EU gene-editing legislation - ongoing debate
MPIPZ provides feedback to the initiative of the European Commission on 'Legislation for plants produced by certain new genomic techniques’
The Max Planck Institute for Plant Breeding Research (MPIPZ) investigates fundamental molecular processes in model plant species with the aim of developing efficient breeding techniques and environmentally sound plant protection strategies for crops. The MPIPZ attracts scientists from around the world and plays a major role in plant science at both national and international level.
We consider it as our responsibility as scientists to provide information on new genomic methods in order to build trust in science and new technologies.
The MPIPZ considers the current EU legislation on GMOs to be outdated and to no longer reflect current scientific knowledge. We are not aware of any science-based evidence that current methods of genome editing, such as CRISPR/Cas9, should be regulated differently from chemically or radiation-induced mutagenesis or spontaneously occurring mutations. We propose that genome editing methods should be treated in the same way as other methods of mutagenesis and be exempt from regulation. The treatment of gene editing contradicts open science which is seen by UNESCO as a key instrument for achieving the UN 2030 agenda on sustainable development (https://en.unesco.org/science-sustainable-future/open-science/recommendation). We therefore call for a revision and adaptation of the legislation to reflect the current state of scientific knowledge, represented by numerous statements by academies of sciences and professional societies worldwide (German National Academy of Sciences Leopoldina, ISBN: 978-3-8047-4064-8).
We would like to present our science-based positions on two frequently expressed concerns:
i) Non-retrievability: Concerns are that mutations generated by genome editing cannot be distinguished from spontaneous mutations that occur in nature and their origin cannot be identified or retrieved. As long as the mutations generated by genome editing are variants of genes that also occur in nature and therefore could be introduced into cultivated plants by classical methods, or are mutations that could also be produced in this form by non-regulated methods of mutagenesis, we do not consider the argument of "non-retrievability" significant. Either such gene variants already exist in nature or they can originate spontaneously at any time. Genome editing only introduces this genetic variation into cultivated plants and thereby makes new genetic variation usable for the breeding process. In this way, breeding of new crop varieties and also de novo domestication of novel crops can be accelerated, and chemical pesticides can be replaced by environmentally benign disease resistance genes. We therefore believe that the "non-retrievability" argument contradicts the objectives of the European Green Deal and prevents sustainability goals in agriculture from being achieved as quickly as possible.
ii) Precautionary principle: It should be borne in mind that inaction can also have negative consequences. Given the urgency of food security, the global threat of climate change and biodiversity loss, we must use all available tools of genomic techniques to reverse the consequences. Regulation of genome editing methods according to current legislation has significant negative consequences. It prevents the rapid adaptation of crop varieties to the effects of human-induced climate change, prevents increasing sustainability through genetically-mediated resistance to pests, leads to further market concentration within the plant breeding industry and prevents research on the role of gene variants in adaptation to different environmental conditions. These are only a few examples from a plethora of negative consequences. We believe that the "precautionary principle" is being misused to discredit and undermine arguments based on facts and scientific evidence.
We emphasize that current regulations on genome editing in Europe significantly limit the competitiveness and innovative power of European research and agriculture.
George Coupland, Raphael Mercier, Paul Schulze-Lefert, Miltos Tsiantis