Background
Euroseeds is a trade association representing nearly 70 European companies that breed, produce, research, and market the seeds of โagricultural, horticultural and ornamental plant species,โ as well as more than 30 national member associations from European Union member and non-member states.1โWho we are,โ Euroseeds. Archived July 4, 2022. Archive URL: https://archive.ph/9BpUW
Euroseeds describes its goals as:2โWho we are,โ Euroseeds. Archived July 4, 2022. Archive URL: https://archive.ph/9BpUW
- โfair and proportionate regulation of the European seed sector;
- โfreedom of choice for customers (farmers, growers, industry, consumers) in supplying seeds as a result of innovative, diverse technologies and production methods;
- โeffective protection of intellectual property rights relating to plants and seeds.โ
Euroseeds says that it โrepresents the European seed industryโ to EU ministers and institutions including the European Commission, the European Parliament, the Council of Ministers, and the Community Plant Variety Office.3โRepresenting the Seed Sectorโ (PDF), Euroseeds, July 1, 2019. Archived July 25, 2022. Archived .pdf on file at DeSmog.
Euroseeds members comprise 67 seed industry companies, and 36 national trade associations.4โWho we are,โ Euroseeds. Archived June 22, 2022. Archive URL: https://archive.ph/U6nK4 It represents national seed trade associations, plant breedersโ societies, and plant variety societies from 27 European countries.5โAssociation members,โ Euroseeds. Archived July 11, 2022. Archive URL: http://archive.today/7jrfx It also represents individual plant breeding companies, seed specialist businesses, and international agrochemical companies, mainly from France, the Netherlands, Britain and Germany.6“Individual members,โ Euroseeds. Archived July 4, 2022. Archive URL: https://archive.ph/3CKZT
Associate members of Euroseeds include the agrochemical giants Bayer, Syngenta, Corteva, UPL, and BASF.7โAssociate members,โ Euroseeds. Archived June 22, 2022. Archive URL: https://archive.ph/MgHpc
Bayer, BASF, and Syngenta are represented on the Euroseeds board.8โIndividual Members,โ Euroseeds. Archived July 4. 2022. Archive URL: https://archive.ph/3CKZT
Euroseeds was established in 2000 by the merger of four European seed associations: COSEMCO, a seed industry trade association; ASSOPOMAC, a potato breeders association; AMUFOC, a trade group for forage seed producers; and COMASSO, a plant breeders association.
Euroseeds has funded at least one impact assessment of the EUโs Farm to Fork Strategy, a component of the European Green Deal that aims to transform the EUโs food system and reduce the use of pesticides and fertilizers in agriculture.
The study, carried out by HFFA Research, concluded that “without accelerating plant breeding in the EU in the future, the objectives of the โFarm to Forkโ and โBiodiversityโ strategies and, hence, the European Green Deal can hardly be achieved.”9Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
Euroseeds routinely advocates for increased support for and investment in โgenetic crop improvementโ technologies and gene-editing, and argues that the techniques and technologies it advocates for will help the EU meet its climate targets.10โSeed Sector Brochure,โ Euroseeds, 2020. Archived July 4, 2022. Archived .pdf on file at DeSmog.
Stance on Climate Change
In its 2020 โSeed Sectorโ brochure, Euroseeds wrote that โEuropeโs seed sector is determined to help achieve the European Unionโs policy objectives of a secure supply of sustainable, healthy, nutritious and high-quality food, and of a greener, circular competitive and climate-neutral economy by 2050.โ11โSeed Sector Brochure,โ Euroseeds, 2020. Archived July 4, 2022. Archived .pdf on file at DeSmog.
Regarding the challenges of sustainability and climate change mitigation, Euroseeds wrote that innovation in plant breeding and seed production were โplaying a major roleโ in helping farmers respond to climate change. Euroseeds also listed one of its aspirations as โmaintaining and creating new biodiversity by using existing plant genetic resources to develop new ones.โ12โSeed Sector Brochure,โ Euroseeds, 2020. Archived July 4, 2022. Archived .pdf on file at DeSmog.
Referring to a self-funded study, Euroseeds states on its website that โrecent scientific studies have proven that plant-breeding innovation already strongly contributes to the economic, social and environmental sustainability of farming, food production and the entire economy.โ13โSustainability and climate change,โ Euroseeds. Archived June 22, 2022. Archive URL: https://archive.ph/6vo6Y
On Twitter, Euroseeds has suggested that genome editing is an โimportant toolโ and โkey solutionโ for responding to climate change, producing food for the worldโs growing population, and conserving biodiversity.14Euroseeds. โWithin 100 years, it is estimated that the # of people needing to be fed will more than triple.โ Tweet by @EuroseedsEU, September 21, 2021. Retrieved from Twitter.com. Archived November 4, 2022. Archive URL: https://archive.ph/zyc5C 15Euroseeds. โ#Agriculture faces the challenges of #foodsecurity, #sustainability & #climatechange.โ Tweet by @EuroseedsEU, January 28, 2022. Retrieved from Twitter.com. Archived November 4, 2022. Archive URL: https://archive.ph/2eWCj
Stance on Farm to Fork Strategy
Euroseeds has been critical of the EUโs Farm to Fork Strategy.
