Report from the Commission to the Council and the European Parliament on the implementation of Regulation (EC) No 1830/2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC
Date: 2006-05-10
Institutions: European Commission
Subjects: EC Regulation, animal nutrition, application of EU law, genetically modified organism, human nutrition, labelling, new product, report, traceability

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 10.5.2006 
COM(2006) 197 final 

REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN 
PARLIAMENT 

on the implementation of Regulation (EC) No 1830/2003 concerning the traceability and 
labelling of genetically modified organisms and the traceability of food and feed 
products produced from genetically modified organisms and amending Directive 
2001/18/EC 

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REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN 
PARLIAMENT 

on the implementation of Regulation (EC) No 1830/2003 concerning the traceability and 
labelling of genetically modified organisms and the traceability of food and feed 
products produced from genetically modified organisms and amending Directive 
2001/18/EC 

Introduction 

Regulation (EC) No 1830/20031 (hereinafter ‘the Regulation’) was adopted on 22 September 
2003 and following the publication of Commission Regulation (EC) No 65/2004 establishing 
a  system  for  the  development  and  assignment  of  unique  identifiers  for  genetically  modified 
organisms2, fully applicable on 16 April 2004. 

The  labelling  and  traceability  requirements  of  the  Regulation  extend  to  products  that  are 
placed  on  the  market  and  which  contain  or  consist  of  genetically  modified  organisms 
(GMOs).  The  Regulation  also  includes  provisions  for  the  traceability  of  food  and  feed 
products produced from GMOs. 

The objectives for traceability under the Regulation are to facilitate; 

•  control and verification of labelling claims 

•  targeted monitoring of potential effects on the environment, where appropriate 

•  identification  and  withdrawal  of  products  that  contain  or  consist  of  GMOs  should  an 

unforeseen risk to human health or the environment be established 

To  ensure  traceability  and  labelling,  the  provisions  of  the  Regulation  require  operators  to 
transmit  and  retain  specified  information  for  the  above  GM  product  types  at  each  stage  of 
their placing on the market. Notably; 

•  operators  are  required  to  have  systems  and  procedures  in  place  to  identify  to  whom  and 

from whom products are made available 

•  for  GMOs  intended for  deliberate  release  into  the  environment  (eg.  seeds),  operators  are 
required  to  transmit  specified  information  on  the  identity  (unique  identifier)  of  the 
individual GMO(s) a product contains 

•  for  GMOs  intended  for  food,  feed  or  for  processing,  operators  may  either  transmit  the 
specified information detailed above or transmit a declaration that the product shall only be 
used as food or feed or for processing, together with the identity of the GMO(s) that have 
been used to constitute the mixture 

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2 

OJ L 268, 18.10.2003, p. 24. 
OJ L 10, 16.01.2004, p. 5. 

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•  for  food  and  feed  produced  from  GMO(s)  operators  are  required  to  inform  the  next 

operator in the chain that the product is produced from GMO(s) 

•  operators  are  required  to  retain  the  information  for  a  period  of  5  years  and  make  it 

available to competent authorities on demand 

•  thresholds  have  been  established  below  which  adventitious  or  technically  unavoidable 
traces  of  certain  GMOs  and  GM  material,  in  food,  feed  and  processing  products,  do  not 
require labelling or tracing 

Transmission  and  retention  of  the  above  information  is  intended  to  reduce  the  need  for 
sampling  and  testing  of  products,  which  is  not  an  obligatory  requirement  for  the  operators 
under  the  Regulation.  Nevertheless,  to  facilitate  a  co-ordinated  approach  for  inspection  and 
control  by  the  Member  States,  the  Commission  has  developed  technical  guidance3  on 
sampling and testing methods. 

