PLANT SCIENCE HORTICULTURE ANIMAL SCIENCE
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Supplementary Report from the Danish Working Group on the Co-existence of
Genetically Modifi ed Crops with Conventional and Organic Crops
Update of the 2003 Report
Karl Tolstrup, Sven Bode Andersen, Birte Boelt, Morten Gylling, Preben Bach Holm, Gösta Kjellsson, Svend Pedersen, Hanne Østergård, Søren A. Mikkelsen
SU M M A R Y
This Supplementary Report on co-existence of genetically modifi ed crops with conventional and organic crops comprises an update of “the 2003 Report” authored by the same expert group. The primary conclusions of the 2003 Report are unchanged, i.e. that co-existence between GM crops, conventional and organic crops is possible for the vast majority of crops under the given assumptions and with the suggested measures. However, the Supplementary Report only evaluates the co-existence for production crops since threshold values for adventitious GM presence in seed remain to be decided at the EU level.
For maize, beet and potatoes, the Working Group proposes reduced separation distances as compared to the 2003 Report, and for a range of other crops the Working Group has made minor adjustments. For forage and amenity grasses and for grassland legumes the Working Group still fi nds the knowledge basis insuffi cient for establishing measures to ensure co-existence.
Compared to the 2003 Report, separate measures have in general not been proposed for conventional and organic crops keeping in line with the EU Commission’s guidelines on co-existence.
The Working Group recommends that a monitoring, research and development programme addressing co-existence under Danish fi eld conditions should be initiated in order to maintain and further develop the national scientifi c competence within the fi eld of co-existence.
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A A R H U S U N I V E R S I T E T
Facult y of Agricultural Sciences
DJF PLANT SCIENCE NO. 131 • AUGUST 2007
The reports primarily contain re- search results and trial statements aimed at Danish Conditions. Also, the reports describe larger completed research projects or act as an appen- dix at meetings and conferences. The reports are published in the series:
Plant Science, Animal Science and Horticulture.
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Prepared by the Working Group:
Karl Tolstrup, University of Aarhus, Faculty of Agricultural Sciences (DJF) Sven Bode Andersen, University of Copenhagen, Faculty of Life Sciences (LIFE) Birte Boelt, University of Aarhus, Faculty of Agricultural Sciences (DJF)
Morten Gylling, University of Copenhagen, Institute of Food and Resource Economics, Faculty of Life Sciences (LIFE)
Preben Bach Holm, University of Aarhus, Faculty of Agricultural Sciences (DJF)
Gösta Kjellsson, National Environmental Research Institute, University of Aarhus (NERI) Svend Pedersen, The Danish Plant Directorate
Hanne Østergård, Risø National Laboratory, Technical University of Denmark (Risø, DTU) Søren A. Mikkelsen, University of Aarhus, Faculty of Agricultural Sciences (DJF)
Supplementary Report from the Danish Working Group on the Co-existence of
Genetically Modified Crops with Conventional and Organic Crops
Update of the 2003 Report
DJ F P L A N T S C I E N C E N O. 131 • AU G U S T 20 07
This Supplementary Report is a translation of the Danish report ”Supplerende rapport fra Udredningsgruppen vedrørende sameksistens mellem genetisk modificerede, konventionelle og økologiske afgrøder” from April 2007.
The Danish Plant Directorate asked the Working Group to prepare the Supplementary Report as an update of its 2003 Report and supported the work financially.
Indhold
1 CONCLUSIONS 5
2 SUMMARY 7
2.1 BACKGROUND 7
2.2 ASSUMPTIONS FOR THE CROP SPECIFIC ASSESSMENTS 9
2.3 CROPS– CHANGES AND NEW KNOWLEDGE 10
2.4 RESEARCH NEEDS 15
2.5 ECONOMIC ASPECTS OF CO-EXISTENCE 15
3 INTRODUCTION 21
4 PRODUCTION OF GM CROPS AND CO-EXISTENCE 23
4.1 PRODUCTION OF GM CROPS GLOBALLY 23
4.1.1 Regulations on co-existence outside the EU 25
4.2 PRODUCTION OF GM CROPS IN THE EU 26
4.3 CO-EXISTENCE IN THE EU 28
4.3.1 Administratively 28
4.3.2 European conferences and projects on co-existence 34
4.4 DEVELOPMENTS IN DENMARK 36
4.4.1 Administration 36
4.4.2 Danish research projects in relation to co-existence 37
5 SCIENTIFIC REVIEW, CROPS 41
5.1 PRECONDITIONS FOR CO-EXISTENCE 41
5.1.1 GM content in the harvested product 41
5.1.2 Threshold value for seed 42
5.1.3 Threshold values for adventitious GM presence
in organic farming 42 5.1.4 Cultivation pattern/structural development in primary
crop production 43
5.1.5 Summary of preconditions 44
5.2 CROPS– CHANGES AND NEW KNOWLEDGE 46
5.2.1 Oilseed rape 46
5.2.2 Maize 53
5.2.3 Beet 60
5.2.4 Potatoes 63
5.2.5 Barley, wheat and oats 67
5.2.6 Triticale 71
5.2.7 Rye 73
5.2.8 Forage and amenity grasses 75
5.2.9 Grassland legumes 79
5.2.10 Field peas 82
5.2.11 Field bean and lupin 84
5.2.12 Vegetables, seed production 87
6 ECONOMIC ASPECTS OF CO-EXISTENCE 89
6.1 NEW KNOWLEDGE 89
6.2 DANISH CONDITIONS 89
7 RESEARCH NEEDS 93
8 REFERENCES 95
9 APPENDIX 103
1 CONCLUSIONS
This Supplementary Report from the Working Group consists of an update of the ”2003 Report”
containing new knowledge that has appeared which requires revisions of the scientific assessments of the Working Group.