Euroseeds has made a number of posts on Facebook warning that the โfull implementationโ of the Farm to Fork and Biodiversity strategies might decrease food security,16โ#DYK that the full implementation of the #EUFarm2Fork and #EUBiodiversity might decrease #foodsecurity? #Plantbreeding progress is potentially able to compensate in the long run!โน๏ธ https://euroseeds.eu/โฆ/plant-breeding-is-a-game-changer-foโฆ/#GrowingTheFuture #COP15,โ Facebook post by Euroseeds, December 16, 2022. Archived December 16, 2022. Archived .png on file at DeSmog. will โrequire dedicated extra hectares of land to produce food,โ17โAccording to HFFA Research study, EU #plantbreeding in the next 20 years will help avoid an additional #GHG emissions of more than 3.6B tons until 2040. โน๏ธ https://euroseeds.eu/…/plant-breeding-is-a-game…/ #EUFarm2Fork #EUBiodiversity,โ video uploaded to Facebook by Euroseeds, January 4, 2022. Archived December 16, 2022. Archived .mp4 on file at DeSmog. and will โsignificantly reduce the crop market supplyโ by 2030.18โEven 2 decades of #plantbreeding progress at current pace will not compensate for market supply losses if #EUFarm2Fork and #EUBiodiversity strategies are fully implemented. With access to all the innovative tools, plant breeding can help!โน๏ธ https://euroseeds.eu/…/plant-breeding-is-a-game…/ #GrowingTheFuture #COP15,โ video uploaded to Facebook by Euroseeds, December 16, 2022. Archived December 16, 2022. Archived .mp4 on file at DeSmog.
In October 2021, Euroseeds signed a joint declaration alongside CropLife Europe, COPA-COGECA, the Agri-Food Chain Coalition, Fertilizers Europe, and other agribusiness industry trade groups that warned the โnon-data based political targetsโ to reduce fertilizer and pesticide use as part of the Farm to Fork Strategy would โhave deleterious effects on European agriculture.โ19โFarm to Fork โ it is time to listen to what the data says,โ CropLife Europe, October 12, 2021. Archived July 19, 2022. Archive URL: https://archive.vn/4R4P3
In November 2022, Euroseeds signed a letter addressed to Wolfgang Burtscher, Director-General for Agriculture and Rural Development in the European Commission, regarding the Sustainable Use of Pesticides Regulation (SUR). SUR is a key element of EU F2F and would see the strategyโs pesticide reduction targets enacted in law.20โRe: Joint open letter from agri-food chain organisations regarding the potential impact of the current proposal on Sustainable Use of Plant Protection Products Regulation (โSURโ) on the EU agricultural value chain, considering the current socioeconomic situation in Europe,โ Europatat, November 17, 2022. Archived December 14, 2022. Archive URL: https://archive.ph/UqwMDย
The letter argued that โpolicy measures need to take into consideration the consequences and downsides of PPPs [plant protection products] reduction targets for all actors in the food chain, especially in light of the aftermath of COVID-19, the Russian invasion of Ukraine, and the effects of climate change.โ It also argued for โa comprehensive impact assessment,โ โadequate targets that are based on science and feasible for producers,โ and providing โalternatives [to widely-used pesticides] before withdrawing chemical solutions.โ
According to Corporate Europe Observatory, such impact assessments โtend to favour economic factors over social and environmental ones,โ adding that these reports are โonly delaying progress towards tackling the climate emergency.โ21Vicky Cann. โExploiting the Ukraine crisis for Big Business,โ Corporate Europe Observatory, July 28, 2022. Archived October 25, 2022. Archive URL: https://archive.ph/dSLE8
In December 2022, Member States demanded a reassessment of SUR, in line with industry calls.22Clare Carlile and Hazel Healy. โFlagship EU Green Farming Reforms in Peril as Lobbyists Exploit Ukraine War,โ DeSmog, December 9, 2022.
Research Funded by Euroseeds
In May 2021, the consultancy HFFA Research published a study initiated and financed by Euroseeds. The study predicted major food production losses resulting from the EU Farm to Fork and the Biodiversity strategies and examined plant breedingโs ability to โcompensateโ for a projected fall in yields.23Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
The study concluded that over the next 10 years, genetic crop improvements could have โthe potential to counteractโ half of possible production and market supply losses resulting from the strategies, as well as their โnegative consequences on use of global natural resources,โ such as water, land, and the climate.
The studyโs recommendations included:
- โSpeeding up processes aiming at genetic crop improvementsโ
- Using โall available technologies,โ including plant breeding technologies, to speed up processes aiming to genetically improve crops
- Ensuring that policy and regulatory frameworks โencourage and not hinder theโฆnecessary investments into future plant breedingโ
- Government policies and funding that support โpublic awareness raisingโ about โmultiple benefits of plant breeding in agricultureโ and to โencourage plant breeders to further (and even more) invest into the development of new and better seed varietiesโ
The study concluded that “without accelerating plant breeding in the EU in the future, the objectives of the โFarm to Forkโ and โBiodiversityโ strategies and, hence, the European Green Deal can hardly be achieved.”24Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
The studyโs authors claimed that their work was never โinfluenced by the initiator and supporters of the study.โ However, they also stated that a โproject steering groupโ from Euroseeds, as well as Euroseeds โpartner organizations,โ provided โcontinuous and valuable feedback throughout the research phaseโ of the project.25Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
Euroseeds held a launch event for the study, titled โHow innovation in plant breeding boosts sustainable farming in the EU.โ Public relations firm Hume Brophy invited the Head of Cabinet for Janusz Wojciechowski, Europeโs Commissioner for Agriculture, to the event.26Hume Brophy. โInvitation โ Euroseeds online event 17 May 2021,โ Provided by the European Commission, Accessed via AsktheEU, May 4, 2021. Archived November 21, 2022. Archived .pdf on file at DeSmog.