In  view  of  the  requirements  of  the  Regulation,  it  is  important  to  note  that  at  the  time  of 
finalising this report, a decision on documentation requirements for GMOs intended for food, 
feed  or  for  processing4  to  be  used  in  international  trade  was  adopted  under  the  Cartagena 
Protocol on Biosafety (Third Meeting of the Parties, 13 to 17 March 2006, Curitiba, Brazil).  

According  to  this  decision,  Parties  to  the  Protocol  must  take  measures  to  ensure  that 
documentation  accompanying  international  shipments  of  GMOs  in  commercial  production 
includes  the  identity  of  the  GMOs  contained  in  the  shipment,  when  their  precise  identity  is 
known.  In  cases  where  the  identity  of  GMOs  in  a  shipment  is  not  precisely  known, 
documentation should make clear that the shipment "may contain" GMOs, together with the 
identity of the GMOs that may be contained in the shipment. 

The  decision  is  consistent  with  the  traceability  requirements  of  the  Regulation,  in  particular 
with regard to its Article 4(3). The implementation of this decision will be reviewed in 20125, 
when the feasibility of extending the requirement for precise information on the identity of the 
GMOs contained in an international shipment will be assessed. For this purpose, experience 
gained with the Regulation should provide useful information. 

Interplay with Regulation (EC) No 1829/2003 

Regulation  (EC)  No  1829/2003  on  genetically  modified  food  and  feed6  was  developed 
alongside  the Regulation and was  also adopted on 22 September 2003. The two regulations 
are intended to operate in tandem and rely on each other for certain requirements. Notably, the 
Regulation provides traceability requirements for all food and feed products that fall under the 
scope of Regulation (EC) No 1829/2003. These traceability requirements are of fundamental 
importance  when  labelling  of  the  final  product  relies  on  information  transmission  in  the 
absence of detectable GM material in products. 

Similarly,  the  labelling  requirements  for  food  and  feed  products  produced  from  GMOs, 
subject to the traceability requirements under Article 5 of the Regulation, are provided for by 

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6 

OJ L 348, 24.11.2004, p. 18. 
Article 18.2(a) of the Cartagena Protocol on Biosafety 
6th Meeting of the Parties to the Cartagena Protocol on Biosafety 
OJ L 268, 18.10.2003, p.1. 

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Chapter  II,  Section  II  and  Chapter  III,  section  II  of  Regulation  (EC)  No  1829/2003.  In 
addition,  Regulation  (EC)  No  1829/2003  lays  down  threshold  values  for  food  and  feed 
products  below  which  adventitious  traces  of  such  products  are  exempted  from  its  labelling 
requirements. The same thresholds have been utilised by the Regulation to provide the same 
exemption  from  its  own  labelling  and  traceability  requirements  ensuring  a  coherent  and 
consistent Community approach. 

Article 12 of the Regulation states that; ‘no later than 18 October 2005, the Commission shall 
forward to the European Parliament and to the Council a report on the implementation of the 
Regulation, in particular with regard to Article 4(3)’. 

In  accounting  for  this  requirement,  the  Commission  compiled  a  questionnaire  comprising 
questions on implementation in five sections as follows; 

•  Traceability requirements 

•  Labelling requirements 

•  Exemptions from traceability and labelling requirements 

•  Inspection and control measures 

•  Other issues  

The questionnaire was submitted to all competent authorities, as well as relevant stakeholders 
from  all  sectors,  including  members  and  associations  of  the  food,  feed  and  seed  industry, 
trading  partners,  NGOs  and  relevant  government  departments  of  Member  States.  A  list  of 
respondees is presented in Annex 1. 

The responses, as well as other information received and retrieved by the Commission from 
the date of application of the Regulation to the current time, have been taken into account in 
the report as laid down in the following sections. 

Regulation  (EC)  No  1829/2003  contains  a  similar  requirement  (Article  48)  for  the 
Commission  to  produce  a  report,  no  later  than  7  November  2005,  concerning  experiences 
gained  with  this  regulation.  The  Commission  has  taken  account  of  the  above  interplay 
between the two regulations and has attempted to avoid duplication in the two reports.  