The primary conclusions of the 2003 Report are retained, i.e. that co-existence between GM crops, conventional and organic crops is possible for the vast majority of crops under the given
assumptions and with the suggested measures.
As a result of the unclarified situation concerning the establishment of threshold values for adventitious presence of GM material in seed, the specific suggestions for measures in this Supplementary Report include only factors relating to production crops.
For maize, beet and potatoes, which are included in the existing ministerial order on cultivation of GM crops in Denmark, the Working Group proposes reduced separation distances as compared to the 2003 Report.
For other crops, that are barley, wheat, oats, triticale, rye, lupin, field bean and peas, the Working Group has made minor adjustments compared with the measures proposed in the 2003 Report.
For fully fertile oilseed rape slightly extended measures are proposed in comparison to the 2003 Report.
For forage and amenity grasses and grassland legumes the Working Group is still unable to find a knowledge basis sufficient for establishing measures to ensure co-existence.
Compared with the 2003 Report, the assumptions in the Supplementary Report are changed for two areas.
First, in keeping with the EU Commission’s guidelines on co-existence there is no distinction between conventional and organic crops. Thus the threshold value of 0.9% for adventitious GM presence, below which the product does not have to be labelled, applies to both conventional and organic products, and the suggested measures are thus – apart from oilseed rape – the same for conventional and organic crops.
Second, the measures are determined on the assumption that the adventitious content of GM material must be below the set threshold value of 0.9% in the harvested product at “the farm gate”.
In the present Supplementary report there is no distinction between different scenarios for the production of GM crops, but it is assumed that the area of a given GM crop does not become very extensive and does not exceed 50% of the total area of that crop.
The Working Group would like to point out that its work includes scientific assessments and
opinions that are based on the most recent available knowledge. These assessments and opinions are naturally subject to a varying degree of uncertainty.
The Working Group would like to recommend that the Danish qualifications in the area of co- existence should be retained and extended. This means a continued international orientation of the Danish work. It also means a distinct need for increasing the Danish knowledge basis. We therefore recommend that a monitoring, research and development programme should be initiated. This will enable measurements under practical growing conditions so that knowledge building on co-
existence can form the basis of further development and scientific qualification of the Danish model for co-existence.
2 SUMMARY
2.1 Background
The world’s first act on co-existence – the Act on Cultivation etc. of Genetically Modified Crops1 – was passed by the Folketing on 9 June 2004. It was followed by the Ministerial order on cultivation etc. of genetically modified crops2, which became effective on 9 April 2005 and by the Ministerial order on compensation3, which became effective on 17 December 2005.
In connection with the passing of the act, a political agreement was concluded between the Danish Social Democrats, the Danish Socialist People’s Party, the Danish Social-Liberal Party and the Government. According to this agreement the Act on co-existence must be re-evaluated 2 years after it became effective. The act became effective when the ministerial order on cultivation mentioned above was issued, which means that this re-evaluation of the Danish model for co- existence must be available by April 2007.
The Danish Plant Directorate, which is responsible for the re-evaluation, asked the Working Group to make an update of the group’s report from November 2003: ”Report from the Danish Working Group on the Co-existence of Genetically Modified Crops with Conventional and Organic Crops”
(Tolstrupet al., 2003), which from now on is called “the 2003 Report”.
The Working Group was asked to look at the assumptions underlying the Working Group’s proposals for measures to ensure the possibility of co-existence for the individual crops. They were especially asked to determine whether the assumptions had changed for those crops for which the Working Group had been unable to identify measures that would ensure co-existence. This applied to seed production of hybrid oilseed rape and production of grasses and clover.
Production of GM crops globally
In 2006 approx. 102 million ha of GM crops were grown globally, which is an increase of 71%
since 2002. More than half of the world’s production of GM crops takes place in the USA, followed by Argentina, Brazil and Canada. Production is also considerable in various other countries in South America and in China, India and South Africa.
Production of GM crops in the EU
The only GM crop that so far has been grown in the EU is insect resistant maize. It has been grown mostly in Spain where it covered 60,000 ha or approx. 15% of the maize production in 2006.
However, in the past few years, production of GM maize was also begun in France, the Czech Republic, Portugal and Germany, and the production is expected to increase in these countries.
1 Act no. 436 of 9 June 2004 on Cultivation etc. of Genetically Modified Crops
2 Ministerial order no. 220 of 31 March 2005 on cultivation etc. of genetically modified crops
3 Ministerial order no. 1170 of 7 December 2005 on compensation of losses due to certain occurrences of genetically modified material
This insect resistant GM maize is however of no interest to Danish growing conditions as the insect in question is not a pest problem here.
The European experimental releases and applications for marketing approval of GM plants give an idea of what is coming. For the whole period from 1996 to 2006, maize, oilseed rape, beet and potatoes are, as in 2003, dominant in field trials. In the period from 2003 to 2006 maize and secondly potatoes are the dominant GM crops in trials followed by oilseed rape, wheat and beet with a smaller number of trials. A large number of these experimental releases possess GM herbicide tolerance or insect resistance, but a range of other characteristics is also included, and an increasing number of plant lines possess two or three inserted characteristics.
Co-existence in the EU
In 2003 the EU Commission published a recommendation to the EU member states on guidelines for the development of national strategies and best practices for the co-existence between GM crops and conventional and organic crops. The recommendation contains many of the elements included in the 2003 Report, and the recommendation has since then provided the background for the development of national regulations on co-existence in several EU countries.
Since 2005 the EU network COEX-NET, with the Danish Plant Directorate as the Danish representative, has coordinated and exchanged information on the questions of co-existence between the EU member states.
At the beginning of 2007, seven EU member states – Denmark, Germany, Portugal, Austria, the Czech Republic, Slovakia and Hungary – have passed national legislation on co-existence. Most other countries have either notified drafts for co-existence legislation or are in the process of preparing regulation.
