Agricultural organisations the Agricultural Business Chamber (Agbiz), CropLife South Africa and the South African National Seed Organisation (Sansor) say government is stifling the development of new breeding technologies (NBTs) by deciding to evaluate them under the risk assessment framework for genetically modified organisms (GMOs).
The Department of Agriculture, Land Reform and Rural Development in October last year announced that a diverse and evolving group of products derived from NBTs would be evaluated according to the GMO Act.
This decision, the organisations say, will have widespread implications in South Africa and on South African innovators, as well as for trade of commodities that may contain products derived from NBTs.
“Asymmetric regulation may cause food insecurity and create significant barriers between South Africa and its trading partners. The current regulatory approach for NBTs will also discourage the development and uptake of the technology by all actors in the South African innovation and research space, including South African-owned seed companies, public and academic sector research organisations and small to medium-sized innovation enterprises,” the organisations explain.
To this end, the agriculture industry in November last year lodged an appeal under Section 19 of the GMO Act, particularly in support of the South African bioeconomy and local innovation.
In the appeal, industry partners of Agbiz suggested that South Africa proactively promote science-based regulation for products derived from NBTs.
Agbiz affirms that the broader agricultural value chain is committed to engaging in this process in good faith and to provide more detail to substantiate the points stipulated in the appeal.
Agbiz is also open to joint action with the department and the executive council of the GMO Act to remove any deemed obstacles and to facilitate effective, efficient, and evidence-based regulation of products derived from NBTs.
“The South African regulator’s interpretation of the GMO definition goes against the widely accepted principle that NBTs should not be regulated differently if they are identical to, or indistinguishable from, products that could have been obtained naturally or through conventional breeding methods.
“This principle is upheld even in countries that use the living modified organisms definition of the Cartagena Protocol on Biosafety, that are party to the protocol, such as South Africa,” the organisations state.
Because it would be nearly impossible to ascertain or uniquely identify whether genetic changes have been created by conventional breeding, random mutation or an approach considered to be an NBT, it would be difficult to classify and test new products, they argue.
They add that this will create unsurmountable challenges for the reliable enforcement of any possible asynchronous decisions among trading partners, as it is not likely that a comprehensive list of products in the global supply chain that has been developed using certain NBTs, will be available.
This decision will risk the ability of South African farmers to access the latest innovative technologies that could further enable them to sustainably produce food with minimal environmental impact, as well as denying consumers access to better end-products, the organisations lament.
They add that it is also important to consider that companies that wish to supply products derived from NBTs in South Africa will have to incur additional costs to access the South African market.
At worst, international suppliers may bypass South Africa owing to time delays and additional regulatory and registration costs. There is also a significant reputational risk for companies if their products are deemed GMOs in South Africa while the very same products are not deemed GMOs in the rest of the world.
This may result in domestic value chains only having access to outdated technology.
As agricultural challenges continue to grow in the face of climate change, increased pest and disease pressure, and a growing global population, it is imperative that innovative technology, such as NBTs, be part of the solution to help meet national commitments in terms of food security, climate mitigation and sustainability goals.
“Our agricultural sector must continue to remain competitive in the international playing field.
“While we differ from the decision regarding the regulatory approach for NBTs in South Africa, Sansor and the broader industry remain committed to engaging with the relevant decision-makers and government departments to create a regulatory environment that promotes innovation and competitiveness, while addressing any potential risks in an evidence-based manner.
“In doing so, the industry will bring these concerns to the attention of decision-makers when the decision on NBT regulation is being reviewed. As an industry collective we view the department and all relevant regulators as critical partners in this process and look forward to working closely to find a mutually acceptable solution,” Sansor concludes.