organised a workshop entitled “Visions on the evaluation of the socio-economic impact of Food 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 farmers) is open to new GMOs for cultivation as long as they are thoroughly evaluated (science-based), sustainable and socially responsible.

o The Greenpeace contribution covers GMOs at large, not just cultivation.

o For the federal Environment department, sustainability 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.

1. Overview of the answers to the questionnaire[16]

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 would remain an important socio-economical issue, to which are linked various other sustainability issues.

o For Greenpeace, the more GMOs are cultivated, the more conventional and biological farmers will have to invest in preventive anti-contaminations means, as GM farmers are not responsible for potential cross contaminations 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 (national professional association of feed producers), if a better yield is obtained with GM feed cultures (for ex. Bt maize ), 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 guarantee the provision of non GM feed (e.g. non GM Soya from Brazil). Labelling of non GM fed livestock 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 conventional seeds. The Austrian Seed Purity Act should be considered as a model.

Impacts on downstream operators

o SYNAGRA (national syndicate for cereals and dried fruits trade) considers that GMOs cultivated in Belgium should not be dealt separately in the food chain, in order to avoid supplementary costs in infrastructures and workload. Furthermore, even with segregation, cross contamination cannot be avoided.

o Public authorities (federal Environment department and regional government of Wallonia) report costs to be supported by the public budget already in the absence of cultivated GMOs on the market: cost of risk assessment by the Belgian Biosafety Advisory Council: costs of controls of labelling of products, cost of post monitoring of field trials, costs of control of non contamination of conventional seeds, 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 anticipate potential costs that would 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 traceability costs along the food production chain. However, should GMOs be accepted by consumers, the range of products proposed to the consumers would significantly expand, agriculture 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 should do better (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 biodiversity 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 for GMOs cultivation should mind taking into account international environmental and public rights agreements signed by the EU and its Member States. This view is shared by the federal Development Cooperation department.

o Greenpeace considers that cultivation of BT maize ends up in much higher contamination rate of the soil than with conventional practices, due to the continuous production of the pesticide by the crop. Furthermore, the benefit of the eradication of the primary pest is cancelled by the development of secondary pests, which then have to be fought against with additional pesticides. Finally, the excessive use of BT through BT crops could generate resistance, what would be a big problem for the biological farmers also using BT insecticides.

o Greenpeace considers that HT crops stimulate 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 that 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 diversity, rather than promoting monoculture (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-ante 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 process against GMOs without any scientific base.

o Following the federal Environment department, some socio-economical impacts could already be evaluated once the destination of the GMO is planned; this assessment could be built step by step, being potentially informative from the field trial phase on.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Cyprus[17]

1. About Cyprus

o No GMO cultivation[18].

o Research activities on GMOs: no field trial notifications between 2002 and 2007[19].

o No coexistence rules adopted[20].

2. General comments

No information

3. Overview of the answers to the questionnaire[21]

Economic and social implications

Impacts on upstream operators

o Countries that cultivate GMOs have increased their use of insecticides but it is difficult to assess the risk and gain specific knowledge since in the EU only Spain cultivates GMOs commercially and no adequate studies have been published. More research is needed.

o Specific conditions in Cyprus: fragmentation of land, small size of fields and small distances between them, high endemic flora, special 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 coordination 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 medium enterprises. GM seeds would reduce the market share of conventional and organic seeds and thus probably have adverse impact on turnover, employment and profit of these small companies.

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 pesticides 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 preference to lower the labelling 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 general, quality of products will be questionable.

o If GM feed dominate the market and its price 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 imports. 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 GMO research (other priorities are set regarding the agricultural sector).

o Public administration: in the event of GMO cultivation, the administrative costs will increase substantially since more monitoring and control will be needed in various sectors of the public administration.

Economic context

o It is difficult to evaluate the potential impact on the internal market but negative impacts are foreseen regarding the local seed producers, 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 established (coexistence) and monoculture will increase.

o GMO cultivation will possibly affect the good reputation of an area. An additional negative agrotourism is to be expected (including due to the decrease of biodiversity).

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 negative impact on other useful insects and on the global biodiversity (including fauna and productivity of the soil).

o New traits could offer advantages that could lead to the widespread 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 their diet which may have 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 enabling 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 whose diet depends on insects.

o Small-scale agriculture, natural habitats protection 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 produce 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 selected for the specific conditions in order to adapt to new climatic conditions of the island.