Most countries provide proposals for separation distances for a number of crops. There is a large variation among the member states as regards the separation distances that are either passed or drafted. The differences for example for maize are striking and vary from 25 m in the Netherlands to 800 m in Luxemburg. Furthermore, a few countries have made rules regarding cropping intervals, i.e. the number of years that must pass from the production of a GM crop until a similar conventional or organic crop may be grown in the same field again.
Threshold values for GM content in seed
When the Working Group published the 2003 Report, proposals were brought forward in the EU’s Standing Committee on Seeds and Propagation Material on threshold values for adventitious GM presence in seed, below which the seed does not have to be labelled with GM content. The threshold values were 0.3%, 0.5% and 0.7% depending on crop.
The question of establishing threshold values for seed was transferred to the EU Commission’s Directorate-General for the Environment in October 2003.
No proposal for threshold values has been made as yet by the Directorate-General. Until this is the case, the European Commission has clarified that all seed with a content of GMO above the practical detection limit of 0.1% must be labelled if the GMO present is approved for cultivation. In these cases the co-existence regulations will apply to the crop established from such seed lots. In case the GMO present is not approved for cultivation such seed lots must be discarded.
Threshold values for adventitious content in organic farming
According to the regulations on organic farming GM material must not be used.
However, the EU Commission’s guidelines on co-existence from 2003 state that the threshold values for labelling of foods and feed laid down in Regulation 1829/2003 – i.e. an adventitious content of maximum 0.9% – apply to both conventional and organic farming.
In 2005 the EU Commission submitted a proposal for regulation on organic production and
labelling of organic products. From this proposal it appears that the general threshold values for GM labelling will also apply to organic products. However, there is a possibility that specific threshold values for adventitious GM presence in organic seed may be laid down at some time.
2.2 Assumptions for the crop specific assessments
Structural development in Danish plant production
The considerable structural development in agriculture, which has been going on for many years, has continued since the 2003 Report and has resulted in larger and fewer but at the same time more specialised farms with larger fields. Thus the average farm size in Denmark grew from approx. 53 ha to approx. 58 ha in the period from 2002 to 2006.
The total organic area showed a slight fall and a stagnating tendency in this period. In 2002 the total organic areas constituted 6.1% of the cultivated land, whereas it constituted 5.6% of the cultivated land in 2006. There is a large concentration of organically cultivated land in South Jutland.
General assumptions
The following general assumptions underlie the Working Group’s new assessments aiming at ensuring co-existence:
¾ The threshold values for adventitious presence of GM in foods and feed of 0.9% apply – based on the EU Commission’s guidelines from 2003 on co-existence – to both
conventional and organic farming. Apart from oilseed rape the Working Group does not, as in the 2003 Report, find it necessary to distinguish between organic and conventional production regarding the measures that could be proposed to ensure co-existence for production crops.
¾ In the 2003 Report we assumed threshold values for adventitious presence in seed of 0.3
% and 0.5 % respectively, depending on crop. No final decision on these threshold values has been made as yet. The Working Group has therefore chosen to retain the assumptions of these threshold values for conventional seed, wherever this has been proposed, and – in contrast to the 2003 Report – also to assume that these threshold values apply to organic seed. These assumptions are used solely to propose measures ensuring co-existence for production crops. In the examination of the various crops the Working Group has also based its assessments on production crops being established by means of certified seed.
¾ In the 2003 Report the Working Group – with reference to a Danish translation of the EU Commission’s recommendation – assumed that the measures should ensure that
adventitious GM presence should be ”well” below the threshold value of 0.9% at ”farm gate”; i.e. up to the first point of sale or distribution. According to the authorised
translation, with which the Working Group is now familiar, the measures must ensure that
adventitious GM presence is below the threshold value of 0.9%, and the Working Group has based its work on the assumption that this applies at ”the farm gate”.
This supplementary report does not distinguish between different scenarios for cultivation of GM crops, but it is assumed that the extent of cultivation of a given GM crop does not become very extensive and does not exceed 50% of the crop area.
In its assessment of the possible measures for ensuring co-existence the Working Group has also assumed:
¾ ”good farming practice”, as described more closely in the 2003 Report, and has taken its starting point in:
¾ the existing Danish regulations on cultivation of certified seed
¾ the international and Danish reports, scientific papers, model analyses and case studies available up to the present day.
Because of the uncertainties regarding threshold values in seed the Working Group has only submitted proposals for measures concerning cultivation of production crops, and these are mentioned under the individual crops and in Table 2.1.
The Working Group has therefore in general not reassessed its original proposals for separation distances and cropping intervals between GM crops and seed crops (seed production) of the same species compared with the 2003 Report, and we therefore refer to this Evaluation concerning seed multiplication. However, it is emphasized that adventitious GM content in seed will be one of the major sources of GM dispersal.
For all crops there will be a continuous need for future reassessment of measures in parallel with developments in scientific knowledge and practical experience.
2.3 Crops – changes and new knowledge
Oilseed rape
The oilseed rape area, mainly winter oilseed rape, has increased considerably since 2002, and oilseed rape is grown on approx. 5% of cultivated land. It is expected that oilseed rape areas may double in the next few years. Organic crops are only 0.6% of the total oilseed rape area.
At present, there is no commercial production of GM oilseed rape in the EU, but a few herbicide tolerant lines are approved for import and processing. Current research work includes studies of the development of GM oilseed rape for bioenergy purposes.
Some new knowledge on oilseed rape of relevance to co-existence is available. The general conclusion is that with suitable separation distances the contribution of pollen dispersal to adventitious GM presence can be kept at a low level. However, management of seed shedding and seed dispersal is difficult and requires strict measures. As results from different trials and models vary depending on the local conditions and assumptions, future adjustments of measures are likely to be needed to fit future requirements for growing of GM oilseed rape.
