IRELAND'S POLICY ON "CO-EXISTENCE" OF GM CROPS
This page is a clearinghouse of information on stakeholder consultations (launched in the summer of 2004) by the interdepartmental / interagency Working Group set up by the Irish Government Department of Agriculture and Food, for a National Strategy and best practices regarding the so-called "co-existence" of GM crops with conventional and organic farming.
Almost a year after a controversial deadline which excluded some 83% of the stakeholder groups who will be materially affected by the Strategy from participating in the related public consultation process, and which also prevented those stakeholders who were invited to become adequately informed to make constructive submissions, Agriculture and Food Minister Mary Coughlan published the "Report on Coexistence of GM and non-GM crops in the Republic of Ireland on 7 December 2005.
When the report was finally published, Mary Coughlan set the deadline for stakeholders to submit "observations" at 31 January 2006, 7 weeks after the report's publication (with Christmas in between).
On 14 February 2006, following pressure from the GM-free Ireland Network, the Dept. of Agriculture extended the deadline to 31 March 2006. Submissions and observations were sent in hard copy format to Mr John Downey, Crop Production and Safety Division, Department of Agriculture and Food, Maynooth, Co. Kildare or by email to john.downey@agriculture.gov.ie on or before 31 March 2006.
The GM-free Ireland Network invited all stakeholder groups to share their submissions and related documents by sending them to this address so we can post them on this page.
Coexistence plans for Northern Ireland are being dealt with by the NI Department of the Environment (DOE). Their draft strategy is in many ways even worse than the Irish one, based on incorrect assumptions and misinterpretation of EU law. For details, download Friends of the Earth's 35 page consultation response (588kb PDF file). The deadline for submissions on the draft co-existence strategy for Northern Ireland is 30 April 2007. Following the re-instatement of the Northern Irish Assembly in May 2007, the appointment of Sinn Féin MEP Michelle Gildernew as the new NI Minister of Agriculture provides an opportunity for her to implement her party's policy and declare the entire Province of Northern Ireland as a GMO-free zone, making it the first designated EU Region to do so on this island.
See also our downloads, scientific evidence, and recommended reading pages for related information.
Sections of this page:
A.
The European Commission strategy to introduce GMO seeds and crops
B.
Irish "stakeholder consultations" on the "co-existence" of GM crops
C.
Stakeholder letters, submissions & related Working Group documents
D.
E.
A.
EC strategy to legalise GMO seeds and crops in member states
Widespread consumer rejection
According to the Eurobarometer poll 55.2, 95% of EU consumers want the right to choose GM-free food, 86% want more information about GM foods, and 60% believe that GM crops could have negative effects on the environment. There is also widespread desire for social control of science - 80% agree with the statement that "the authorities should oblige scientists to obey ethical rules". Eurobarometer polls also indicate that over 70% of EU consumers reject GM food. In the UK the number is over 90%. The vast majority of consumers in Ireland's British, French and Italian export markets are also opposed to GM food. A survey carried out by Friends of the Earth Europe indicates that 94.6% of EU citizens want the right to choose GM-free food, and 70.9% refuse GM food.
No market for GM-labelled food in Europe
In January 2005, Greenpeace published a detailed report showing that the EU market for GM labelled food products is virtually closed. Europe's top 30 retailers and top 30 food & drink producers have policies and non-GM commitments which reveal a massive international food industry rejection of GM ingredients. This cuts across the industry from food and drink manufacturers to retailers, and includes everything from snacks and ready meals to pet food and beer. The combined total food and drink sales of the 49 companies with a stated non-GM policy in their main market or throughout the EU (27 retailers and 22 food and drink producers) amounts to § 646 billion, more than 60% of the total § 1,069 billion European food and drink sales. Irish food companies doing business internationally need to implement a non-GM policy without delay. Download report (2MB PDF file).
The EU de facto moratorium on GM seeds and crops
After the first field trials of GM crops were destroyed by protesters during the 1980s, the European Commission decided to suspend the legal cultivation of GM seeds and crops until GM Traceability and Labelling Regulations came into force in June 2004. This continues to cause hundreds of millions of dollars of lost revenues for GM farmers in Canada, Argentina and the USA, who have paid higher costs plus annual licensing fees to grow patented GM crops which they cannot export to European markets where consumers refuse contaminated food.