Euroseeds promoted the study on its website and on social media.27โPlant breeding is a game changer for sustainable agriculture, new study shows,โ Euroseeds, May 17, 2021. Archived July 26, 2022. Archive URL: https://archive.vn/sTTJM
The organization posted a video on Facebook captioned, โAccording to HFFA Research study, EU #plantbreeding in the next 20 years will help avoid an additional #GHG emissions of more than 3.6B tons until 2040.โ The video stated: โThe EU Farm to Fork and Biodiversity strategies will require dedicating extra hectares of land to produce food. This results in extra greenhouse gas emissions of 3.6 billion tons until 2040.โ28โAccording to HFFA Research study, EU #plantbreeding in the next 20 years will help avoid an additional #GHG emissions of more than 3.6B tons until 2040. โน๏ธ https://euroseeds.eu/…/plant-breeding-is-a-game…/ #EUFarm2Fork #EUBiodiversity,โ video uploaded to Facebook by Euroseeds, January 4, 2022. Archived December 16, 2022. Archived .mp4 on file at DeSmog.
However, the HFFA study highlighted the speculative nature of some of its findings. According to its authors, study described only one of “many possible future outcomes of implementing the two strategies,โ and stated: โThis should especially be kept in mind when discussing and interpreting the subsequent results.โ29Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
Campaign group Corporate Europe Observatory (CEO) has stated that the HFFA study โreplicates the GM [genetic modification] lobby regulatory wish-listโ and could be used to justify weakening GMO policies in the Farm to Fork Strategy.30โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork.,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
One month before the Euroseeds-funded study was published, the European Commission published a report recommending that EU legislation on genetically modified organisms should be updated to allow the use of targeted gene editing in crops.31โEC study on new genomic techniques,โ European Commission, April 29, 2021. Archived November 28, 2022. Archive URL: https://archive.vn/3NzFf Pรคivi Mannerkorpi, head of the unit for plant health at the European Commission, said that the study strengthened the case for allowing gene editing, saying: โWe believe that we should use all the available tools.โ32Florin Zubaศcu. โBiotech lobbies gear up for gene editing regulation battle,โ Science Business, May 18, 2021. Archived June 21, 2021. Archive URL: https://archive.ph/UsPgq
Other Industry-Funded F2F โImpact Assessmentsโ
The Euroseeds-funded HFFA study was one of five โimpact assessmentsโ of Farm to Fork funded by industry groups. Among them, CropLife Europe commissioned an impact assessment of the possible outcomes of the F2F strategy from Wageningen University and Research (WUR). Euroseeds and other agribusiness lobby groups such as COPA-COGECA and Fertilizers Europe also funded this study.33โFarm to Fork: What the analysis and data tell us,โ EURACTIV YouTube, October 12, 2021. Archived July 26, 2022. Archive URL: https://archive.ph/TR15L 34โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
WUR published a summary of its findings in October 2021, a week before the European Parliament voted on the Farm to Fork Strategy, and released the entirety of its study in January 2022, according to Corporate Europe Observatory.35โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
Euroseeds promoted the study in a January 2022 press release, claiming that it โhighlights that innovation is crucial to help reduce the negative impacts of the Farm to Fork and Biodiversity strategies.โ The statement did not mention that CropLife Europe โ the pesticide trade association, and a vested industry interest โ had funded and โguidedโ the WUR report.36โWageningen University and Research study highlights that innovation is crucial to help reduce the negative impacts of the Farm to Fork and Biodiversity strategies,โ Euroseeds, January 20, 2022. Archived July 26, 2022. Archive URL: https://archive.ph/DTXVL
The WUR impact assessment predicted an average 10-20 percent drop in agricultural production, based on modeling of the EUโs targets for reducing land and agrichemical use. Its key recommendation was โremoving legislative barriers to new [crop] breeding techniques,โ including gene-editing.37Johan Bremmer, Ana Gonzalez-Martinez, Roel Jongeneel, Hilfred Huiting, Rob Stokkers, Marc Ruijs. โImpact Assessment of EC 2030 Green Deal Targets for Sustainable Crop Production,โ Wageningen University and Research, December 2021. Archived December 14, 2022. Archived .pdf on file at DeSmog.
The WUR assessmentโs methodology and findings have been criticized by other scientists, and one author of the report has also highlighted its limitations. The study did not include any simultaneous changes in the food system in its analyses,38โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork.,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3 such as changing diets, or shifts in the rest of the world food system that would improve the implementation of the Farm to Fork strategy.39Magdalena Pistorius, โFarm to Fork studies do not give โwhole pictureโ, agri stakeholders warn,โ Euractiv, October 29, 2021. Archived December 14, 2022. Archive URL: https://archive.ph/ibXPF 40โFactsheet: Green Deal targets for 2030 and agricultural production studiesโ, European Commission, February 2022. Archived August 4, 2022. Archived .pdf on file at DeSmog.
In a statement about several of the industry-funded F2F impact assessments, the European Commission stated:41โGreen Deal 2030 targets and agricultural production studies,โ News Article, Directorate-General for Agriculture and Rural Development, European Commission, October 18, 2021. Archived July 22, 2022. Archive URL: http://archive.today/9MJmE
โThe studies provide both the scientific community and policy makers with a valuable insight on the choice of policy tools to mitigate the risks. However, the models used in the studies all have their limitations. They are not able to assess the full impacts of the two strategies and predict the future. For instance, the future consumer behavioural changes, the impact of research and innovation or technological uptake in the agricultural sector have not, or partially, been taken into account.โ
Stance on Gene Editing and Genetic Modification
Euroseeds has suggested that developing and implementing new gene editing and other genetic techniques will be necessary to address climate change.