The food production and distribution chains 

The  European  food  and  retailing  industries  remain  reticent  to  market  GM  food  and  food 
products  due  to  the  perception  of  negative  consumer  reaction.  As  a  result,  only  a  limited 
number of products are currently being marketed and imported GM material is currently not 
utilised in food products to any great extent.  

The European industry recognises that consumer and public perception drives market forces 
and that a high level of health and environmental protection must be ensured in order to be 
able  to  market  GM  products.  The  industry  currently  appears  to  be  responding 
to 
retailer/consumers  demands  of  non-GM  products  and  is,  therefore,  attempting  to  avoid  purchasing 
ingredients containing or produced from GMOs. 

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Trading partners do not appear to share this view. Indeed, a large third country food exporter 
has  stated  that  it  no  longer  exports  any  processed  food  products  to  the  European  Union.  It 
alleges that this is due to the burden of the regulatory framework, which specifically includes 
the traceability provisions of the Regulation, rather than to market demand. 

A third country industry association has stated that many companies marketing food products 
in the European Union have stopped using internally produced GM soybean  oil and  protein 
ingredients  to  avoid  what  are  perceived  as  onerous  and  costly  mandatory  traceability 
requirements of the Regulation. It has also stated that the requirements have allegedly led to a 
decrease  in  the  export  of  certified  organic  commodities  containing  soybean  material.  This 
problem has been attributed to the ‘restrictive’ 0.9% threshold for adventitious presence.  

A second food association also argues that an additional layer of administrative and financial 
costs  is  imposed  by  the  labelling  and  traceability  requirements  and  highlights,  in  particular, 
that  this  has  created  an  unacceptable  burden  on  small  food  exporters.  It  also  suggests  that 
conflicting  national  regulations  and  different  approaches  to  enforcement  in  individual 
Member States adds to the regulatory burden of business transactions. 

An  overseas  Government  Department,  in  its  response  to  the  questionnaire,  similarly  claims 
that  the  Regulation  is  a  barrier  to  trade  arguing  that  it  is  too  restrictive  and  provides  a 
disincentive  for  manufacturers  to  place  GM  products  on  the  market.  However  it  should  be 
noted that available data - and in particular the relevant market share of GM products in the 
feed distribution chain - do not confirm this view, indicating, on the contrary, that GM food 
trade patterns are largely market (consumers) driven.  

This  Government  Department  also  alleges  that  the  reluctance  of  European  industry  to  offer 
GM products to consumers, the lack of implementation of the Regulation by certain Member 
States  and  delays  in  new  product  approvals  have  provided  major  obstacles  in  obtaining 
relevant information in terms of implementation of the Regulation, notably with respect to its 
Article  4(3).  The  Department  further  suggests  in  its  response  that  it  is  difficult  for 
stakeholders to provide practical input to this report (as a means to improve the consistency of 
the Regulation) given that they do not have the necessary experience with its implementation 
as yet. 

In particular, the US Government (and certain third country food associations) has urged that 
the  European  Commission  joins  with  trading  partners  to  work  towards  harmonisation  and 
some form of mutual recognition of the trade of GM products that relieves small enterprises 
of  such  administrative  burdens.  They  suggest,  in  particular,  a  need  for  guidance  on 
documentary  requirements  to  address  the  issue  of  consistent  implementation.  It  should  be 
noted  that  the  Commission  has  actively  engaged  in  and  remains  open  to  international 
discussions  with  trading  partners  but  since  2002,  the  US  Government  has  been  reticent  to 
engage in bi-lateral discussions on issues pertaining to GMOs. 

In  terms  of  the  limited  number  of  food  products  that  are  currently  marketed,  certain  NGO 
groups  express  that  in  general,  the  labelling  rules  have  a  positive  effect  in  facilitating 
informed choice. 