The WTO GM trade dispute against the EU
Thee governments of Canada, Argentina and the USA (a.k.a. "the coalition against nature") then proceeded to file a trade dispute against the European Union at the World Trade Organisation, arguing that the EU's recent de facto moratorium, its current precautionary stance on the approval of GM products (including mandatory labeling) - together with national bans in Austria, France, Germany, Greece, Italy and Luxembourg on some GM products - are an impediment to "free trade" which violates the WTO rules. The complainants claim that GM agriculture is "of proven safety and brings great benefits, including in reducing hunger and improving health and crop productivity worldwide". The WTO has set up a 3-person Dispute Panel which meets in secret to judge the case.
But in August 2004 the Dispute Panel decided that it would require scientific advice in making its decision about the US challenge. The USA, Canada and Argentina had argued that there is no need for scientific advice and that the dispute was about procedural matters. Europe argued that in a complex matter which relates to the risks of GMOs, the Dispute Panel has to take wider advice. The Panel's decision on this point indicates that they see strength in the European case. For updates on the WTO dispute see www.genewatch.org/WTO.
The false concept of "substantial equivalence"
The US-led trade war against the EU rests on the scientifically preposterous legal assumption that GMOs are "substantially equivalent" to their non-GMO counterparts. The concept of "substantial equivalence" between GM and conventional crops was discredited in a paper by Dr. Arpad Pusztai which found that GM potatoes contained 20% less protein than normal spuds. (The study also found physiological changes in the internal organs of rats fed on GM potatoes. The changes involved GM material transferring to the gut lining and creating a pre-cancerous state.) The concept of "substantial equivalence" was dealt a further blow on 10 November 2004 in a scientific report from the North American Free Trade (NAFTA) commission. The report, written by a group of geneticists convened under NAFTA, refuted the U.S. claim that GM maize is, for trade purposes, "substantially equivalent" to GM-free maize. Mexican farmers had asked NAFTA to undertake the study after researchers found that cross-pollination by wind or insects carried GM maize pollen from the USA across the border into Mexico. The commission said this contamination of Mexican farms is unacceptable because the Mexican government never approved the GM hybrids, and that the contamination should be limited or stopped. NAFTA's decision will strengthen the EU's side in the WTO trade dispute.
While the outcome of the WTO trade dispute remains pending, the EC has been keen to avoid costly punitive trade sanctions that could result if the WTO dispute panel were to rule in favour of the complainants. The EC is therefore moving ahead with its effort to legalise GM food and crops amidst growing resistance from hundreds of regional governments, thousands of sub-regional governments, and the vast majority of food brands, retailers, and consumers.
End of the EC's de facto moratorium on GM food and crops
On 19 May 2004, the EC lifted its moratorium on genetically modified food, which had been in place for nearly six years, when it first approved a type of GM sweetcorn to be sold in tins. On 8th September 2004, the outgoing EU Health and Consumer Affairs Commissioner David Byrne decided to list 17 GM maize varieties derived from Monsantoís MON 810 in the European Union's Common Catalogue of Seeds. Although presented by the Commission as a formality, many observers saw this last minute move by the outgoing Commission as highly controversial. In 1994, David Byrne also used his political influence to attempt to establish a 0.5% threshold for the labelling of 17 varieties of GM-contaminated seeds, whereas EU Agriculture Commissioner Franz Fishler and EU Environment Commissioner wanted 0.3%, and the European Parliament, NGOs, consumer groups, farmers organisations and trade unions have appealed to the Commission to set the seeds labelling contamination threshold at the reliable detection level of 0.1%.
Currently there is no legislation in place to stop GM crops from contaminating conventional or organic crops. If contamination is to be stopped, and consumer choice and the environment to be safeguarded, measures such as co-existence rules and GM-free zones should be in place before GM crops are authorised for cultivation.
European Commission Recommendation 2003/556/EC
On 23 July 2003, the European Commission issued Recommendation 2003/556/EC on guidelines for the development of national strategies and best practices to ensure the coexistence of genetically modified crops with conventional and organic farming. The Recommendation asks Member States to put in place legal measures for "co-existence" measures which should not go further than to keep GM contamination of non-GM and organic crops below the threshold set down in European GM labelling legislation (currently 0.9 per cent). It also says that measures should ignore environmental concerns and be limited to economic issues. The problem is that if member states put in place measures, like separation distances, based on this guidance, widespread GM contamination of crops and food is very likely to occur.