Other implications

o No Answer

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution

by Czech Republic[22]

1. About Czech Republic

o Cultivates MON810 Maize since 2005 (approx. 6,480 ha in 2009)[23].

o Research activities: 11 notifications for field trials between 2002 and 2007[24]. 4 notifications for field trials in 2008 (according to the SNIF database)

o Coexistence rules adopted[25].

2. General comments

o 526 stakeholders were consulted, with a 12% answer rate.

o The Czech Republic welcomes the questionnaire and the discussions on the socio-economic aspects of cultivation of GMOs.

o "The views of the consultees are not necessarily the same as the formal position of the Czech Republic's government".

3. Overview of the answers to the questionnaire[26]

Economic and social implications

Impacts on upstream operators

o For 78 % of respondents, GMOs had a positive effect 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 research 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 available, 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).

o 77% of responding farmers reported equal or lower production costs, resulting from lower (or none) insecticide treatments, lower handling 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 conflicts or mentioned threat of such conflicts.

o 77% of responding GM growers reported difficulties to sell the GM harvest (therefore GM harvest is used as a feed 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 the reduction of use of insecticides.

o Respondents report significant gains in labour flexibility when pest pressure is high (less or no need for chemical treatment).

o For consultees cultivating GM maize, the effect of GM crops on livestock is positive – production of plants with lower mycotoxin content finally resulting in lower costs for veterinary care. No opinion on the issue was obtained from organic farmers.

o For 72% of consultees, health of labours improves due to reduced exposure to chemicals. 28% considered that the difference is minimal 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 influence 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 attention to a possible consumers' reluctance to buy honey products contaminated with GM pollen.

o If GM cultivation significantly expands, difficulties to find sufficient 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 development by international seed companies.

Impacts on downstream operator

o Lower level of mycotoxin leads to higher quality products. However, GMO cultivation in higher extent could decrease the 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 the right to choice has being kept.

o Segregation GM/non-GM complicates organisation of work and increases costs and administrative burden for cooperatives and grain handling companies (activity records, labelling, controls).

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 segregation 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 methods 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 Ministry of the Environment (GMO reference laboratories ~ 22.500 EUR in 2009).

Economic effect

o 42 % of respondents assumed that placing on the 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, introduction of GMOs does not put at risk crop varieties as limited to Bt for now. But sound scientific assessment of this potential impact if GM crops are more cultivated in future should be carried out.

o Protected species/migration routes/biodiversity: for a majority, there is no more danger with GMOs than for conventional crops if inappropriately cultivated. Ca 21 % of consultees considered that there is a lack of data to assess any of the mentioned categories for the moment.

o Extensive research carried out in the Czech Republic on impact of Bt on non-target organisms demonstrated positive impact on their diversity.

o No negative impact is anticipated on renewable resources. The real problem lies in bad farming practice (for both GM and conventional crops). Some consider that GMOs could also have a positive impact by increasing production of plants for biofuels.

o According to 38 % of consultees, a positive impact on the use of non renewable resources is expected due to less treatment i.e. less use of fossil fuels (tractors/production of biocides). But no macro scale impact due to the limited surface of cultivated in the Czech Republic.

o According to 86 % of consultees GM crops could help fighting against extension of pest due to warming.

Other implications

o No answer.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Germany[27]

1. About Germany

o Cultivation of MON810 Maize until 2008 (3371 ha in 2008); cultivation of Amflora[28].

o Research activities on GMOs: 49 field trials notified between 2002 and 2007 (apple; barley; maize; oilseed rape; pea; poplar; potato; Solanum nigrum; soybean; wheat)[29].

o Coexistence rules adopted[30].

2. General comments

o The questionnaire was sent to 25 stakeholders and to all German Federal Länders. 20 responses were received (12 from official institutions, 3 from industry, and one for institutions representing farmers, retailers, consumers, or NGOs, respectively). Germany considers that these 20 responses do not allow answering properly to the Commission Questionnaire. Therefore the German response 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 context of intensive agriculture. It should be evaluated if conclusions from 3rd countries could be transferred to the European conditions.

o The evaluation of socio-economic consequences 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 could be relevant for risk management decisions should be considered for the formulation of EU criteria.

o Socio-economic criteria can be included, in addition to the scientific risk assessments, in risk management decisions in the context of a European authorization of GMOs. For this the definition of specific criteria is needed, which needs to be based on a precise and complete definition of the elements of these criteria.

o Socio-economic criteria should consider WTO rules and basic rights of the Lisbon treaty.