However,  they  also  state  that  it  is  not  acceptable  and  misleading  that  the  traceability  of 
products (milk, meat, eggs, wool etc) derived from animals fed with GM material is excluded 
from  the  scope  of  the  Regulation.  They  perceive  this  as  a  ‘loophole’  that  undermines  the 
credibility of the whole labelling system. It should be noted that the labelling and traceability 

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of  such  products  was  extensively  discussed  by  both  the  Council  and  European  Parliament 
during preparation of the Regulation but their inclusion was not adopted. 

The feed production and distribution chains 

The majority of GM products placed on the European market are destined for animal feed and 
originate  from  imported  commodities,  largely  soybean,  either  containing  or  produced  from 
GMOs. Millions of tonnes of soybean material are imported into the European Union every 
year, largely from the US, Argentina and Brazil. These countries grow a high proportion of 
GM soybean crops and shipments into the Community will, therefore, inevitably contain GM 
soybean material. 

Certain trading partners state that because soybeans exported within a given shipment for feed 
use are often thoroughly mixed by the US commodity-handling system (and may also contain 
soybeans  from  Canada),  it  is  not  feasible  to  transmit  the  information  required  by  the 
Regulation. This viewpoint is somewhat surprising given that the European feed industry and 
competent  authorities  have  reported  that  the  correct  information  (in  accordance  with  the 
Regulation) has been provided with imported shipments of soybean. Moreover, members of 
the  European  feed  industry  have  stated  that  the  requirements  of  the  Regulation  have  not 
altered  sales  of  animal  feed  although  many  consider  the  provisions  as  burdensome  and 
unnecessary. Interestingly, industry contacts have suggested that certain crushers of non-GM 
soybeans  have  had  some  difficulties  in  selling  the  resultant  material  as  operators  are  not 
prepared to pay the associated premium costs. 

At the current time, the Monsanto Round-up Ready soybean accounts for the majority of GM 
soybean grown in the Americas and indeed, world-wide. This variety is the only GM soybean 
product that has received Community approval (for import and use in food and feed). Meeting 
the traceability and labelling requirements for imports of bulk commodity soybean shipments 
does not appear to have created many problems given the predominance of a single variety. 
The  situation  may  change,  however,  as  further  GM  soybean  varieties  are  approved  in 
exporting countries. 

Labelling and traceability of GM seed products for cultivation 

Cultivation  of  GMOs  is  not  practised  in  the  vast  majority  of  Member  States  although  Bt-
maize is commercially grown (approximately 60 000 ha) in certain regions of Spain. This and 
other  GM  maize  varieties  are  also  grown  in  France,  Germany,  the  Czech  Republic  and 
Portugal  but  on  a  much  smaller  scale.  The  harvested  products  from  these  crops  are  largely 
used  for  animal  feed  ‘on  farm’  although  some  are  destined  for  processing  via  the  starch 
industry. Very few, if any, of these GM maize products are subsequently exported. 

Reports  suggest  that  marketing  of  ‘internally  produced’  GM  products  has  not  created 
problems given the continued experience of both farmers and subsequent operators (although 
it must be noted that the majority of products remain ‘on-farm’). Labelling of GM seed stocks 
appears to have been complied with although some problems have been reported concerning 
the ‘interpretation’ and calculation of adventitious traces of GMOs in conventional seed lots. 

The  experience  of  the  plant  biotechnology  industry  (technology  providers  and  integrators, 
including seed companies) has been somewhat limited to date as GM crop varieties have not 
been  widely  available  to  growers  in  the  EU  for  commercial  cultivation.  Nevertheless,  the 
industry  has  reported  that  no  serious  problems  have  been  encountered  concerning 

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interpretation of the Regulation and in countries where GM varieties are available (notably in 
Spain)  no  particular  difficulties  have  been  encountered  in  implementing  the  Regulation. 
Indeed, the requirements for documentation of transactions and the labelling of GM varieties 
appear to have been implemented as a standard business practice. These requirements have, 
however, apparently added to the administrative requirements and associated costs (although 
actual figures have not been provided). 