On 21 March 2005, Greenpeace, Friends of the Earth, GeneWatch UK, Which? and Five Year Freeze issued a joint press release stating that this recommendation is legally flawed and called for it to be withdrawn. A legal opinion by leading European lawyer Paul Lasok QC was presented to the EC Commissioners for Agriculture, Environment and Consumers, condemning the EC position as "fundamentally flawed" and criticising the UK Government for following this approach, which has no basis in community legislation and is legally incorrect. The opinion concludes:
"Öthe Recommendation is based on a fundamental misunderstanding of the relevant
legal provisions, and risks advising Member States to adopt coexistence measures that
are incompatible with the aims of the legislation or which would result in preventing, in
practice, the use of the "organic" label and the reliance on the GM labelling exemption."
Friends of the Earth's GM campaigner, Clare Oxborrow said:
"This legal opinion destroys the European Commission's position on GM crop coexistence
with non-GM crops. Countries around Europe are already putting in place laws
to control contamination from GM crops, but they are being misguided by flawed advice.
There is a growing movement for GM free areas in Europe, and consumer demand for
GM free food remains as strong as ever. The Commission must now ditch its misleading
guidance and replace it with tough, EU-wide laws that will truly protect our choice for
GM-free food, our health and the environment from the threat of GM crops."
Sue Davies, Chief Policy Officer, Which? said:
"The EC's Recommendation on coexistence takes GM contamination of up to 0.9 per
cent as its starting point and therefore restricts people's ability to have meaningful choice between GM, non GM and organic crops. The legal advice offered today suggests that
the European Commission and member states should be aiming to minimize
contamination when establishing rules for how GM crops should be grown."
Peter Melchett, Policy Director of The Soil Association said:
"One reason consumers choose organic food is to avoid eating GM products, yet the
European Commission is trying, we believe illegally, to impose rules that could mean
almost one in every hundred mouthfuls of organic food was actually GM food, with no
requirement to tell people what they are really eating."
Sarah North GM Campaigner for Greenpeace said:
"The European Commission may have to go back to the drawing board with GM crops
now. If their assumptions about how to stop contamination between GM and normal
crops are wrong, then it follows that subsequent decisions to allow some GM crops to be
grown in Europe and proposals for permissible levels of GM contamination of regular
seeds may also be flawed. Our legal opinion could stop the Commission disregarding
their own legislation and forcing GM crops into Europe on a remiss premise."
This press release came out the day after community groups across Europe accused the European Commission of an ongoing conspiracy to keep sensitive information on GM safety studies out of the public domain. The EC has also been accused of "playing politics with public health" by turning a blind eye on inconvenient scientific findings and approving potentially dangerous GM varieties simply to please the Americans and the WTO. See GM Free Cymru press release, 20 March 2005 (Download (64K PDF file).
B.
The Irish stakeholder consultation process on the "co-existence" of GM crops
The DAD syndrome: Decide, Announce and Defend!
In 1997, Fianna Fáil Agriculture spokesperson (and subsequent Minister) Joe Walsh T.D., and spokesman for the Environment Noel Dempsey (now Minister for Communications, Marine and Natural Resources) set out their party's clear position against the development and sale of GM food, crops and livestock in a campaign pledge to keep Ireland GM-free. But after Bertie Ahern's St. Patrick's Day 1988 meeting with US National Security Adviser Sandy Berger, Fianna Fáil issued a completely opposite communication declaring (falsely) that "the area of Irish economic interest where biotechnology, particularly modern biotechnology / genetic modification, has greatest potential is in agriculture". Our government's hard-line pro-GM voting record in the European Parliament since then clearly ranks the wishes of the US government and the biotech industry above the economic, environmental, and food security interests of its own citizens. Our government approved the importation of GM animal feed which now contaminates most of our meat and dairy produce, legalised the importation of various GM foods, and played a key role in legalising the first GM crops in Europe.
The government now seems bent on using the pretence of an undemocratic "stakeholder consultation" process for the so-called "co-existence" of GM crops with conventional and organic farming as a smokescreen to justify its pre-determined policy for the further legalisation of GM animal feed, seeds, trees, crops, livestock, fish and food on this island.