In October 2021, Euroseeds held a joint event with the American Seed Trade Association, with panelists speaking on โHow can innovation and new technologies in agriculture, such as Plant Breeding Innovation, contribute to a more sustainable food system?โ42โCharting transatlantic cooperation for a sustainable food system,โ Euroseeds, October 13, 2021. Archived November 21, 2022. Archive URL: https://archive.ph/BSLvr Speakers included John Clarke, Director of International Affairs at the European Commissionโs Directorate-General for Agriculture and Rural Development (DG-AGRI), alongside an MEP and representatives from the U.S. Department of Agriculture.43Hume Brophy. โRE: Invitation as a guest speaker: Transatlantic dialogue on agricultural innovation for a sustainable food system,โ Provided by European Commission, Accessed via AsktheEU, October 8, 2021. Archived November 21, 2022. Archived .pdf on file at DeSmog.
In January 2022, Euroseeds contributed to a joint statement published by the Agri-Food Chain Coalition regarding the EU Farm to Fork Strategy, stating: โWe need a regulatory environment that encourages plant breeding and delivers on both purposes: quality assurance for customers (the reproductive material meets their demands regardless of the production system, conventional/organic) and speeding up the development of new varieties (for which New Genomic Techniques are a crucial element).โ44โFarm to Fork Strategy: how to reach the targets?,โ Agri-Food Coalition, January 27, 2022. Archived on July 25, 2022. Archive URL: https://archive.ph/5PRDt
In June 2022, Euroseeds met with members of the European Commission’s Directorate-General for Health and Food Safety (DG-SANTE), and emphasized that Commission proposals to deregulate gene editing should be adopted with โurgency.โ Euroseeds argued that while โsome varieties might be rejected after testing,โ the โmarketing of PRM [plant reproductive materials] could be permitted while testing is still ongoing.โ45Email from DG Sante. โBTO: meeting CAB with Euroseeds of 16 June,โ Provided by European Commission, Accessed via Ask the EU. Archived November 16, 2022. Archived .pdf on file at DeSmog.
What Is Gene Editing?
Gene editing in agriculture is the process of adding, enhancing, or removing specific traits from the DNA of an organism, in order to make it more resistant to pests, diseases, weather, and other problems that can lower crop yields. Gene editing and other โplant breeding technologiesโ are considered forms of genetic modification under current EU law.46Kai Purnhagen and Justus Wesseler. โEU Regulation of New Plant Breeding Technologies and Their Possible Economic Implications for the EU and Beyond,โ Applied Economic Perspectives and Policy, September 28, 2020. Archived July 26, 2022. Archive URL: https://archive.ph/8szpW
Some studies conclude that there is still not enough data in order to assess the long term safety of such new crops, nor their environmental impact.47Aristidis M. Tsatsakis, Muhammad Amjad Nawaz, Demetrios Kouretas, Georgios Balias, Kai Savolainen, Victor A. Tutelyan, Kirill S. Golokhvast, Jeong Dong Lee, Seung Hwan Yang, Gyuhwa Chung. โEnvironmental impacts of genetically modified plants: A review,โ Environmental Research, 2017. https://doi.org/10.1016/j.envres.2017.03.011
Scientists, NGOs and industry members have widely debated whether gene editing should be considered a form of genetic modification. Proponents of gene editing say that it differs from genetic modification because it does not introduce DNA from other species โand creates new varieties similar to those that could be produced more slowly by natural breeding processes.โ48โPress release: Plans to unlock power of gene editing unveiled,โ Gov.uk, September 29, 2021. Archived July 26, 2022. Archive URL: https://archive.ph/RnjAL
Greenpeace has expressed concerns about the unknown effects of these technologies, such as unintended outcomes created by gene editing errors, or the control of gene-editing techniques by few corporations.49โDanger Ahead: Why gene editing is not the answer to the EUโs environmental challenges,โ Greenpeace, March 2021. Archived July 26, 2022. Archived .pdf on file at DeSmog.