There are no changes to the proposed separation distances of 150 m to production fields for fully fertile winter and spring oilseed rape compared with the 2003 Report. As a new compulsory measure we propose a distance of 50 m to other major volunteer populations of oilseed rape such as in some set-aside fields.
The new knowledge has confirmed that volunteers from the seed bank are very important for adventitious presence in the field. There is much uncertainty as to how the occurrence of volunteers depends on dormancy, soil treatment and the efficacy of the control. As for cropping intervals, the proposed intervals of 8 and 12 years are maintained for the production of conventional and organic crops respectively, as there are not the same possibilities in organic farming for controlling volunteers and closely related weeds as in conventional farming.
In addition we propose a number of compulsory measures to limit seed dispersal and control volunteers (see Table 2.1).
GM dispersal through seed is considered to be a significant factor, and a more thorough testing and monitoring of certified seed will therefore be needed.
More research, especially under practical Danish cropping conditions, is required on seed dispersal and varietal purity, pollen dispersal in connection with the growing of hybrids, the importance of honeybees for pollen dispersal and the importance of harvesting methods and field sizes.
Specifically, information on winter oilseed rape is needed as most details so far have come from spring oilseed rape. Finally, dispersal from future GM oilseed rape fields should be monitored using DNA markers.
Maize
Maize is primarily grown in Jutland and Funen. Since 2002 the cropping area has grown from 97,000 to 138,000 ha and is approx. 5% of the cultivated area, but is locally up to approx. 20% of the cropped land. Maize is still used almost exclusively for silage for which the whole plant is used.
There is no production of maize seed in Denmark.
In 1999 and 2000 there were yield and demonstration trials in Denmark with herbicide tolerant GM maize. In 2007 a number of demonstration trials are planned, also with herbicide tolerant maize.
In the EU the number of field trials with GM maize is increasing fast. For a number of years insect resistant maize has been grown in Spain where it now accounts for about 15% of the total maize growing area, and this type now exists in several EU countries. It is to be expected that Danish agriculture will show an interest in herbicide tolerant GM maize varieties.
Since 2003 a very large number of studies have been carried out of the dispersal of maize pollen to neighbouring fields. We propose that the separation distance of 200 m from a GM maize field to a conventional maize field should be reduced to 150 m due to new knowledge of maize co-existence under European conditions. We further propose that the existing regulations on separation distances should be supplemented by regulations on buffer zones as an alternative or as a combination possibility. In this case, a buffer zone is a zone sown with conventional maize between the GM maize field and non-GM neighbouring fields that are cultivated at the same time as the GM maize.
We especially lack knowledge of the dispersal of maize pollen under Danish conditions, including the effect of buffer zones and studies of the effect of different field sizes and shapes. We propose that a Danish research project should be initiated to establish the knowledge and experience basis needed to handle co-existence in areas with intensive maize growing.
Beet
Denmark has experienced a considerable fall in the growing of both sugar beet and fodder beet, and the growing of beet is now 1.6% of the cultivated area, of which 0.05% is organic. Production of beet seed primarily takes place in southern Europe.
No GM beet is approved for production in the EU, and marketing of GM fodder and sugar beet developed in Denmark has been abandoned. Growing of GM beet is not expected within the next 5- 10 years.
The greatest risk of dispersal is still considered to be through the presence of GM seeds in commercial seed. Control of bolters and weed beet can minimise dispersal between crops. For production crops we propose that the separation distance from GM crops should be reduced from 50 m to 10 m, and a 3-year cropping interval is still considered to protect against germination in a new crop.
We lack knowledge of annual weed beet in Denmark, the importance of the pollination system and genetic conditions for the dispersal risk as well as of the importance of field size and soil
preparation for gene dispersal.
Potatoes
The growing of potatoes in Denmark, which is concentrated in Middle and West Jutland, is almost unchanged since 2002 and is approx. 1.4% of the cultivated area. Of this, organic growing accounts for 2.5% of total production.
GM potatoes for the starch industry, which are likely to be suitable for growing in Denmark, are expected to be grown in the EU within the next couple of years. In addition, some trial releases with late blight resistant potatoes are expected to be of interest for growing in Denmark.
For production potatoes we propose that the separation distance from a GM field to a conventional or an organic field, respectively, should be reduced from 20 to 10 m due to present knowledge in this area. We propose that the separation distance for non-flowering potatoes of 2 m, a cropping interval of 3 years and other recommended measures should not be changed (see Table 2.1).
Knowledge is needed of strategies for managing over wintering potatoes and monitoring of over wintering of GM potatoes will be required due to the present mild winters.
Barley, wheat and oats
The total areas in Denmark of these three cereals are almost unchanged since 2002, and they constitute approx. 52% of the total cultivated area, of which the organic area is approx. 2.2%.
There is no experience as yet of cultivation of GM types of these cereals in Denmark, but several types of GM wheat and barley have been developed. There are several trial releases in Europe of GM wheat and GM barley with different characteristics. In North America, a glyphosate tolerant
GM wheat was approved in 2004, but it has not been marketed (AGBIOS, 2006). There is no actual experience with commercial cultivation of GM cereals, only results from experimental releases.
Based on the most recent knowledge in this area, we propose that when GM barley, wheat and oat crops are grown, a 1-metre isolation distance should be maintained to production fields with non- GM crops of the same species, which would correspond to a clear boundary.
We propose that the cropping interval after growing GM barley, wheat or oats to growing conventional or organic crops of the same species should remain unchanged, that is 1 year.
As these species have very little gene dispersal, managing the GM content in seed will be the most crucial factor to control gene dispersal from future GM cereal varieties.
Knowledge is needed of cross-pollination frequencies between barley, wheat and oat fields under Danish cropping conditions as well as better knowledge of volunteer problems.
Triticale
The Danish production of triticale, which primarily is for forage, especially takes place on sandy soils in West Jutland and in 2006 was approx. 1.1% of the cultivated area, of which approx. 14% is organic.
