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No big deal. Co-existence of precision bred and other crops in England 

Julian Sturdy MP

May 2024

Science for Sustainable Agriculture

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Arable farmer and politician Julian Sturdy MP outlines the recommendations of a new policy paper issued by the All-Party Parliamentary Group on Science and Technology in Agriculture, which concludes that farm-level co-existence between precision bred and other crops in England can be delivered through existing, well-established arrangements for meeting the quality and purity specifications of different end-markets. He also joins calls for more targeted action from the next Government to help registered organic producers source genuine organic seed, and so reduce their dependence on emergency use of non-organic seed.

 

Earlier this month, the All-Party Parliamentary Group on Science and Technology in Agriculture published a policy paper focusing on the issue of farm-level co-existence between new precision bred (PB) and other crops in England.

 

This follows the passing into law of the Genetic Technology (Precision Breeding) Act 2023 and the likelihood that, over the coming years, farmers in England will have the choice to grow crop varieties improved using precision breeding techniques such as CRISPR gene editing.

 

It also follows exaggerated claims from organic groups opposed to precision breeding that the introduction of PB crops could cause severe economic disruption to the UK’s £3 billion organic market, and undermine the viability of Britain’s organic farmers and food businesses.

 

Our aim in producing the policy paper, with input from experts along the UK crop production and processing chain, is to support informed discussion of the practical considerations needed to deliver effective co-existence, and so minimise concerns over unwanted mixing of seed or harvested crops destined for different market outlets.

 

Many examples already exist of farmers and supply chains successfully managing co-existence to meet both statutory and commercial specifications, for example in the production of high purity certified seed, the segregation of food grade and non-food crops, and the delivery of variety-specific consignments to meet customer requirements.  

 

So, we don’t need to reinvent the wheel.

 

In developing proportionate co-existence arrangements to support the introduction of PB crops, our policy paper also identifies a number of guiding principles, reflecting established practical, commercial and legal precedents, eg:

 

1. Co-existence is not a safety issue

Co-existence is not concerned with issues of safety to health or the environment, which are addressed in law through the Precision Breeding Act and associated food, environmental  and seeds marketing legislation. The Act establishes that growing approved PB crops should not be treated any differently from growing conventionally bred, non-PB crops.    

2. Co-existence measures will be determined by (differentiated) market demand

Farmers in England will only choose to grow PB crops if it makes economic sense, and if there is market demand. Similarly, the need for co-existence measures will only arise if there is differentiated market demand for PB and non-PB crops. In each case, the level of market differentiation will determine the nature (and cost) of co-existence arrangements.  

 

3. Co-existence is not a new concept

The UK crop production and supply chain has long-established practices enabling sexually compatible species to be planted, grown, harvested and delivered to meet the quality and purity specifications of a range of different end-markets. For example:

 

-  Certified seed and non-seed crops

-  Sweetcorn and forage maize

-  Industrial and food grade oilseed rape

-  Feed wheat and breadmaking wheat

 

These same practices are equally applicable in the context of PB crop production.

 

4. Zero presence is not achievable, but practical tolerance thresholds work

No sector of agriculture operates to, or can claim, 100% purity. In every crop sector, from certified seed to mainstream commodity production, practical tolerance levels are applied to define a crop’s end-use quality and value according, for example, to its varietal purity or freedom from unwanted material.

 

5. Co-existence is a two-way street

Since farming takes place in the open air, co-existence involves mutual co-operation and communication between farmers who share a vested interest in delivering products to meet their customers’ requirements.

 

6. Good neighbourliness is essential for effective co-existence, but PB growers cannot reasonably be expected to bear responsibility for the self-imposed marketing standards of others

In cases of dispute, relevant legal precedents establish that where niche or premium operators set standards which go above and beyond the legal norm, they must bear the primary responsibility for ensuring the necessary co-existence measures are followed.