As mentioned in section A above, the consultation process is based on Recommendation 2003/556/EC which is inherently flawed, has no basis in community legislation and is legally incorrect, especially because it avoid all consideration of health and environmental risks, and fails to truly protect our choice for GM-free food, our health and the environment from the threat of GM crops.
How the consultation process began
To implement Recommendation 2003/556/EC, the Irish Government has set up an interagency / interdepartmental Working Group co-ordinated by the Department of Agriculture and Food National Crop Variety Testing Centre (see members).
On 13 August 2004, this Working Group invited 22 stakeholder groups (including the GM-free Ireland Network) to participate in consultations. But at least 86% of the stakeholder groups were excluded from the consultation process (including relevant government agencies, all County and Town Councils, foresters, food producers, food exporters, chefs, restaurants, retailers and Non Governmental Organisations who have the greatest expertise and/or will be most directly affected by any introduction of GM crops on this island).
First GMFI meeting with the Working Group
The GM-free Ireland Network held its first consultation with the Working Group on 23 September 2004. The GMFI delegation included representatives of An Taisce, Demeter Organic Standards Ltd., the Irish Doctors Environmental Association, the Irish Organic Farmers and Growers Association (IOFGA), the Irish Seed Savers Association, the Leitrim Organic Farmers Cooperative, Global Vision Consulting Ltd (which is co-ordinating the GMFI Network), and the Organic Trust. The Irish Cattle and Sheepfarmers Association (which is also a member of GMFI) did not attend as it had been invited to a separate meeting with the Working Group a few days earlier).
GMFI welcomed the Working Group's invitation to participate in the consultation process with considerable reservations, because of inter alia:
(1)
scientific evidence that the so-called "co-existence" of GM crops with conventional and organic farming is difficult if not impossible to achieve due to inevitable and irreversible contamination by GMOs. See, for example, the European Commission Joint Research Centre's May 2002 report Scenarios for co-existence of genetically modified, conventional and organic crops in European agriculture (download as 1 MB PDF file) which found that GM crop varieties inevitably contaminate conventional and organic crops and may cause up to 40% higher production costs for EU farmers. (Note that Ireland's Chief Scientific Officer Dr. Barry McSweeney, was accused by Greenpeace of attempting to suppress the publication of this report because of its disappointing conclusions for the biotech industry, whilst he was CEO of the Joint Research Centre.)
(2)
a complete lack of trust in this Government's statements on GMOs because of its campaign promise to never allow GM crops, its subsequent pro-GM voting record in the EU parliament, the highly controversial legalisation of the first GMO crops in the EU by former Health and Consumer Affairs Commissioner David Byrne prior to leaving office in late 2004, and flagrant conflicts of interest in the Food Safety Authority of Ireland and the Environmental Protection agency, which routinely downplay or deny the scientific evidence of GM health and environmental risks;
(3)
almost complete lack of public awareness of the economic, agricultural, environmental, health and food security risks of introducing GM farming on the island of Ireland;
(4)
the need to expand the group of stakeholders being consulted in order to include all those who will be most directly affected by Ireland's policies on GM farming;
(5)
the need for adequate time to empower all the stakeholder groups to (a) become adequately informed on the complex relevant issues in genetics, agriculture, ecology, health, economics, politics, law, food security and sustainability; (b) exchange views amongst themselves; and (c) reach consensus;
(6)
the need for the consultation process to comply with the obligations and legal requirements of the 1992 Rio Convention on Sustainable Development, the 1998 Aarhus Convention, and the 2000 Cartagena Protocol on Biosafety. The Aarhus Convention empowers citizens of EU countries to have an active role in formulating any governmental environmental policies which will affect them. For details see the European Eco Forum's analysis on Gaps in the Public Participation requirements of the EU Directive on GMOs as compared with the Aarhus Convention: download (924K PDF file).
Controversial deadlines
The Working Group said that the closing date for stakeholders' submissions would be sometime in the Spring of Summer of 2005. GMFI accepted this deadline and expressed the necessity for a national stakeholders' conference (following the success of the Forging a GM Policy for Ireland workshop held in April 2004), in order to empower all the groups involved in the consultation process to become sufficiently informed on the various aspects of the GM controversy to make a meaningful contribution to the formulation of Ireland's national policies on GM farming.