There is as yet no experience of growing GM triticale varieties in Europe or in the rest or the world, but GM types are being developed.
Triticale is more cross-pollinating than wheat, barley and oats. We propose that the separation distance of 20 m from a GM triticale field to a conventional or an organic production field should remain unchanged. This is similar to the separation distance used for multiplication of triticale seed.
We propose that the cropping interval after growing GM triticale to growing conventional or organic triticale should remain unchanged, that is 1 year.
Managing the GM content in seed will be the most important measure for co-existence for triticale.
There is a general lack of knowledge of cross-pollination frequencies and gene dispersal between triticale fields, and the problem of volunteers is incompletely examined under Danish growing conditions.
Rye
The growing of rye has been halved since 2002 and is now 0.9% of the cultivated area. Organic growing is almost unchanged and amounts to approx. 11% of this area.
To our knowledge no trial releases were carried out with GM rye.
The Working Group proposes that the separation distances proposed in the 2003 Report of 250 m for ordinary rye (not hybrids) and 500 m for rye hybrids are retained due to considerable uncertainty and limited experience of cross-pollination. We propose that the cropping interval should be 1 year, similar to other cereals.
There is still a lack of knowledge of the dispersal of rye pollen under Danish conditions and studies of the effect of different field sizes and shapes.
Forage and amenity grasses
Denmark has an internationally prominent position as a producer of grass seed, and grass is furthermore widespread in grazing fields and in uncultivated areas. In 2006, grass areas amounted to a total of approx. 26% of the total cultivated area, and 10% of the grass area was organic.
So far, there is only limited experience with GM grass (from the USA), and this experience together with the most recent knowledge in the area confirms that grasses have a high potential for gene dispersal both within and outside cultivated areas.
On the existing knowledge basis, it is still not possible to propose guidelines to ensure co-existence in grass in Denmark.
We lack knowledge of the extent of pollen dispersal between fields for different uses, of the extent of pollen dispersal from potential sources outside the field and of the extent of grass volunteers producing seeds in intermediate crops.
There is also a need for studying competitive parameters for various biological characteristics in grasses in order to be able to assess the dispersal efficacy of a given trait, both within and outside the cultivated areas.
Grassland legumes
Denmark has a prominent position as a producer of white clover seed, and in addition clover is widespread in grazing fields and in uncultivated areas. Areas of grassland legumes amounted to approx. 9% of the total cultivated area, and in 2006 the organic part of the areas amounted to 22%
of these areas. So far, there is no practical experience of GM clover.
Grassland legumes are insect-pollinated, and the pollen may be dispersed over large distances.
Furthermore, their seeds survive for a long time in the soil. Based on our present knowledge, it is still not possible to propose guidelines to ensure co-existence in clover.
There is a large need of increased knowledge of pollination biology, methods for reducing seed dispersal and of the competitive ability of GM traits, both within and outside the cultivated areas.
To maintain Denmark’s leading position as a producer of white clover seed, there is also a need for developing cropping systems that will ensure genetic purity in the production of clover seed.
Field pea
There has been a considerable reduction in the growing of peas, which now amounts to 0.6% of the cultivated area, of which 20% is grown organically.
No GM peas have yet been marketed worldwide, and they are not expected to be marketed within the next 5 years.
As only production crops are in question and as field pea is not considered a difficult crop in co- existence contexts, we propose that the separation distance should be reduced to 5 m and the cropping interval should be reduced to 1 year (see Table 2.1).
The major risk of GM dispersal of peas is still considered to be adventitious GM presence in seed.
By monitoring seed etc., it is expected that the GM presence can be maintained at low levels.
Field bean and lupin
In Denmark field bean and lupin are only grown in small areas. The species are of considerable interest to organic production, and a large part of the areas is organic.
No GM trial releases with these species are recorded as yet in Europe. GM types of blue lupin with an altered protein composition are being evaluated in Australia.
The proposal for ensuring co-existence is unchanged from the 2003 Report and is shown in Table 2.1.
Information is required on gene dispersal via pollen, seed dormancy and volunteers in order to develop management strategies.
2.4 Research needs
There are still crops for which the Working Group on the present basis of knowledge is not able to propose guidelines for co-existence.
In addition the guidelines proposed are largely based on evaluations of foreign investigations/results and hence the cultivation practice, management etc. may differ from Danish agriculture.
In the examination of the crops, we identify areas where we lack knowledge of co-existence under Danish conditions for both production and seed crops. Crop specific needs for supplementary knowledge are focused on the following three main themes:
¾ Seed dispersal and control of volunteers
¾ Pollen dispersal, the effect of buffer zones, as well as field size and shape
¾ Gene dispersal from the cultivated areas.
The national research effort in this area is still very limited and there is a distinct need to increase the Danish knowledge of the biology of gene dispersal in crops of major importance in Danish agriculture. We therefore recommend that a monitoring, research and development programme should be initiated so that measurements made under practical growing conditions and knowledge building concerning co-existence can form the basis of further development and scientific qualification of the Danish model for co-existence in preparation for the extensive growing of GM crops.
2.5 Economic aspects of co-existence
The provisions in the Danish Act on Co-existence of a GM cultivation fee of 100 DKK/ha and participation in the course on GM production impose some ”fixed” costs on the GM grower, which must be added to the costs of co-existence estimated previously. However, it is our assessment that
these costs will not constitute a barrier to GM production. The cultivation fee can be considered an insurance premium against unintended events.
Further analyses are needed of the total costs of co-existence based on practical or near practical experience with growing GM crops.
Table 2.1. Summary of crop specific measures proposed to ensure GM co-existence for production crops1.