Lobbying Against Regulation of New Genomic Techniques
Euroseeds has argued that new genomic breeding techniques โshould not be subject to [European] GMO legislation.โ50Tarja Laaninen. โNew plant-breeding techniques: Applicability of EU GMO rules,โ European Parliament Memberโs Research Service, October 2019, Archived August 24, 2022. Archive URL: https://archive.vn/fmcy8
EU Update of GMO Rules
In 2019, the EU began revising its rules on plant and forest reproductive material, which includes seeds, young plants, tubers, and plant cuttings. The updateโs goals included aligning legislation with the European Green Dealโs Farm to Fork, biodiversity, and other strategies.51โPlant and forest reproductive material (revised rules).,โ European Commission, June 15, 2021. Archived July 26, 2022. Archive PDF: https://archive.ph/meWLS
In April 2021, the European Commission published a study on the status of new genomic techniques in EU law, stating that the current EU GMO directive is โnot fit for purpose for some new genomic techniques and their products, and that it needs to be adapted to scientific and technological progress.โ
In response to the study, Euroseeds Secretary General Garlich von Essen signed a joint letter with other industry associations including the European Chemical Industry Council, CEMA, and CropLife Europe. The letter welcomed the findings of the study, and called on EU ministers of agriculture to act on them in the context of both climate change challenges and the European Green Deal. The letter stated:52โInter-association letter to the EU Ministers of Agriculture and DG SANTE โ Europabio,โ Europabio, May 21, 2021. Archived October 31, 2022. Archive URL: https://archive.vn/hdZXe
โThe NGT study now confirms that โseveral of the plant products obtained from NGTsโ can contribute to various goals of the European Green Deal by saving land resources, allowing a more sustainable use of crop protection products, antibiotics and emissions while stabilizing and increasing crop yields and improving animal health and welfare to ensure food security.โ
In September 2021, over 50 organizations โ including Corporate Europe Observatory, European Coordination Via Campesina, and Friends of the Earth โ published a critical response to the EU study. They charged that the commission had โuncriticallyโ followed โthe GMO industryโs โwish listโ for deregulation,โ and ignored โa large body of scientific evidence and analysis pointing to the risks of new GM techniques.โ
According to the NGOs:53Slow Food Europe. โBiased from the outset: The EU Commissionโs โworking documentโ on new GM techniques fails to uphold environmental and consumer protection Standards,โ Slow Food, September 2021. Archived June 28, 2022. Archive URL: https://archive.vn/c6Dg1
โGMO developers and associated lobby groups (such as ALLEA, EU-SAGE, EuropaBio, EPSO, Euroseeds, Plants for the Future European Technology Platform (ETP), and the โbig farmersโโ lobby organisation COPA[)] claim that there should be โnondiscriminationโ between conventional and gene-edited products because the mutations induced by gene editing could also arise in nature or during conventional breeding programmes, so gene-edited products are no riskier than natural or conventionally bred products. The Commission’s document comes to a strikingly similar conclusion.
โBut this argument is false and misleading. New GM techniques may induce a single base change that could also occur in nature โ but they can also induce changes that do not occur in nature. Gene-editing applications can target several genes at once, or be used in repeated applications, resulting in changes that would be extremely difficult or impossible to achieve using chemical- or radiation-based mutagenesis or in nature. However, risk is not dependent on the size of the intended change โ large risks can result from small changes, and vice versa.โ
In its July 2021 submission to the public consultation on the revised EU rules, Euroseeds cited the HFFA Research study that the association itself had funded, stating:54Euroseeds. โFeedback from: EUROSEEDS on Plant and forest reproductive material (revised rules),โ European Commission, July 13, 2021. Archived July 26, 2022. Archive PDF: https://archive.ph/Q3OLB
โThe study reconfirms that plant breeding has been and continues to be the key driver of competitiveness and resource efficiency, boosting both the socio-economic and the environmental sustainability of EU agri-food production, and with that fully supporting the two EU strategiesโ objectivesโฆEuroseeds strongly supports continuous further improvement of the legal framework to take account of latest technological and other developments, to speed up processes, drive quality and reduce cost for operators as well as administrations.โ
EU Legislation on Seed Treatment Technologies
Euroseeds has also lobbied specifically on seed treatment technologies in EU legislation. Euroseeds writes that seed treatment involves applying โplant protection products [pesticides, fungicides, and/or herbicides] directly to the seed itselfโ prior to sowing in order to โprotect the seed during germination and protect the plant itself during growth.โ Euroseeds claims that seed treatment is โmore environmentally friendly than spraying crops in the field.โ55โSeed Treatment And Technologies,โ Euroseeds. Archived October 4, 2022. Archive URL: https://archive.vn/2lwCD
In 2020, Euroseeds co-hosted a workshop with the Seed Treatment Industry Stewardship Steering Committee (STISSC) that โfocused on the challenges the seed and crop protection industry is facing on the authorization and access of plant protection products for the treatment of seeds that are intended to be used within and outside the European Union (EU).โ56โWorkshop Seed Treatment evaluation under Regulation (EC) 1107/ 2009,โ Euroseeds and Seed Treatment Industry Stewardship Steering Committee, November 19, 2020. Archived December 14, 2022. Archived .pdf on file at DeSmog.
The workshop was held in response to โthe finalization of the guidance document for the authorisation of plant protection products for seed treatments.โ Representatives of the national authorities of Austria, Denmark, Germany, Hungary, Ireland, Latvia, Lithuania, the Netherlands, Poland, Spain, and the European Commission attended the workshop.57โWorkshop Seed Treatment evaluation under Regulation (EC) 1107/ 2009,โ Euroseeds and Seed Treatment Industry Stewardship Steering Committee, November 19, 2020. Archived December 14, 2022. Archived .pdf on file at DeSmog.
