1. CONSEQUENCES OF PROPOSED EU LEGISLATION ON THRESHOLDS FOR THE ADVENTITIOUS PRESENCE OF GENETICALLY ENGINEERED (GE) SEEDS. Janet Cotter, Greenpeace Science Unit, Exeter University, Exeter, UK, EX4 4PS Introduction The EC has proposed legislation 1 to establish thresholds for the adventitious presence of EU approved genetically engineered (GE) seeds in conventional seed lots. These thresholds are: oilseed rape - 0.3 %; maize, beet, cotton - 0.5 % and soya - 0.7 %. These thresholds were chosen to give a GE content in the food product within the labelling limit (assumed to be 1 %) 2. However, there are concerns that these proposed thresholds will result in an immediate, unprecedented release of GE plants in the EU and, in the future, the accession countries. Method Land acreage for oil seed rape, beet, maize, soybean and cotton were obtained for 2000 from annual statistics 3 for EU countries, those for Accession countries from EUROSTAT 4. Data for silage/ forage maize are not given in the EU annual statistics, nor available from EUROSTAT for Accession countries. Data for silage/forage maize were reported only for those countries where data was readily available from national statistics and, as such, are likely to be an underestimate of the actual acreage of silage/ forage maize. Data for cotton is either not available or zero for all Accession countries. Plant densities were supplied by ADAS, UK, personal communication for mid- range target established plant populations in the UK. Planting densities for silage maize were assumed to be the same as grain maize. The total area of arable land in the EU was calculated from annual statistics 3 as the sum of main crops in 1999 and excluding land used as pasture. Using average plant densities, the number of GE plants grown at these thresholds were calculated for the EU and Accession countries. The effective acreage of GE plants and the % of EU arable area affected were also calculated. Discussion The results demonstrate that the proposed thresholds lead to a large quantity of GE plants in Europe – 7 000 million at the best case scenario (oilseed rape and maize in the EU only) to 14 580 million in the worst case scenario (soy, sugarbeet, cotton, maize and oilseed rape across and enlarged EU). These GE plants will be unregulated, e.g. separation distances and segregation will not apply. Therefore, these plants will be able to freely cross with non-GE crops and also feral and wild relatives, especially of beet and oilseed rape. The appearance of herbicide resistant “weeds” could necessitate the widespread use more environmentally damaging herbicides. These numbers of unregulated GE plants will be allowed annually. Thus, the numbers of unregulated GE plants will increase annually. The values of 0.3%, 0.5% and 0.7% are not a reflection of how low it is possible to keep GE contamination nor do they take into consideration the environmental and agronomic impact of such contamination. It has been acknowledged that, by choosing such high levels, the amount of contamination in the final product would creep up over the long term - especially in oilseed rape 2. Therefore, it is vital to keep GE contamination to a minimum and keep to that minimum. GE-free seed production and supply can and is being achieved by major seed suppliers at a threshold of 0.1% (the effective detection limit). In over 3 000 seed samples analysed so far by EU governments less than 5% show any detectable GE contamination. In other words over 95% of all seed lots tested in the EU, including imported seeds, are already produced under the zero tolerance threshold of 0.1% GE contamination 5. Conclusion : A threshold level of 0.1 % is achievable and vital to protect the environment. References 1 Draft COMMISSION DIRECTIVE../…/Ecof … amending Council Directives 66/400/EEC, 66/401/EEC, 66/402/EEC, 66/403/EEC, 69/208/EEC, 70/458/EEC and Decision 95/232/EEC as regards additional conditions and requirements concerning the presence of genetically modified seed in seed lots of non-genetically modified varieties and the details of the information required for labeling in the case of seeds of genetically modified varieties Brussels, 02.07.2002, P./secr/doc2001 /va/1542en02july2002 http://www.zs-l.de/gmo/downloads/Seed_Directive_3_July_2002.pdf 2 European Commission Scientific Committee on Plants. Opinion of the Scientific Committee on Plants concerning the adventitious presence of GM seeds in conventional seeds. SCP/GMO-SEED-CONT/002-FINAL 13 March 2001 http://europa.eu.int/comm/food/fs/sc/scp/out93_gmo_en.pdf 3 European Union, Directorate-General for Agriculture. Agriculture in the European Union: Statistical and Economic Information 2001. (Jan 2002) http://europa. eu. int/ omm/ agriculture/ agrista/ 2001/ table_ en/ index. Htm 4 EUROSTAT: Statistics for crop acreage in Accession countries were purchased from Data Shop Newport, UK. Details from http://europa.eu.int/comm/eurostat/ 5 Greenpeace (2002) Save Our Seeds! Agriculture and environment threatened by GE seed contamination law. October 2002. http://www.greenpeace.org/reports/