3. Overview of the answers to the questionnaire[31]

o The responses were, in most cases not covering 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 answers were general and some provided available information or reports for further consideration, 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 compilation below is necessarily biased due to the reduced number of responses and the incomplete 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 SMEs can not invest in green biotechnology (high administrative costs for the regulatory processes without a guarantee on the results, slow transfer of research results into praxis, 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 threshold based on technical possibilities).

o Reduced production costs due to a reduction in the use of pesticides (Bt-maize), more secured harvest, better quality of the harvest (reduced presence of mycotoxins).

o Higher administrative costs for farmers because 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 would 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 supported by farmer associations nor NGOs.

o Farmer advice not to cultivate GMOs because 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 companies is expected (need to separate non-GMO and GMO production lines, and respective controls).

o An impact on price of goods could be possible 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/with 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 labelling 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 expected due to asynchronous authorisation and zero tolerance of non-authorised GMOs in Europe.

o The cultivation of GMOs should only be allowed if the coexistence with conventional crops is guaranteed, since otherwise the free choice of the consumer is not guaranteed.

o Public administration: important cost increase (implementation/monitoring of cultivation).

Economic context

o An impact on the European internal marked is expected (differences between the Member States when transposing the European legislation into national legislation are expected).

o In the case of continuing with the zero-tolerance 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 acceptable 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 costs 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. Potential 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 costs are associated with this "buffer zones".

o Since tolerance to herbicides or resistance to insects could be achieved also by traditional breeding methods, a change of agricultural management achieved by the use of new varieties should be evaluated independently of the techniques used.

o The non authorization of drought tolerant GM crops would be irresponsible (higher yields with the same resources and less CO2 emissions).

o The legislation in the areas of GMO and natural protection (Food Fauna Habitat Directive) is not sufficiently harmonised.

Other implications

o Independent and transparent research is needed, in particular 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 consumers, more information should be given, including on risks and benefits associated with the use of GMO products.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Denmark[32]

1. About Denmark

o No cultivation of GMOs[33].

o Research activities on GMOs: 8 field trial notifications between 2002 and 2007[34].

o Coexistence rules adopted[35].

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 prerequisite 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 questionnaire[36]

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 suffering many extra costs to prevent GMO-contamination. The application of the "polluter pays" principle is reversed.

o Danish Seed Council APVD: GM seeds producers may not improve economic output but might realize lower input.

o Danish Seed Council APVD: The farmer must have access to seeds from several companies.

o Greenpeace: The contamination risk means that, 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 farmers: 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 saved seeds will probably be of minor importance in Denmark as most farmers is buying certified seeds paying a license even for farm saved seeds.

o Danish Beekeepers' association: Beekeepers fear that GM crops will make biodiversity even further decrease, monocultures increase and have a negative impact on the vitality of honeybee colonies. Beekeeping and honey production is considered to be not adequately covered in the "co-existence" legislation (GMO grower is not liable to pay compensation in case of damage, no protection for the beekeeper against non intentional presence of GMOs in its products).

o Cooperation of biodynamic consumers/agriculturalists: 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. Furthermore, 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 competitiveness of European Seed Industry. The development of new products is necessary to increase or secure employment, turn-over and profits. However, it is predicted 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 breeding in the future, respecting breeder's exemption.

o Danish Seed Council APVD: As regards seed production, identification of seed production areas with least impact on production of conventional varieties can be an issue.

o Danish Seed Council APVD/Danish Agriculture 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 the ability to engage in GM seed development. However, production 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, the 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 must prevent spreading and apply coexistence legislation. They are, however, currently handling imported products containing GMOs.

o Public institutions: Innovation and research: increasing need for information and trials on the potential environmental effects (genetic interactions, 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 genetic resources and tools (other modern breeding technologies).

Economic context

o Public institutions: The 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 and 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: field edge effects, long term effects, landscape effects, non-target effects, monitoring programs.

o Cooperation of biodynamic consumers/agriculturalists: Several already existing challenges regarding environment, climate and public health will further deteriorate. By keeping GMOs out, it is believed that over time the livestock production within the EU will diminish due to an expected lack of GM-free 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 (resistant to drought, temporary flooding, saline conditions) constitute a possible adaptive capacity 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 any 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 CO2 and 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.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Estonia[37]

1. About Estonia

o No GMO cultivation[38].

o Research activities on GMOs: no field trials but contained use research ongoing[39].

o No coexistence rules adopted yet[40], 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 questionnaire[41]

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. Compensation of damages is regulated 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 required to avoid any possible contamination.