The GM-free Ireland Network was thus astonished to receive a letter from the Working Group three weeks later (on 18 October 2004), announcing a decision to bring the closing date for submissions to 12 November 2004 - less than a month away - in order for the Working Group to finalise its report to the Department of Agriculture at the end of November.
On 11 November 2004, the GM-free Ireland Network sent a letter to the Working Group requesting it to (A) extend the deadline for a first round of submissions until 17 December 2004 (with notice of the same to be sent to all the other stakeholder groups on its list) and (B) extend the deadline for final submissions to 31 May 2005. This letter included an explicit warning to the Working Group that failure to agree the 31 May 2005 deadline would result in formal complaints being filed with the Ombudsman and the European Commission.
Similar letters requesting an extension of the deadline were also sent on 11 November 2004 by An Taisce, the Ecological Environmental NGO Secretariat (EENGO), and the Irish Organic Farmers and Growers Association, which also sent a preliminary submission expressing its view that the entire consultation process is untransparent and appears to provide no opportunity for those consulted to consider any draft documents produced by the Working Group in advance of its final report being published.
On 12 November 2004, the Working Group issued a press release which stated, inter alia, that "Today, Friday, November 12th 2004, was set as the final date for receipt of submissions thereby allowing the Working Group submit its Report
to the Department in a timely fashion. However, a number of the stakeholders have requested an extension to this closing date and the Working Group, in the interest of considering the views of as broad a spectrum as possible, has acceded to this request and extended the date for receipt of submissions to the end of the year - 31st December 2004. As a consequence of this extension the Working Group now propose to be in a position to submit its report to the Department early in 2005."
In an effort to legitimise its rushed deadline, this press release falsely claimed that "All Member States are obliged to have their measures submitted to the EU Commission by July 2005" [emphasis added]. Since the consultation process derives from an EC Recommendation (not a Directive), there is no legal obligation to submit any "co-existence" measures, nor to do so by any date.
Following further telephone requests from the GM-Free Ireland Network, the Department then reluctantly extended the deadline to January 2005.
Second GMFI meeting with the Working Group
On 10 January 2005, the GM-free Ireland Network held its second consultation with the Working Group. Our delegation included Richard Auler (Spokesperson, Irish Organic Farmers and Growers Association), John Brennan (Director, Leitrim Organic Farmers Coop),
Stella Coffey (Irish Organic Farmers and Growers Association), John Heney (Rural Development Chairman, Irish Cattle and Sheepfarmers Association), Kathryn Marsh (Boardmember, Organic Trust), Michael O'Callaghan (Co-ordinator, GM-free Ireland Network), and Eanna Ní Lamhna (President, An Taisce).
By this date, GMFI had already succeeded in getting the Working Group to include six more stakeholder groups in the consultation process: An Taisce, An tIonad Glas Organic College, Cavan Leitrim Environmental Awareness Network Ltd (CLEAN), the Ecological Environmental NGO Core Funding Secretariat (EENGO), the Irish Doctors Environmental Association (IDEA), the Irish Wildlife Trust, and the Kerry Earth Education Project.
The GMFI Network reiterated its request to (A) extend the deadline for a first round of submissions until 17 December 2004 (with notice of the same to be sent to all the other stakeholder groups on its list) in order to participate in the European Conference on GMO-free Regions, Biodiversity and Rural Development (held on 21 - 23 January 2005 in Berlin) before submitting its preliminary submission by the end of January 2005, and (B) also reiterated its request to extend the deadline for final submissions to 31 May 2005.
The Working Group again refused to accede to both of these requests. Moreover, it informed GMFI that it had already begun editing its Report, that its mission is to prepare a technical report, and that the health and environmental safety of GM crops are beyond its remit. It claimed to be taking the Precautionary Principle seriously, but said that GM crops being approved for Ireland include maize, cereals (wheat, oats, barley, triticale), sugar beet, potatoes, oilseed rape, and horticultural crops (flowers etc.). It also re-affirmed its belief in the concept of "co-existence" with crop separation distances of between 2 and 100 meters, and said it only intends to address ways to prevent SACs and other protected areas from GM contamination on a case-by-case basis.
On 19 January 2005, the Irish Creamery Milk Suppliers Association (ICMSA) informed the GM-free Ireland Network that their executive board is extremely concerned about the introduction of GM animal feed, GM seeds, and GM crops, and wants the deadline for stakeholder submissions extended to enable ICSMA's 70,000 members to become adequately informed before making their submission.