GM crop
Separation distances2 (to similar crop
species)
Cropping interval3
Proposed compulsory measures4
Additional possible measures
Oilseed rape
(fully fertile) 150 m
8 years 12 years5
Control of volunteers in the previous GM field, adjacent areas around the field and on transport routes within the entire farm
Cleaning of machinery and transport equipment as for certified seed after GM production and before non- GM production
Transport of GM oilseed rape in seed-tight containers Minimal tillage after GM oilseed rape crops A distance of 50 m to large oilseed rape volunteer populations in for example set-aside fields
Control of related weeds in the field and adjacent areas Consideration for field size and shape Choice of crop rotation that reduces the content of GM seeds in the seed bank Separate harvesting of field margins in non-GM
neighbouring fields
Maize 150 m 0 years
Buffer zone as an alternative to or in combination with separation distances6 Cleaning of jointly used machinery and transport equipment after GM production and before non- GM production
Potatoes
10 m 2 m7
3 years
Monitoring and control of volunteers and ground- keepers
Cleaning of jointly used machinery and transport equipment after GM production and before non- GM production
Beet 10 m 3 years
Monitoring. Control of bolters/weed beets Cleaning of jointly used machinery and transport equipment after GM production and before non- GM production
Barley, wheat
and oats 1 m 1 year
Control of volunteers Cleaning of machinery and transport equipment as for certified seed after GM production and before non- GM production
Triticale 20 m 1 year
Control of volunteers Cleaning of machinery and transport equipment as for certified seed after GM production and before non- GM production
Rye/
Rye hybrids
250 m/
500 m 1 year
Control of volunteers Cleaning of machinery and transport equipment as for certified seed after GM production and before non- GM production
Forage and amenity grasses
No knowledge basis for proposing measures that can ensure co-existence
- -
Grassland legumes
No knowledge basis for proposing measures that can ensure co-existence
- -
Field pea 5 m 1 year
Cleaning of machinery and transport equipment as for certified seed after GM production and before non- GM production
Field bean
Lupin 400 m 2 years
Control of volunteers Cleaning of machinery and transport equipment as for certified seed after GM production and before non- GM production
Control of naturalised populations8
1Assumption: The threshold value for labelling at adventitious GM content in a conventional or organic crop grown for food or feed production is 0.9%.
2The minimum distance from a GM crop to a non-GM cross-pollinating production crop. Concerning the distances to non-GM cross-pollinating seed crops, please see the 2003 Report.
3Cropping interval: Years with other crops in the field from growing a GM crop or a crop with a considerable GM presence until non-GM growing of the same crop can take place in the same field. In the setting of the cropping interval, it is assumed that volunteers are controlled and monitored in the intervening period.
4Specific testing of seed for adventitious GM presence is generally an important measure for all crops for which adventitious GM presence is likely.
5Cropping interval after GM production and before organic production of the same crop in the field is allowed.
6A buffer zone is in this case a zone sown with non-GM maize between the GM maize field and neighbouring non-GM maize fields cultivated at the same time as the GM maize.
7If the genetically modified potato variety is of a type characterised by not developing flowers or by having male- sterile flowers, the distance can be reduced to 2 m, as stated.
8Naturalised populations are populations originating from cultivated plants that are established outside the agricultural area.
3 INTRODUCTION
The world’s first act on co-existence – the Act on Cultivation etc. of Genetically Modified Crops4 – was passed by the Folketing on 9 June 2004. It was followed by the Ministerial order on cultivation etc. of genetically modified crops5, which became effective on 9 April 2005 and by the Ministerial order on compensation6, which became effective on 17 December 2005.
In connection with the passing of the act, a political agreement was concluded between the Danish Social Democrats, the Danish Socialist People’s Party, the Danish Social-Liberal Party and the Government. According to this agreement “… a first evaluation of the Danish model shall take place 2 years after the act on cultivation etc of genetically modified crops became effective”.
As the act became effective when the ministerial order on cultivation mentioned above was issued, this means that the re-evaluation of the Danish model for co-existence must be available by April 2007.
The Danish Plant Directorate is responsible for the evaluation and has asked the Working Group to make an update of its report from August 2003: ”Report from the Danish Working Group on the Co-existence of Genetically Modified Crops with Conventional and Organic Crops” (Tolstrup et al., 2003), which from now on is called “the 2003 Report”.
The 2003 Report attracted international attention and resulted in many international contacts. In its update the Working Group chose to build on this international orientation. As was the case with the 2003 Report, the update begins with a conclusion followed by a summary also including a table summarising measures for ensuring co-existence in production crops. In section 4, the Supplement contains a review of developments since 2003, both nationally and internationally with emphasis on developments in the EU. Section 5 includes both a general review of changes in crop production and preconditions, and a review of the individual crops. Section 6 consists of reflections on economic aspects and section 7 a summary of future research needs.
It proved possible to reassemble the original Working Group, ensuring continuity from the original work and good connections with the Danish research organisations that deal with GM crops and co- existence. Furthermore, this also ensures connection with relevant international research
developments.
The original Contact Group was invited to participate as before. Various user interest groups were consulted through dialogue with the Contact Group. During the process of updating the report the Working Group had three meetings with the Contact Group.
4 Act. No. 436 of 9 June 2004 on Cultivation etc. of Genetically Modified Crops
5 Ministerial order no. 220 of 31 March 2005 on cultivation etc. of genetically modified crops
6 Ministerial order no. 1170 of 7 December 2005 on compensation of losses due to certain occurrences of genetically modified material
The Working Group chose to publish the results of the update as a separate report in the form of a supplement to the original evaluation. Our intention is that the supplement can be used as a stand- alone document independently of the first report.
As in the 2003 Report, the update only covers co-existence to the first stage of distribution from the farm, and it covers only outdoor crops.
As mentioned above, the present report is an update of the 2003 Report. The update includes new knowledge that has appeared since the original report by the Working Group in 2003. For a comprehensive review of all the scientific issues including dispersal routes and measures, we also refer readers to the original 2003 Report.