Impacts on downstream operators

o According to a survey among Estonians (2009), 43% of the population would not buy GM products, only 2% agree to buy, rest of them are not sure about their preferences. 54% of 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 cleaning 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 investment in plant research, number of patents held by European organisations, investment 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 resources, and expected effect on access to new knowledge.

o Public administration: Several costs are foreseen (surveillance, operating costs of GMO register etc…)

Economic context

o Possible cross-border investments flows

Agronomic sustainability

o Patterns of use of chemical herbicides would change and the amount of used herbicides may rise as well.

o Supposedly there is no impact on the climate in EU. GMOs are not cultivated in sufficiently large areas to talk about any measurable impact on climate change.

Other implications

o No answer

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Greece[42]

1. About Greece

o No cultivation of GMOs[43].

o No research activities on GMOs[44].

o No coexistence rules adopted[45].

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 apiculture 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 questionnaire[46]

Economic and social implications

Impacts on upstream operators

o Contamination risks for non-GM crop farmers, need for extra controls of all seeds, coexistence cannot be controlled as the acreage in Greece is small, farmers will suffer from contaminations causing conflicts among neighbours.

o Beekeepers would not be able anymore to produce 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 carried out. Need for additional analysis.

o Seed production: need for additional measures for seed production, 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 other 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.

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 price, while the non-GM product would present a gradually decreased diversity and will become ore and more expensive. Consumer choice will 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 taxation of the added value.

o New employment and investment opportunities (directly or through collaboration with public research institutes.

o Additional financial surcharge in all levels (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 inadequate to allow for coexistence. Grain handling installations do not have by design the proper structure to prevent mixing.

o Transport: delays and extra cleaning are also expected to add an extra cost but problems will remain minimal if procedures are followed.

o Feed traders consider that there would be significant 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 could go down due to the economy of scaling up). People would need to be skilled and specialised. Time for analysis is expected to increase.

o Public administration: government will have to allocate funds and important resources in order to organize, policing, putting enforcement costs and quality control testing.

Economic context

o Risk of mono or oligo-polizing in the seed market.

o Could lead progressively to an increase in the size of farms and decrease the number of farmers and monoculture.

Agronomic sustainability

o In case of insect resistant plants, possible increase of secondary pests, 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.

o In case of HT crops: possible increase of selection pressure for resistant weed biotypes and reinforcement of the use of broad spectrum herbicides.

o Possible irreversible adverse effects on biodiversity.

o Loss of traditional varieties and knowledge. Reducing diversity of cultivars may case problems such as higher susceptibility 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, possibly enabling them to out-compete other species.

o Insect resistant GMOs may reduce the number of phytophagous and pollen-feeding insects in the field, which could have an impact throughout the food chain.

o Peer-reviewed studies have demonstrated that 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 bees and feeding collection capacity.

o Possible impact of GM plants on the environment 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 biogeochemical cycles and soil biotransformation and decomposition processes on ecosystem function;

– Increased persistence in the environment through increased survival, establishment and invasiveness of GM plants;

– Adverse effects on non-target organisms;

– Wider biodiversity implications as a consequence of specific agronomic practices to manage GM plants;

– Changes in pesticide residues 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

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Spain[47]

1. About Spain

o MON 810 cultivated since 1997 (76,057 ha in 2009)[48].

o Research activities: 165 field trials notified between 2002 and 2007 (cotton, grape/plum, carrizo citrange, maize, potato, rice, soybean, sugar beet, wheat)[49].

o No coexistence rules adopted[50].

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 questionnaire[51]

Economic and social implications

Impacts on upstream operators

o Potential for EU research would be significant if GMOs were better accepted in the EU. However R&D on GMOs would affect research 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 period, but afterwards much material would be available for research. For the public administration and researchers, the current lack of visibility on the evolution 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 institutions, for provinces infested 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 yield 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 yield 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 hectare depending on the year and areas of cultivation (Gómez-Barbero et al, 2008).

o The growing surface planted in Spain –from 22.000 ha in 1998 to 76.000 ha in 2009[52]– 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 impact 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 growers, with 12 years of experience in Bt maizes no problems have been reported so far thanks to appropriate good farming/co-existence practices.

o For environment protection associations, co-existence 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 innovators, Bt maize harvests contain less mycotoxins.

o For public authorities and innovators, decreased 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 pesticides can remain high as more herbicides can be used depending of farming practices.

o For public authorities and innovators, patenting of the crops and prohibition of plant breeder's right is not perceived as an additional constraint or as an additional risk on availability of non GM varieties, 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 providing such products to the market place.

o Since there is no legislation in the EU concerning the presence of GM seeds in batches of conventional varieties, there is disparity in the criteria and measures taken by Member states; therefore, a 100% GMO free organic farming cannot be guaranteed.