By this date, over 100,000 stakeholders thus wanted the deadline extended.
By the termination of the supposed deadline at the end of January 2005, invited stakeholder groups who had not had time to complete their final submissions included, inter alia, An Taisce, the Ecological Environmental NGO Core Funding Secretariat (EENGO), the GM-free Ireland Network, the Irish Cattle and Sheepfarmers Association (ICSA), the Irish Creamery and Milk Suppliers Association (ICMSA), the Irish Organic Farmers and Growers Association, the Irish Seed Savers Association, the Irish Wildlife Trust, Macra na Feirme, and the Organic Trust - to name but a few.
86% of stakeholders excluded from the consultation process
A survey of 215 principal stakeholders identified by Global Vision Consulting Ltd. as those who will be most affected by the National Strategy on GM issues - and who therefore have a legal right to participate in the consultation process for its formulation - found that 86% were excluded and only 7.9% made final submissions as of 1 February 2005.
Failure to comply with international law and best practice
Shifting the deadline for submissions, the lack of time, the exclusion of stakeholders, and the lack of any clear provision for stakeholders to provide feedback on and approve the Working Group's final report to the Department mean that this entire consultation procedure fails to comply with the minimum standards for transparency and democratic public participation in environmental decision-making which are now legally required under the Biosafety Protocol, the Aaarhus convention, the Codex Alimentarius, and EC law.
Publication of the "Report on coexistence of GM and non-GM crops in Ireland"
On 7 December 2005 –" almost a year after the working group imposed its 31 January 2004 deadline which prevented most stakeholders from making their submissions as part of the public consultation process – the Minister for Agriculture and Food, Mary Coughlan, published the government's offical Report on coexistence of GM and non-GM crops in Ireland. This was accompanied by a press release announcing a new deadline of 31 January 2006 for interested parties to make "observations" on the report. Our critique of this report will be published here soon.
Complaints to Ombudsman, EC, and Aarhus Convention Compliance Committee
The GM-free Ireland Network is now preparing formal complaints to the Ombudsman, the European Commission and the Aarhus Convention Compliance Committee, concerning the Working Group's failure to comply with the requirements for democratic public participation in the consultation process. These will add to the lawsuits filed by the EC against the Government in 2005 for chronic failure to comply with EU laws intended to safeguard the Irish citizens from a raft of other major environmental and public health time-bombs.
What next?
Since GM crops can never be recalled after their release, the best option for the Irish Government is to simply scrap its flawed consultation process on "co-existence" and work with its counterpart in Northern Ireland to declare the whole of this island as a GMO-zone.
Failing this, the second best option is for stakeholders and citizens North and South of the Border to take responsibility to forge an island-wide democratic sustainable GM policy that will be good for farmers, consumers, the environment and future generations - and which will ensure the survival of Ireland's GM-free food sector which exports to Europe and provides hundreds of thousands of jobs here.
The new EC Agriculture Commissioner Mariann Fisher Boel has indicated that she may now introduce an EU legal framework on "co-existence" later this year which will allow regions to determine for themselves whether growing GM crops is in the wider interests of their farmers and environment. This legal framework should also include strict liability provisions and take into account not only economic but also ecological aspects of growing GM crops. For more on this, see the briefing Time to change European policy on GMOs in agriculture issued to the new EC Commissioners on 17 March 2005 by the European Environmental Bureau (EEB), European Community of Consumer Cooperatives (EURO COOP), Friends of the Earth Europe (FOEE), Greenpeace European Unit, and the International Federation of Organic Agriculture Movements (IFOAM) EU Group, 17 March 2005 - which you can download here (924K PDF file).
Recommendation of the GM-free Ireland Network:
(1)
Extend the current deadline for stakeholders to provide their "observations" on the "Report for coexistence of GM and non-GM crops in Ireland" to the end of July 2006, with a guarantee that the final document will fully incorporate their views;
(5)
Provide funding and support for a national conference to inform government and stakeholder policy makers on the range of relevant issues in genetics, agriculture, ecology, health, economics, politics, law, food security and sustainability;
(2)
Expand the list of participating stakeholder groups to include all those who will be affected by the National Strategy and who have the legal right to participate in its formulation;
(3)
Broaden the membership of the Co-existence Working Group to include stakeholder representatives;
(6)
Enable communication between stakeholder groups with a view to reach consensus;
(7)
Guarantee the stakeholders' right to provide feedback and approve (a) all draft and final documents produced by the Working Group, (b) the National Strategy, and (c) any resulting laws.