Enforcement of the Regulation  

Many national authorities, as for organisations from other sectors, have deemed that there has 
been  an  insufficient  period  of  time  in  which  to  gather  relevant  experience  and  information 
concerning  implementation  of  the  Regulation.  Nevertheless,  a  large  majority  of  Member 
States  consider  that  the  requirements  of  the  Regulation  have  had  a  positive  effect  on  the 
provision of relevant information, consumer choice as well as the necessary safety guarantees. 
The  necessity  of  these  requirements  has  been  highlighted  notably  by  Member  States  where 
organic production is viewed as important. Other Member States consider that the Regulation 
should  be  made  stricter  for  imported  goods  with  tighter  control  measures  to  ensure 
compliance. 

Certain  Member  States  have  reported  difficulties  with  sampling  and  testing,  pointing  to  the 
complexity  of  the  techniques,  particularly  where  detection  of  adventitious  presence  is 
required.  Recommendation  2004/787/EC  advises  that  “the  results  of  quantitative  analysis 
should be expressed as the percentage of GM DNA copy numbers in relation to target taxon 
specific  DNA  copy  numbers  calculated  in  terms  of  haploid  genomes”.  Nevertheless  some 
confusion still exists in terms of the units in which GM content should be expressed and some 
Member  States  have  referred  to  a  need  for  conversion  factors  allowing  for  a  harmonised 
approach irrespective of whether GM content is expressed according to DNA, weight or seed 
number.  Further  queries  of  this  nature  have  extended  to  the  introduction  of  ‘stacked-gene’ 
varieties of GM crops and clarification requested. 

The approach to inspection and control, followed by many Member States, appears to be one 
of random sampling and testing or where there is a suspicion that the labelling of a product 
may  not  be  correct.  Whilst  a  number  of  Member  States  have  found  the  Commission 
Recommendation on sampling and testing to be useful, others have reported that it is either 
too detailed or too vague. Certain Member States have also pointed to a need for legislation 
rather  than  guidance  to  ensure  a  harmonised  approach  to  sampling  and  testing.  Others  have 
requested  a  practical  ‘operating  manual’  as  a  means  to  ensure  harmonisation  and  uniform 
implementation of the Regulation. It has also been highlighted that individual Member States 
need to exchange more information and experience to ensure a harmonised approach. 

Reports  from  Member  States  suggest  that  the  relevant  information  required  under  the 
Regulation is certainly being made available by operators with transactions although in some 
cases,  it  appears  that  hard  copies  of  documentation  may  not  be  present.  In  addition,  a  few 
Member  States  have  reported  that  unique  identifiers  are  not  always  included  in  the 
documentation from exporters accompanying bulk shipments of products containing GMOs. 
Certain Member States have also pointed towards an initial reluctance of importers to provide 
the  relevant  documentation  to  subsequent  operators  but  state  that  this  situation  has 
dramatically improved as further experience has been gathered. 

One  Member  State  has  also  reported  a  situation  where  wholesalers  had  not  passed  on  the 
necessary  information  to  individuals  further  down  the  chain.  This  again  was  put  down  to  a 

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lack of experience and has since been rectified. Indeed, Member States appear fully aware of 
the necessity for the correct information at the start of the distribution chain if the system is to 
be  effective  throughout  the  entire  chain.  Some  Member  States  clearly  believe  that  a 
harmonised  format  for  documentation  would  assist  both  operators  and  national  authorities 
with  implementation  and  enforcement  and  avoid  such  problems.  Industry  members  and 
trading  partners,  on  the  otherhand,  do  not  believe  that  harmonised  documents  are  necessary 
and that the relevant information can be detailed satisfactorily on existing commercial invoice 
documentation. 