Impacts on downstream operators

o For the administration, GMOs contribute to enlarge consumers' choice (GMOs, conventional, organic), decrease prices. Acceptance levels of Spaniards for GM food are among the highest of the EU (Eurobarometer 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 information would help increasing acceptance levels.

o Environment protection associations 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 ignores 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 segregation to guarantee the purity of their stocks.

o The prices of the organic products 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) should 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 threshold 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 authorisation or LLP, despite 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 resulted in a reduction of 0,54 insecticide applications 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 research institutions, no environmental impact should be expected since an assessment 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. Furthermore, less needs in insecticides/herbicides means less production, transport and recycling of these agro-chemicals.

o Climate change: new GM traits could be more adapted to drier climate conditions.

o CO2 emissions: benefit expected due to reduced transport and applications of pesticides, and simplified tillage operations.

o Recent studies for indicate that if EU farmers 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 play 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 within 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 cultivation by EFSA and Member State Authorities.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Finland[53]

1. About Finland

o No cultivation of GMOs[54].

o Research activities on GMOs: 2 field trial notifications between 2002 and 2007[55].

o No coexistence rules adopted[56].

2. General comments

o The Finnish contribution is a compilation of answers received from the following stakeholders: MTT Agrifood Research Finland; Finnish union of organic farming (FUOF); Finnish beekeepers association; Finnish Food and Drink Industry Federation (FFDIF); Professor in Microbiology/University of Helsinki; Finnish Environment Institute (FEI), the Finnish Consumer's Association (FCA), the Seed Traders Association (STA), Finnish Forest Research Institute (FFRI), the Sugar Beet Research Centre Finland and professors of agro-ecology and plant breeding of the University of Helsinki.

o Answering to the questions considered challenging (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 questionnaire[57]

Economic and social implications

Impacts on upstream operators

o Co-existence issues in the field 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 farmers or other neighbours may arise.

o Bees' health and quality of honey can be affected by low nutritional value of GM pollen.

o Bees could go on non-food GM plants and pollen could be found in honey. All GM plants entering the market should be accepted for as human food.

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 (status 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 varieties. 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 analysis 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 plant 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 choice. Consumers need to get a clear benefit.

o Link between price, GM-characteristic of goods and propensity of consumers to buy them is not clear.

o Cooperatives, grain handling companies, transport companies: handling, storage, logistics can be a problem.

o Insurance companies: the fact that no insurance 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 for rotation, the farm's business becomes non-profitable.

Agronomic sustainability

o GM potato has potential to decrease the use of fungicides but risk of resistance is possible over time.

o There is an interest in the GM potato to reduce the production costs of seeds (losses due to viruses and mycosis are very high).

o There is a possibility to reduce the use of herbicides when cultivating HT sugar beet but the cultivation of HT rapeseed may increase the amount of herbicide used.

o 2 HT beets were tested[58] and demonstrate an economic benefit in using the HT version. The risks and benefits of the GM varieties could 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 fuel use and soil compaction). Risks would be: disappearance of other herbicides from the market, accelerated appearance of HT weeds, HT gene moving to weedy relatives and causing a more problematic weed development, increase of the use of total mount of herbicides

o GMO sugar beet and other GM crops are valuable steps. It would be extremely important to make good evaluations for minimizing 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 with non-renewable resources.

o The efficiency of the use of field and forest 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 environments. 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 developed. 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 uncontrolled spreading and admixture. Very strict transport conditions are therefore necessary.

Other implications

o No answer.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by France[59]

1. About France

o Cultivation of Bt maize until 2007[60].

o Research activities on GMOs: 75 field trial notifications between 2002 and 2007[61].

o Coexistence legislative framework adopted[62].