(4)
Purge the Food Safety Authority of Ireland and the Environmental Protection Agency of all persons who have current or prior links to the biotech industry they are supposed to regulate;
(9)
Hold a national referendum on keeping Ireland GM-free.
C.
Stakeholder letters, submissions & related Working Group documents:
(most recent at top of list)
8.
"Report on Coexistence of GM and non-GM crops in Ireland" issued by the Department of Agriculture and Food on 7 December 2005, with notice of deadline for stakeholder observations on 31 January 2006).
7.
Department of Agriculture press release announcing extension of deadline for submissions from 12 November to 31 December 2004 (issued on 12 November 2004).
6.
Department of Agriculture letter to the GM-free Ireland Network bringing forward the deadline for submissions to 12 November 2004 (issued on 18 October 2004).
5.
Letters and submissions sent by some stakeholders to the Working Group between 11 November and 31 December 2004 (in reverse chronological order):
Irish Cattle and Sheep Farmers Association submission (31 December 2004)
Irish Organic Farmers and Growers Association - additional submission (December 2004)
Cavan Leitrim Environmental Awareness Network submission (28 December 2004)
An tIonad Glas Organic College submission (20 December 2004)
An tIonad Glas Organic College concerns (20 December 2004)
Kerry Earth Education Project submission (9 December 2004)
An Taisce letter (11 November 2004)
Federation of Irish Beekeeping Associations submission (11 November 2004)
GM-free Ireland Network letter (11 November 2004)
Irish Doctors Environmental Association letter (11 November 2004)
Irish Organic Farmers and Growers Association letter (11 November 2004)
Irish Organic Farmers and Growers Association submission (11 November 2004)
Irish Seed Savers Association submission (11 November 2004)
4.
List of Working Group members provided by the W.G. on 28 September 2004.
3.
List of stakeholders invited by the Working Group provided by the W.G. on 13 September 2004.
2.
GM-free Ireland letter to the Working Group sent on 10 September 2004 requesting a list of the other stakeholders being consulted.
1.
Invitation to participate in stakeholder consultations on the so-called "co-existence" of GM crops with conventional and organic farming sent to the GM-free Ireland Network on 13 August 2004 by the interdepartmental / interagency Working Group set up by the Irish Government Department of Agriculture and Food. Attached to this letter was a copy of EC Recommendation 2003/556/EC
.
D.
Report on coexistence of GM and non-GM crops in Ireland:
Published by the Minister for Agriculture Mary Coughlan on 7 December 2005 – almost a year after the controversial deadline on 31 December 2004 which prevented the majority of stakeholders from being able to make their submissions! This report came with a press release and notice of deadline for final observations by interested parties on 31 January 2006.
E.
Related documents: (most recent at top of list)
16.
Impossible coexistence: Seven years of GMOs have contaminated organic and conventional maize: an examination of the cases in Catalonia and Aragon. Published by Greenpeace International, 4 April 2006 (928 KB PDF file).
15.
European GM crop co-existence recommendations legally flawed. As European Commissioners gathered to debate the future of GM crops and food on 22 March 2005, environment and consumer representatives said that the EC Recommendation 2003/556/EC (which advised EU member states to set up rules for the so-called "co-existence" of GM crops with conventional and organic farming) is legally and fundamentally flawed. The NGOs want the Recommendation to be withdrawn and are calling for an urgent meeting to discuss its legal status and content. Paul Lasok QC, a leading European Lawyer, was asked by Which? (the UK consumers' association), Friends of the Earth, The Soil Association, Greenpeace, the Five Year Freeze Campaign and GeneWatch UK to advise on the EC Recommendation on the growing of GM crops alongside non GM and organic crops (co-existence)
Joint press release from European Environmental Bureau (EEB), European Community of Consumer Cooperatives (EURO COOP), Friends of the Earth Europe (FOEE), Greenpeace European Unit, and the International Federation of Organic Agriculture Movements (IFOAM) EU Group, 21 March 2005. Download (272K PDF file).
14.