Euroseeds has also suggested that seed treatments have a role in meeting EU pesticides targets. In a 2022 response to the EU Regulation on the Sustainable Use of Pesticides (SUR), Euroseeds suggested that seed treatment technologies could help reach the legislationโs goal: โSeed treatment technologies are fully compatible to the integrated pest management (IPM) principles, while contributing to delivering resilient and healthy plants for the benefit of society.โ58โEuroseeds position on the Regulation on the Sustainable Use of Pesticide,โ Euroseeds, June 23, 2022. Archived July 4, 2022. Archive URL: https://archive.ph/C3tUn
Scientists and NGOs say that seed treatments can cause harm to biodiversity, by risking mortality of sensitive bird species and affecting wild bee populations, much like conventionally applied pesticides.59Paul de Zylva. โThe problem with pesticides: Effects on wild species, food production and our environment,โ Friends of the Earth Insight Unit, December 2019. Archived December 14, 2022. Archived .pdf on file at DeSmog. 60Rundlรถf, M., Andersson, G., Bommarco, R. et al., โSeed coating with a neonicotinoid insecticide negatively affects wild beesโ, Nature, March 26, 2015. Archived December 14, 2022. Archive URL: https://archive.ph/sxhxj
Funding
Euroseeds received EU grants worth 101,200 euros in 2020, according to its entry in the EU Transparency Register.61โEuroseeds,โ EU Transparency Register. Archived June 22, 2022. Archive URL: https://archive.ph/gslM7
The organization also lists several EU-funded projects on its website. These include โInvite,โ which aims to โexplore opportunities that may improve the current variety testing system (DUS, VCU and performance), e.g. by use of advanced technologies and to look at how the sustainability profile of varieties could be better reflected.โ Euroseeds was a consortium member of this project.62โINVITE: INnovations in plant VarIety Testing in Europe,โ Euroseeds. Archived December 14, 2022. Archive URL: https://archive.ph/RP7pd
The majority of Euroseedsโ funding may come from its members, though this information is not currently available on its website.
Lobbying
According to its entry in the EU Transparency Register, Euroseeds spent between 1,500,000 euros and 1,749,999 euros on EU lobbying in 2020, the last year for which information is available.63โEuroseeds,โ EU Transparency Register. Archived June 22, 2022. Archive URL: https://archive.ph/gslM7
Between 2013 and 2020, the group spent between 6,250,000 euros and 7,249,994 euros on EU lobbying, according to official data gathered by LobbyFacts.64โEuroseeds,โ LobbyFacts. Archived June 22, 2022. Archive URL: https://archive.ph/Djf5e
The organization has held seven meetings with representatives of the European Commission since 2016. These include:65โList of meetings “Euroseeds” has held with Commissioners, Members of their Cabinet or Director-Generals since 01/12/2014 under its current ID number in the Transparency Register: “11362308587-10” (PDF),โ European Transparency Register, July 26, 2022. Archived July 26, 2022. Archived .pdf on file at DeSmog.
- In June 2022, Euroseeds met with Stella Kyriakides, the European Commissioner for Health and Food Safety on Plant reproductive material and New Genomic Techniques (NGTs).
- In December 2021, Euroseeds met with Valdis Dombrovskis, chair of the Commissionersโ โGroup on an Economy that Works for Peopleโ, to talk about the transatlantic seed trade in the context of the Trade & Technology Council. A U.S. lobby group, The American Seed Trade Association, also attended the meeting.
In the Transparency Register, Euroseeds lists its policy and legislation targets as: โAll EU initiatives, policies and legislative files touching upon plant breeding (including access to genetic resources, research and development), seed production, seed trade and seed marketing.โ66โEuroseeds,โ EU Transparency Register, July 6, 2022. Archived July 26, 2022. Archive URL: https://archive.ph/Ku9mU
Euroseeds has submitted comments to a number of EU public consultations and roadmaps, including legislation regulating plants produced by certain new genomic techniques, and revision of EU rules for sustainable use of pesticides.
Affiliations
Euroseeds is a member of the Agri-Food Chain Coalition, an association of twelve of the largest industry bodies that lobby on behalf of the EU agriculture industry.67โMembers,โ Agri-Food Chain Coalition. Archived June 22, 2022. Archive URL: https://archive.ph/9RvTP
Resources
- 1
- 2
- 3โRepresenting the Seed Sectorโ (PDF), Euroseeds, July 1, 2019. Archived July 25, 2022. Archived .pdf on file at DeSmog.
- 4โWho we are,โ Euroseeds. Archived June 22, 2022. Archive URL: https://archive.ph/U6nK4
- 5โAssociation members,โ Euroseeds. Archived July 11, 2022. Archive URL: http://archive.today/7jrfx
- 6“Individual members,โ Euroseeds. Archived July 4, 2022. Archive URL: https://archive.ph/3CKZT
- 7โAssociate members,โ Euroseeds. Archived June 22, 2022. Archive URL: https://archive.ph/MgHpc
- 8
- 9Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
- 10โSeed Sector Brochure,โ Euroseeds, 2020. Archived July 4, 2022. Archived .pdf on file at DeSmog.
- 11โSeed Sector Brochure,โ Euroseeds, 2020. Archived July 4, 2022. Archived .pdf on file at DeSmog.
- 12โSeed Sector Brochure,โ Euroseeds, 2020. Archived July 4, 2022. Archived .pdf on file at DeSmog.
- 13โSustainability and climate change,โ Euroseeds. Archived June 22, 2022. Archive URL: https://archive.ph/6vo6Y
- 14Euroseeds. โWithin 100 years, it is estimated that the # of people needing to be fed will more than triple.โ Tweet by @EuroseedsEU, September 21, 2021. Retrieved from Twitter.com. Archived November 4, 2022. Archive URL: https://archive.ph/zyc5C
- 15Euroseeds. โ#Agriculture faces the challenges of #foodsecurity, #sustainability & #climatechange.โ Tweet by @EuroseedsEU, January 28, 2022. Retrieved from Twitter.com. Archived November 4, 2022. Archive URL: https://archive.ph/2eWCj
- 16โ#DYK that the full implementation of the #EUFarm2Fork and #EUBiodiversity might decrease #foodsecurity? #Plantbreeding progress is potentially able to compensate in the long run!โน๏ธ https://euroseeds.eu/โฆ/plant-breeding-is-a-game-changer-foโฆ/#GrowingTheFuture #COP15,โ Facebook post by Euroseeds, December 16, 2022. Archived December 16, 2022. Archived .png on file at DeSmog.