4 PRODUCTION OF GM CROPS AND CO- EXISTENCE
4.1 Production of GM crops globally
In the period from the Working Group’s first report in 2003 until today, the global areas cultivated with GM crops have continued to increase. The development in cultivated area since commercial production of GM crops began in 1996 is shown in Figure 4.1.
Figure 4.1. The development in the total global area with GM crops for the period 1996-2006 and the development in production in industrial and developing countries respectively during this period (Source: C. James, ISAAA, 2006).
In 2006, GM crops were grown on 102 million ha globally, which is an increase of 71% since 2002.
From 2005 to 2006 the increase in the global area of GM crops was 13%.
GM crops were grown in 22 countries in 2006. The increase took place in both industrial and developing countries.
The area distribution of GM crops in countries outside the EU and for the EU in total is shown in Table 4.1. The USA still has the largest GM crop area and more than half the GM production takes place in this country. There is also a considerable production in Brazil and other countries in South America, as well as in Canada, India and China.
Table 4.1. Global GM crop areas in 2006. The crops are listed in descending order based on the extent of cultivation.
Country Area (ha) GM crops
USA 54.6m Soya, maize, cotton, oilseed rape, courgette, papaya, lucerne
Argentina 18.0m Soya, maize, cotton
Brazil 11.5m Soya
Canada 6.1m Oilseed rape, maize, soya
India 3.8m Cotton
China 3.5m Cotton
Paraguay 2.0m Soya
South Africa 1.4m Maize, soya, cotton
Uruguay 400,000 Soya, maize
The Philippines 200,000 Maize
Australia 200,000 Cotton
Romania 115,000 Soya
The EU 68,000 Maize
Mexico 60,000 Cotton, soya
Colombia 30,000 Cotton
Iran 4,000 Rice
Honduras 2,000 Maize
Sources: 1. James, C., 2006 and 2. TransGen Wissenschaftskommunikation, 2007.
GM crops on the way
According to James (2006) 539 approvals of GM plant lines have been issued in 51 different countries since 1996. Plant lines of soya, cotton, maize and oilseed rape with herbicide or insect resistance developed by the companies Monsanto, Syngenta, Dupont/Pioneer, Bayer Crop Science and Dow AgroSciences are by far the most dominant. In a number of cases herbicide resistance and insect resistance are combined, as are several different transgenes for insect resistance.
At present, the development of new GM crops seems to concentrate on five main groups:
¾ Production of GM plant lines with improved characteristics concerning human nutrition, for example a higher content of minerals and vitamins and healthier vegetable oils. Soya beans with an improved composition of oil are being produced in the USA, and the time frame for commercial growing of plants with improved nutritional composition is thought to be about 5 years.
¾ Forage crops with a better nutritional composition, for example better protein, oil or starch composition or improved bioavailability of phosphate. Maize with an improved composition of amino acids is being produced in the USA, and the time frame for commercial growing of crops with other characteristics is supposed to be about 5 years.
¾ Plants with a changed biochemical composition for industrial purposes, for example potatoes with a changed starch composition. The latter is expected to be produced within a couple of years.
¾ Drought tolerant plants, for example drought tolerant maize, which is expected to be marketed 2010-2011.
¾ Plant lines that synthesise enzymes, antibodies, vaccines or substances for diagnostic purposes. Plants that produce insulin are being approved, and it is expected that plants that produce antibodies will be marketed within a few years.
In the industrialised part of the world, introduction of these characteristics in soya, maize, oilseed rape and potatoes is the primary goal. In the developing part of the world, primarily China and India, a larger range of plant species is in focus, and it must be assumed that these two countries in particular will become major players within the development of GM crops, also on the global stage, in the years to come.
Within the last few years there has been increased interest in developing crops with a larger biomass as well as improved characteristics for biodiesel and bioethanol production. At present, the EU is considering an application for approval of a maize line that produces a heat stable Į-amylase. It is expected that these developments will accelerate in years to come in response to international demands for reductions of CO2 and wishes for security of supplies of liquid fuels for transport.
These developments may have marked effects on agricultural production and choice of crops in both industrial and developing countries, including on the need for GM energy crops.
4.1.1 Regulations on co-existence outside the EU
Official regulations on co-existence based on legislation are found almost exclusively in the EU. As the establishment of regulations on co-existence is closely related to the existence of regulations on labelling products with GM content, labelling regulations is the starting point for countries developing regulations on co-existence.
The non-EU countries of Norway and Switzerland have introduced the same threshold value for adventitious presence of 0.9% as the EU. Norway expects to have a proposal for regulations on co- existence ready in 2007.
Outside Europe, there are regulations on GM labelling in countries like Australia, New Zealand, Japan, Thailand, Taiwan and South Korea.
The Working Group knows of regulations on co-existence existing or about to be introduced in certain Japanese provinces.
In Argentina and Brazil there are no regulations on co-existence and labelling based on legislation.
However, in some regions GM crops are not grown, and there are different certified non-GM soya products based on private identity preservation and traceability programmes.
4.2 Production of GM crops in the EU
The only GM crop commercially cultivated in the EU is a GM maize. The distribution of GM maize areas within the EU in 2006 is shown in Table 4.2.
Table 4.2. The distribution of GM maize areas in the EU in 2006. The cultivated maize areas are all with the insect resistant type MON810.
Country Area (ha) GM crop
Spain 60,000 Maize
France 5,000 Maize
The Czech Republic 1,290 Maize
Portugal 1,250 Maize
Germany 950 Maize
Slovakia 30 Maize
Only in Spain is GM maize grown on a considerable area. The maize is insect resistant (Bt) and has since the beginning of 1998 been grown to an increasing extent. In 2004 the GM maize area in Spain was 58,000 ha, but because of drought in the spring of 2005 there was a general decrease in the maize cultivation, and the GM maize area fell to 48,000 ha. In 2006 the GM maize area rose again to 60,000 ha, which amounted to approx. 15% of the country’s total maize area in 2006.