Legal advice by leading European lawyer Paul Lasok QC, that EC Recommendation 2003/556/EC (which advised EU member states to set up rules for the so-called "co-existence" of GM crops with conventional and organic farming) is legally and fundamentally flawed. 21 January 2005. Download (180K PDF file).
13.
EC accused of "ongoing conspiracy" to suppress research on GM health hazards. The EC has been accused by community groups across Europe of an ongoing conspiracy to keep sensitive information on GM safety studies out of the public domain. It has also been accused of "playing politics with public health" by turning a blind eye on inconvenient scientific findings and approving potentially dangerous GM varieties simply to please the Americans and the WTO. GM Free Cymru press release, 20 March 2005. Download (64K PDF file).
12.
Complaint to the EU Ombudsman by CLEAN (Cavan Leitrim Environmental Awareness Network) Ltd. against the European Commission, 18 March 2005. This complaint argues (A) that existing EU regulations, directives and policies in respect of GMOs are inconsistent and violate the European principles of equality, competitiveness, transparency, proportionality, informed consumers' choice, access to information and public participation; and (B) that existing EU regulations, directives and policies in respect of GMOs are not in compliance with the Treaty Establishing the European Union. Download (44K PDF file).
11.
Time to change European policy on GMOs in agriculture Letter sent to the Commissioner by the European Environmental Bureau (EEB), European Community of Consumer Cooperatives (EURO COOP), Friends of the Earth Europe (FOEE), Greenpeace European Unit, and the International Federation of Organic Agriculture Movements (IFOAM) EU Group, 17 March 2005. Download report (924K PDF file).
10.
Gaps in the Public Participation requirements of the EU Directive on GMOs as compared with the Aarhus Convention: a comparative analysis by the European ECO-Forum, January 2004. Download report (924K PDF file).
9.
Corporate control of the food chain: the GM link. A comprehensive review of the role of biotech corporations in GM food production and distribution, food aid, labelling and traceability, regulatory regimes, misinformation and food safety. Published by Consumers International. Download report (924K PDF file).
8.
GMO factsheet: Why consumers should take action.
Consumers International factsheet published on World Consumer Rights Day 2005, explaining genetic engineering and its prevalence, with a summary of consumer concerns about GMOs including the role of subsidies, corporate ownership, patents, unsubstantiated claims and labelling. Download (152K PDF file).
7.
GMO factsheet: "Co-existence" or GM-free zones? Consumers International factsheet published on World Consumer Rights Day 2005, outlining contamination concerns, providing example cases of contamination of GM-free crops, and GM-free zone initiatives. Download (184K PDF file).
6.
No Market for GM-labelled Food in Europe. In January 2005, Greenpeace published this detailed report showing that the EU market for GM labelled food products is virtually closed. Europe's top 30 retailers and top 30 food & drink producers have policies and non-GM commitments which reveal a massive international food industry rejection of GM ingredients. This cuts across the industry from food and drink manufacturers to retailers, and includes everything from snacks and ready meals to pet food and beer. The combined total food and drink sales of the 49 companies with a stated non-GM policy in their main market or throughout the EU (27 retailers and 22 food and drink producers) amounts to § 646 billion, more than 60% of the total § 1,069 billion European food and drink sales. Irish food companies doing business internationally need to implement a non-GM policy without delay. Download report (2MB PDF file).
5.
Amendment to Germany's Genetic Modification Act. This implements Directive 2001/18/EC and aims to ensure GM-free production and the co-existence of GM crops and non-GM crops in Germany. The Amendment passed the German parliamentary procedure on 26 November 2004 and is likely to enter in force early in 2005. It provides a useful model that could be transposed into Irish law.
4.
Co-existence between genetically modified crops, and conventional and organic crops. Opinion of the European Economic and Social Committee, Section for Agriculture, Rural Development and the Environment (issued on 24 November 2004). NGO Press release
3.
Growing GM Crops: The Need for Contamination and Liability Rules. GeneWatch UK Briefing no. 29 (issued in October 2004).
2.
Second Written Submission by the European Communities to the WTO Trade Dispute Panel on measures affecting the approval and marketing of biotech products in relation to the complaint filed against the EU by the governments of Argentina, Canada and the USA in connection with GM products. 19 July 2004. Download (760KB PDF file).
1.
EC Recommendation on guidelines for the development of national strategies and best practices to ensure the coexistence of genetically modified crops with conventional and organic farming (2003/556/EC). 23 July 2003.