- 17โAccording to HFFA Research study, EU #plantbreeding in the next 20 years will help avoid an additional #GHG emissions of more than 3.6B tons until 2040. โน๏ธ https://euroseeds.eu/…/plant-breeding-is-a-game…/ #EUFarm2Fork #EUBiodiversity,โ video uploaded to Facebook by Euroseeds, January 4, 2022. Archived December 16, 2022. Archived .mp4 on file at DeSmog.
- 18โEven 2 decades of #plantbreeding progress at current pace will not compensate for market supply losses if #EUFarm2Fork and #EUBiodiversity strategies are fully implemented. With access to all the innovative tools, plant breeding can help!โน๏ธ https://euroseeds.eu/…/plant-breeding-is-a-game…/ #GrowingTheFuture #COP15,โ video uploaded to Facebook by Euroseeds, December 16, 2022. Archived December 16, 2022. Archived .mp4 on file at DeSmog.
- 19โFarm to Fork โ it is time to listen to what the data says,โ CropLife Europe, October 12, 2021. Archived July 19, 2022. Archive URL: https://archive.vn/4R4P3
- 20โRe: Joint open letter from agri-food chain organisations regarding the potential impact of the current proposal on Sustainable Use of Plant Protection Products Regulation (โSURโ) on the EU agricultural value chain, considering the current socioeconomic situation in Europe,โ Europatat, November 17, 2022. Archived December 14, 2022. Archive URL: https://archive.ph/UqwMD
- 21Vicky Cann. โExploiting the Ukraine crisis for Big Business,โ Corporate Europe Observatory, July 28, 2022. Archived October 25, 2022. Archive URL: https://archive.ph/dSLE8
- 22Clare Carlile and Hazel Healy. โFlagship EU Green Farming Reforms in Peril as Lobbyists Exploit Ukraine War,โ DeSmog, December 9, 2022.
- 23Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
- 24Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
- 25Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
- 26Hume Brophy. โInvitation โ Euroseeds online event 17 May 2021,โ Provided by the European Commission, Accessed via AsktheEU, May 4, 2021. Archived November 21, 2022. Archived .pdf on file at DeSmog.
- 27โPlant breeding is a game changer for sustainable agriculture, new study shows,โ Euroseeds, May 17, 2021. Archived July 26, 2022. Archive URL: https://archive.vn/sTTJM
- 28โAccording to HFFA Research study, EU #plantbreeding in the next 20 years will help avoid an additional #GHG emissions of more than 3.6B tons until 2040. โน๏ธ https://euroseeds.eu/…/plant-breeding-is-a-game…/ #EUFarm2Fork #EUBiodiversity,โ video uploaded to Facebook by Euroseeds, January 4, 2022. Archived December 16, 2022. Archived .mp4 on file at DeSmog.
- 29Steffen Noleppa, Matti Cartsburg. โThe socio-economic and environmental values of plant breeding in the EU and for selected EU member states,โ HFFA Research, June 2021. Archived July 21, 2022. Archive URL: http://archive.today/5p4z3
- 30โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork.,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
- 31โEC study on new genomic techniques,โ European Commission, April 29, 2021. Archived November 28, 2022. Archive URL: https://archive.vn/3NzFf
- 32Florin Zubaศcu. โBiotech lobbies gear up for gene editing regulation battle,โ Science Business, May 18, 2021. Archived June 21, 2021. Archive URL: https://archive.ph/UsPgq
- 33โFarm to Fork: What the analysis and data tell us,โ EURACTIV YouTube, October 12, 2021. Archived July 26, 2022. Archive URL: https://archive.ph/TR15L
- 34โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
- 35โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
- 36โWageningen University and Research study highlights that innovation is crucial to help reduce the negative impacts of the Farm to Fork and Biodiversity strategies,โ Euroseeds, January 20, 2022. Archived July 26, 2022. Archive URL: https://archive.ph/DTXVL
- 37Johan Bremmer, Ana Gonzalez-Martinez, Roel Jongeneel, Hilfred Huiting, Rob Stokkers, Marc Ruijs. โImpact Assessment of EC 2030 Green Deal Targets for Sustainable Crop Production,โ Wageningen University and Research, December 2021. Archived December 14, 2022. Archived .pdf on file at DeSmog.
- 38โA loud lobby for a silent spring: The pesticide industryโs lobbying tactics against Farm to Fork.,โ Corporate Europe Observatory, March 17, 2022. Archived July 26, 2022. Archive PDF: https://archive.ph/hpFb3
- 39Magdalena Pistorius, โFarm to Fork studies do not give โwhole pictureโ, agri stakeholders warn,โ Euractiv, October 29, 2021. Archived December 14, 2022. Archive URL: https://archive.ph/ibXPF
- 40โFactsheet: Green Deal targets for 2030 and agricultural production studiesโ, European Commission, February 2022. Archived August 4, 2022. Archived .pdf on file at DeSmog.