2. General comments

o The French contribution consists in (1) an opinion of the High Council of Biotechnologies, consisting of an opinion of its scientific committee and a recommendation of its economic, ethical and social committee, (2) contributions by scientists from the National Institute of Research in Agronomy (INRA) and (3) contributions from 43 stakeholders.

o The format and methodology of the questionnaire was challenged by several respondents.

o The High Council for Biotechnologies made suggestions on the methodology and procedures to consider socio-economic factors in the process of evaluation and authorisation of GMOs.

3. Overview of the answers to the questionnaire[63]

Economic and social implications

Impacts on upstream operators

o Seeds producers and growers stress that GMOs are effective tools for farmers to better manage pest pressure and prepare to the forthcoming climate changes. If properly regulated, co-existence should not be problematic.

o For environmental associations and organic producers, 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 adventitious presence of GMOs.

o Environmental associations and organic producer stress that apiculture is at heart of the problem. Honey can contain GM pollen (with negative impact on the marketability of the products and by-products) and bees can be vectors of diffusion of GM pollen into non-GM crop fields.

o Environmental associations and organic producer consider that GMOs increase the dependence of farmers toward seed/agrochemical 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 conventional hybrids. Such dependence is the consequence of the political decisions taken at European and international levels.

o Insurance companies do not propose insurance 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, higher 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 material will be more expensive or less available for all farmers, due to the higher cost and length of cleanings.

o As regards the cost of co-existence in general, reference is made to the study Coex1 by the Joint Research Center. Organic farmers and environmental 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 growers underline that, when pest pressure is high, Bt maize harvest contain 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 animal health problems over the last ten years. They call for a better 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 keep developing seeds for all markets, i.e. conventional, GM and organic. France being the 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 farmers, who will have difficulties to know whether varieties they use are protected or not.

o Seed producers consider that farmers and 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 issue if adventitious presence thresholds are not too low. However, COOP de France underlines that the stricter thresholds for GMOs are more challenging. Environment/organic associations consider that such segregation will generate unbearable extra-costs for the non-GM food chains and for consumers of non-GM food.

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. destruction of experimental cultivations). Consequently, young researchers are not attracted by biotechnologies, and France fully depends from innovations developed abroad.

Impacts on downstream operators

o Consumers, environment protection and conventional/organic producers associations claim that consumers do not see any added value in GM food. 72% of French consumers think it is important to be able to consume 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, "GM 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 2008 in 8 farms by AGPM concluded that MON810 allows reducing the use of insecticides. Saving for farmers can be up to 93€/ha, depending of the number of applications.

o Environment and organic association contest the agronomic sustainability of GMOs over time, even if results could be positive in the first years. Furthermore, GMOs are associated to the intensive monoculture model, which agronomic sustainability is negative (fertilizers, over consumption 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 spreading), and sequestration of greenhouse gas. Environment and organic associations consider that same or better results can be achieved thought improved cultivation practice of conventional crops.

Other implications

o Several respondents underline the need to address rapidly the challenge of world food crisis in the next 40 years. Increase of yields and more sustainable 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.

Socio-economic implications of GMO cultivation

Non exhaustive compilation of the contribution by Hungary[64]

1. About Hungary

o No cultivation of GMOs[65].

o Research activities on GMOs: 26 field trial notifications between 2002 and 2007[66].

o Coexistence rules adopted[67].

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 evaluation should be set up, inspired by Norway, where the impact assessment of a GM release should consider health, environment, benefit to society (in both the producing and 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 Modified 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 questionnaire[68]

Economic and social implications

Impacts on upstream operators

o Surveys of farmers show negative opinion about the benefits of using GMOs.

o Cross-contaminations are unavoidable (cf international practices). Extra costs due to laboratory test for GMO contamination will increase production costs and tensions between farmers.

o Experience in Spain shows that organic agriculture 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 international studies (including USDA 2006).

o International experience with GMOs shows advantageous effects for large scale farmers. However, increase of profitability cannot be unequivocally established or proved. The decrease of use of pest/weed control materials tend to reverse after 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 the 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 family based model of agriculture should be preserved.

o Seed producers will have to set up segregation systems. Hungary wants to preserve its capacity to produce GM-free seeds (clear market 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%, prices of conventional/organic goods will drop. GMOs can decrease the profitability of farmers and industry 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 coexistence is inefficient (bees 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 introduced, 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 adventitious presence). Overall, loss of profitability of the whole conventional/organic sector, leading to its vanishing. Local and traditional varieties may disappear which also means that without customs the domestic plant breeding institutes will have difficulties to survive.

o The whole seed business wou