Conversely,  other  Member  States  have  reported  that  there  have  been  no  problems  in 
interpreting,  implementing  and  enforcing  the  Regulation.  These  Member  States  point  to  the 
fact that general labelling and traceability rules have been long-since implemented by the food 
and feed industries and considerable experience has already been gained with such rules. The 
Regulation is, therefore, viewed basically as an extension to these rules. Some confusion has, 
however, appeared to have arisen where the labelling of mixtures of GMOs is concerned. 

Further  issues  that  have  been  reported  include,  as  mentioned  by  other  sectors,  the  means  to 
reliably detect the presence of non-approved GMOs in bulk shipments and other products as 
well as the means to enforce labelling and traceability requirements where DNA and protein 
are absent in products. Moreover, there appear to have been some difficulties in linking such 
products  to  origin  when  attempting  to  determine  if  or  not  they  were  derived  from  GM 
material. 

Certain Member States have reported that they consider the costs of sampling and testing to 
be  excessive  and  have  requested  that  such  costs  be  reviewed.  In  addition,  other  national 
authorities  have  reported  that  the  correct  testing  of  bulk  shipments  requires  too  much  time, 
creating problems particularly where perishable goods are concerned. The lack of accessible 
reference material has also been raised by some authorities in terms of delays but reference to 
specific  products  was  not  provided.  It  should  be  noted  that  Regulation  (EC)  No  1829/2003 
requires  that  notifiers  must,  as  part  of  their  notifications  (including  those  for  existing 
products) include the place where reference material can be accessed. 

Conclusions 

The  majority  of  stakeholders  have  pointed  to  the  fact  that  the  Regulation  has  only  been 
operational for a limited period of time and that experience in terms of its implementation is 
extremely limited. This has been exacerbated by the limited number of GM products currently 
being  marketed  in  the  European  Union.  Consequently,  this  report  realistically  can  only  be 
viewed  as  preliminary  and  further  experience  and  reporting  will  be  required  to  gain  a  true 
picture of implementation of the Regulation. 

In  spite  of  the  above,  it  appears  that  the  provisions  of  the  Regulation  are  being  correctly 
applied. Whilst some early ‘teething’ problems have been reported, they appear to have been, 
in the main, largely resolved. 

Many stakeholders have pointed to a need to specifically address the adventitious presence of 
‘non-approved’ GM material, notably in terms of available detection methodology. It should, 
however,  be  made  clear  that  the  Regulation  covers  only  GM  products  that  have  received 
Community  authorisation  for  their  placing  on  the  market.  The  Commission,  via  its  Joint 
Research Centre (JRC), continues to address this issue and information pertaining to GMOs 

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approved  in  other  countries,  where  available,  will  be  placed  on  a  Community  register  in 
accordance with Article 9(3) of the Regulation. 

Whilst certain stakeholders, have highlighted that the sampling and detection guidelines in the 
Commission  Recommendation  are  useful,  others  consider  that  they  are  complicated  and 
difficult to apply. The bottom line is that sampling and detection are complex issues and only 
a  limited  number  of  methodologies  were  available  prior  to  on  the  entry  into  force  of  this 
Regulation. The JRC and the European Network of GMO Laboratories (ENGL) subsequently 
developed  a  methodology  for  sampling  bulk  shipments  of  grain  and  this  has  since  been 
accepted  as  an  international  standard.  The  JRC  and  ENGL  continue  to  validate  specific 
detection methods for individual GMOs but this work is time-consuming (and costly) given 
the precision and accuracy required for validation. It is, however, clear that continued efforts 
in this area must and will have to continue. 

Certain  trading  partners  continue  to  allege  that  the  Regulation  introduces  an  excessive 
administrative burden. Imports of soybean and maize, including their derived products such as 
soy-meal  or  corn  gluten  feed  do  not  appear  to  have  been  affected  by  the  Regulation.  In 
practice,  consumer  and  market  demand  for  foodstuffs  in  particular  has  certainly  had  a  far 
greater effect than the provisions  of the  Regulation  in  terms of trade in products containing 
GM  material.  The  asynchronous  approval  regime  for  GMOs  between  countries  remains  the 
major obstacle to trade. Whilst some trading partners have been able to successfully manage 
this issue to avoid trade disruption, others seem either unable or unwilling to address it.  