- 41โGreen Deal 2030 targets and agricultural production studies,โ News Article, Directorate-General for Agriculture and Rural Development, European Commission, October 18, 2021. Archived July 22, 2022. Archive URL: http://archive.today/9MJmE
- 42โCharting transatlantic cooperation for a sustainable food system,โ Euroseeds, October 13, 2021. Archived November 21, 2022. Archive URL: https://archive.ph/BSLvr
- 43Hume Brophy. โRE: Invitation as a guest speaker: Transatlantic dialogue on agricultural innovation for a sustainable food system,โ Provided by European Commission, Accessed via AsktheEU, October 8, 2021. Archived November 21, 2022. Archived .pdf on file at DeSmog.
- 44โFarm to Fork Strategy: how to reach the targets?,โ Agri-Food Coalition, January 27, 2022. Archived on July 25, 2022. Archive URL: https://archive.ph/5PRDt
- 45Email from DG Sante. โBTO: meeting CAB with Euroseeds of 16 June,โ Provided by European Commission, Accessed via Ask the EU. Archived November 16, 2022. Archived .pdf on file at DeSmog.
- 46Kai Purnhagen and Justus Wesseler. โEU Regulation of New Plant Breeding Technologies and Their Possible Economic Implications for the EU and Beyond,โ Applied Economic Perspectives and Policy, September 28, 2020. Archived July 26, 2022. Archive URL: https://archive.ph/8szpW
- 47Aristidis M. Tsatsakis, Muhammad Amjad Nawaz, Demetrios Kouretas, Georgios Balias, Kai Savolainen, Victor A. Tutelyan, Kirill S. Golokhvast, Jeong Dong Lee, Seung Hwan Yang, Gyuhwa Chung. โEnvironmental impacts of genetically modified plants: A review,โ Environmental Research, 2017. https://doi.org/10.1016/j.envres.2017.03.011
- 48โPress release: Plans to unlock power of gene editing unveiled,โ Gov.uk, September 29, 2021. Archived July 26, 2022. Archive URL: https://archive.ph/RnjAL
- 49โDanger Ahead: Why gene editing is not the answer to the EUโs environmental challenges,โ Greenpeace, March 2021. Archived July 26, 2022. Archived .pdf on file at DeSmog.
- 50Tarja Laaninen. โNew plant-breeding techniques: Applicability of EU GMO rules,โ European Parliament Memberโs Research Service, October 2019, Archived August 24, 2022. Archive URL: https://archive.vn/fmcy8
- 51โPlant and forest reproductive material (revised rules).,โ European Commission, June 15, 2021. Archived July 26, 2022. Archive PDF: https://archive.ph/meWLS
- 52โInter-association letter to the EU Ministers of Agriculture and DG SANTE โ Europabio,โ Europabio, May 21, 2021. Archived October 31, 2022. Archive URL: https://archive.vn/hdZXe
- 53Slow Food Europe. โBiased from the outset: The EU Commissionโs โworking documentโ on new GM techniques fails to uphold environmental and consumer protection Standards,โ Slow Food, September 2021. Archived June 28, 2022. Archive URL: https://archive.vn/c6Dg1
- 54Euroseeds. โFeedback from: EUROSEEDS on Plant and forest reproductive material (revised rules),โ European Commission, July 13, 2021. Archived July 26, 2022. Archive PDF: https://archive.ph/Q3OLB
- 55โSeed Treatment And Technologies,โ Euroseeds. Archived October 4, 2022. Archive URL: https://archive.vn/2lwCD
- 56โWorkshop Seed Treatment evaluation under Regulation (EC) 1107/ 2009,โ Euroseeds and Seed Treatment Industry Stewardship Steering Committee, November 19, 2020. Archived December 14, 2022. Archived .pdf on file at DeSmog.
- 57โWorkshop Seed Treatment evaluation under Regulation (EC) 1107/ 2009,โ Euroseeds and Seed Treatment Industry Stewardship Steering Committee, November 19, 2020. Archived December 14, 2022. Archived .pdf on file at DeSmog.
- 58โEuroseeds position on the Regulation on the Sustainable Use of Pesticide,โ Euroseeds, June 23, 2022. Archived July 4, 2022. Archive URL: https://archive.ph/C3tUn
- 59Paul de Zylva. โThe problem with pesticides: Effects on wild species, food production and our environment,โ Friends of the Earth Insight Unit, December 2019. Archived December 14, 2022. Archived .pdf on file at DeSmog.
- 60Rundlรถf, M., Andersson, G., Bommarco, R. et al., โSeed coating with a neonicotinoid insecticide negatively affects wild beesโ, Nature, March 26, 2015. Archived December 14, 2022. Archive URL: https://archive.ph/sxhxj
- 61โEuroseeds,โ EU Transparency Register. Archived June 22, 2022. Archive URL: https://archive.ph/gslM7
- 62โINVITE: INnovations in plant VarIety Testing in Europe,โ Euroseeds. Archived December 14, 2022. Archive URL: https://archive.ph/RP7pd
- 63โEuroseeds,โ EU Transparency Register. Archived June 22, 2022. Archive URL: https://archive.ph/gslM7
- 64
- 65โList of meetings “Euroseeds” has held with Commissioners, Members of their Cabinet or Director-Generals since 01/12/2014 under its current ID number in the Transparency Register: “11362308587-10” (PDF),โ European Transparency Register, July 26, 2022. Archived July 26, 2022. Archived .pdf on file at DeSmog.
- 66โEuroseeds,โ EU Transparency Register, July 6, 2022. Archived July 26, 2022. Archive URL: https://archive.ph/Ku9mU
- 67โMembers,โ Agri-Food Chain Coalition. Archived June 22, 2022. Archive URL: https://archive.ph/9RvTP