 

Certified seed growers, for example, must observe statutory separation distances from neighbouring crops of the same species to achieve the required levels of varietal purity and integrity. These separation distances are not the responsibility of neighbouring non-seed growers, and yet certified seed production successfully covers an estimated 8-9% of the UK arable area.    

 

This is primarily because, as with other routine examples of co-existence, there is an established tradition within the crop production sector of due diligence and reasonableness between growers, eg in terms of good neighbourliness, communication, timely exchange of information regarding cropping intentions etc.

 

Importantly, the use of precision breeding may also lead to the development of specialist, high value PB crops, whose market premium will depend on preventing unwanted mixing with non-PB material. In this instance, of course, the primary responsibility for observing co-existence requirements will lie with the PB crop grower. 

    

7. PB crops introduce no new or unique liability issues

Once PB crops are approved as safe for commercial release and marketing, there are no legal grounds to suggest they should be treated differently—in liability terms—from other equivalent, conventionally bred products.

 

Our policy paper also emphasises the importance of focusing on realistic case studies of PB products most likely to reach the market in England, in each case taking account of factors such as the reproductive biology of the crop species, the production system (eg indoor/outdoor), and the anticipated scale of cropping under organic or ’non-PB’ production.

 

We considered eight examples of early PB products in the pipeline, from longer-fruiting strawberries and vitamin-enriched tomatoes to disease resistant sugar beet and high-yielding baby potatoes, with the conclusion that, in the vast majority of cases, farm-to-farm co-existence requirements would not be required at all.    

 

Concerns have also been raised by organic sector representatives that the current use of derogations from organic rules allowing the ‘emergency’ use of non-organic seed may give rise to unintentional use of PB varieties by organic growers.

 

This issue raises longstanding questions about the production and availability of organically produced seed, and whether a fresh approach is needed to ensure a reliable supply of certified organic seed. This is important not only to safeguard the integrity of organic production and maintain the confidence of organic consumers, but also to prevent unfair competition with conventional growers.

 

Concerns over this issue have previously been raised by the All-Party Group following reports that organic growers participating in OSR trials in Scotland using non-organic F1 hybrid oilseed rape seed were receiving premiums over conventional in excess of £500 per tonne. At the time, I described the reports as “a kick in the teeth for conventional oilseed rape growers struggling with pest-ravaged crops following the loss of neonic seed treatments.”

 

As part of the PB co-existence discussions, therefore, we believe it is timely for a future Government to review arrangements for the authorisation of non-organic seed use, including whether, after 20 years of operation, the Defra-funded OrganicXSeeds database is delivering on its stated aim to ‘help operators to find organic seed and seed potatoes’, and whether alternative arrangements and incentives may prove more effective in supporting the development of a sustainable market for organically produced seed.    

 

Calls for such a review are also supported by plant breeders and suppliers of organic seed. The British Society of Plant Breeders’ head of policy, Dr Anthony Hopkins, recently noted that despite a long-term decline in the UK organic area, emergency authorisations to use non-organic seed are at record high levels. Indeed, non-organic seed makes up the majority of sales to registered organic producers, and in some crop species can account for as much as 90% of seed sales. This in turn is preventing the development of a sustainable market for organically produced seed.

 

Overall, therefore, our conclusion is that a pragmatic approach to delivering effective co-existence between PB and non-PB crop growers and supply chains, including organic, can build on existing arrangements for meeting the quality and purity specification of different end-markets. We also need more targeted action from the next Government to help organic producers source genuine organic seed and reduce their dependence on emergency use of non-organic seed. It’s no big deal.

 

Julian Sturdy was first elected as MP for York Outer in 2010. He has served on the House of Commons Environment, Food and Rural Affairs Select Committee since 2017, and has chaired the All-Party Parliamentary Group on Science and Technology in Agriculture since 2016. Julian grew up in Yorkshire and has farmed in the area all his working life, having studied agriculture at Harper Adams University.   

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