However,  it  remains  clear  that  only  a  limited  amount  of  information  and  experience 
concerning the implementation of the Regulation is available at the current time. Therefore, 
the  Commission  will  draw  up  a  second  report,  following  a  further  period  of  24  months  to 
enable a more complete picture of implementation to be obtained. 

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ANNEX 1 

Department for Environment, Food and Rural Affairs, United Kingdom 

State Veterinary and Food Administration of the Slovak Republic 

Central Control and Testing Institute for Agriculture (Slovak Republic) 

Ministry of Agriculture, Forestry and Food (Slovenia) 

Ministry of Health (Slovenia) 

Ministry for the Environment and Spatial Planning (Slovenia) 

National Food Administration (Sweden) 

Swedish Board of Agriculture  

Swedish Work Environment Authority 

Directorate-General for Veterinary Services (Portugal) 

Directorate-General for Crop Protection (Portugal) 

DGFCQA - Directorate-General of Food Quality Inspection and Control (Portugal) 

Ministry of Health, Welfare and Sport (Netherlands) 

Ministry of Agriculture, Nature and Food Quality (Netherlands) 

Ministry of Housing, Spatial Planning and the Environment (Netherlands) 

Malta Environment and Planning Authority 

Malta Standards Authority 

Ministry of the Environment (Lithuania) 

Ministry of Agriculture and Rural Development (Hungary) 

Ministry  of  Rural  Development  &  Food-  Directorate  of  Processing,  Standardization  and 
Quality Inspection (Greece) 

Ministry of Development, Hellenic Food Safety Authority (Greece) 

Ministry  of  Economy  and  Finance,  General  Chemical  State  Laboratory,  Food  Division 
(Greece) 

Board for Gene Technology (Finland) 

Ministry of Trade and Industry (Finland) 

National Food Agency (Finland) 

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Customs Laboratory (Finland) 

Plant Production Inspection Centre (Finland) 

National Product Control Agency for Welfare and Health (Finland) 

Sub-directorate-General for the Means of Livestock Production (Spain) 

Ministry of Health and Consumer Affairs: Spanish Agency for Food Safety (Spain) 

Ministry of Agriculture, Fisheries and Food (Spain) 

Veterinary and Food Board (Estonia) 

Danish Veterinary and Food Administration  

Danish Plant Directorate 

German Federation for Food Law and Science 

Ministry of the Environment (Czech Republic) 

Ministry of Agriculture (Czech Republic) 

Central Institute for Supervising and Testing in Agriculture (Czech Republic) 

Reference laboratory for GMO identification and DNA fingerprinting (Czech Republic) 

Research Institute of Crop Production (Czech Republic) 

Ministry of Health (Cyprus) 

Department of Agriculture (Cyprus) 

Federation of European Food Additives and Food Enzymes (Belgium) 

FPS Public Health, Food Chain Safety and Environment (Belgium) 

FAVV/AFSCA (Belgium) 

Greenpeace 

FEDIS – La Fédération belge des entreprises de distribution 

FEDIMA (Federation of the European Union Manufacturers and Suppliers of Ingredients to 
the Bakery, Confectionery and Patisserie Industries) 

European Association for Bio-industries (EuropaBio) 

ELC – Federation of European Food Additives and Food Enzymes Manufacturers 

CIAA - The Confederation of Food and Drink Industries of the European Union 

BEUC - The European Consumers’ Organisation 

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The National Association for the Speciality Food Trade, Inc., New York, USA 

Nestlé 

US Government 

American Soybean Association 

Florigene (Australia) 

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