In 2005 GM maize was grown on small areas in Portugal (750 ha), France (500 ha), Germany (350 ha) and the Czech Republic (150 ha). As appears from Table 4.2, these areas increased in 2006, and GM maize was grown in Slovakia for the first time.
All the maize grown commercially in the EU in 2006 originated from the genetically modified maize line ’MON810’ from the company Monsanto. The GM maize has a protein that is toxic to the larvae (caterpillars) of corn borers that can cause considerable losses in maize crops in Southern and Central parts of Europe.
A number of GM maize varieties have been developed based on the ’MON810’ line, which first were included in the catalogue of varieties in Spain, France and Germany and then in the EU’s common catalogue of agricultural plant varieties (see the Appendix in section 9).
Romania has for a number of years grown GM soya of the type that has been imported into the EU since 1997 primarily for use in animal feeds. In 2006 the area was thought to be approx. 115,000 ha.
With Romania’s accession to the EU on 1 January 2007 the growing of GM soya was suspended, as it was not approved for growing in the EU. However, an application for growing is being
considered under the regulation of GM foods and feed.
Prospects for 2007
The GM maize area will probably increase further in 2007 and in the years to follow, especially in France, Germany, Portugal, the Czech Republic and Slovakia. A homepage of the German Federal Office of Consumer Protection and Food Safety publishes the location of fields with GM crops in Germany (Bundesamt für Verbraucherschutz und Lebensmittelsicherheit, 2007). For 2007 planned growing of MON810 maize on more than 3,700 ha had been reported by mid-March. However, experience shows that some of the reported area is withdrawn before the growing season begins.
GM maize varieties in the EU common catalogue of agricultural plant species
At the beginning of 2007 47 GM maize varieties are listed in the EU common catalogue of agricultural plant species. These varieties come from the national catalogues of varieties in France, Spain and Germany and, as mentioned above, are all based on the insect resistant ’MON810’ maize line.
In principle, all these varieties can be grown in Denmark. However, the pest (the European corn borer), to which the GM maize is resistant, is not a problem in Danish maize crops, and so Danish farmers have no incentive to grow this maize. In addition to this, these maize varieties are grain maize varieties adapted to growing in more southerly environments and tend not to ripen sufficiently under Danish conditions.
Trial releases with GM crops in Europe
The frequency with which different plant species and GM characteristics, respectively, occurs in the trial releases indicates what can be expected to be approved, grown and marketed in Europe in later years (Figures 4.2 and 4.3).
The most frequently occurring GM crops in trial releases have not changed since 2002. The four most frequent crops are maize, oilseed rape, beets and potatoes, after which there is some distance to the next four species. Most new trials in the period 2003-2006 were with maize and potato, and the four new approvals for marketing in this period were all GM maize events.
Figure 4.2. The most frequent GM plant species in trial releases in the EU (Source: JRC 2007 a &
b). The number of applications for trial releases from 1991 to April 2006 is shown horizontally.
There was a total of 2121 trial releases during this period. The number of GM events approved for marketing is shown to the right of the columns (see also Appendix in section 9).
The frequency of the selected characteristics found in GM plants in trial releases has shown some clear tendencies during the last 11 years (Figure 4.3). Herbicide tolerant GM plants were included in 74% of the trial releases in 2004-2006 compared with just under 60% in the previous trials. Insect resistance increased rapidly from just 18% in 1997-2000 to 48% in 2004-2006. GM plants with changed “ingredients” occurred in approx. 20% of the trial releases in all periods.
The modified plant characteristics include stress tolerance, changed morphology or reduced flowering. The relatively large number of the trial releases with “changed plant characteristics” in 2001-2003 (approx. 25%) included many trials on rice with changed growth and morphology in 2002. “Morphology and changed plant characteristics”, “disease resistance” and “other
characteristics” were generally included in a smaller number of trials.
0 10 20 30 40 50 60 70 80
Herbicide tolerance
Insect resistance
Constituents
Pathogen resistance
Plant characteristics
Others
Percentage field trials 2004-2006 2001-2003 1997-2000
Figure 4.3. Characteristics of the genetically modified trial release crops in the EU 1997-2006 (after Kjellsson et al., 2007). As a GM plant often had several transgenic traits, the sum of the percentages exceeds 100. The development of several GM traits in the plants in the EU trial releases is also clear in the way that 55% of the plants had two transgenic traits and 21% of the plants had three traits in 2005.
4.3 Co-existence in the EU
4.3.1 Administratively
In 2003, the EU Commission published a recommendation to the EU member states on guidelines for the development of national strategies and best practices for co-existence between GM,
conventional and organic crops (EU Commission, 2003). The publication took place a month before
the 2003 Report, but the recommendation contains many of the same elements that are included in the 2003 Report.
The recommendation has formed the background for the development of the EU countries’ national regulations on co-existence, which have been subsequently completed or are still being prepared. In its recommendation the Commission committed itself to preparing a report after 2 years on the experience on co-existence gained by the member states (EU Commission, 2006; see below).
COEX-NET
In 2005, the EU Commission established the expert group COEX-NET with the task of exchanging and coordinating information between the EU members states on questions related to co-existence.
The group meets twice a year. Denmark is represented by the Danish Plant Directorate.
Through the adoption of the Council of Minister’s conclusions regarding co-existence on 22 May 2006 (EU Council of Ministers, 2006; see below), COEX-NET has been allocated a major role in connection with discussions of for example cropping distances, regulations on responsibility and co-existence across national borders.
Report from JRC/IPTS
In January 2006, the EU Joint Research Centre (JRC and IPTS) published a new report with case studies on co-existence between GM and non-GM crops in European agriculture (Messean et al., 2006). The first report from 2002 marked the starting signal for the work on establishing regulations on co-existence in the member states.
The new report includes both updates for maize and oilseed rape and studies of new crops; sugar beet and cotton. The 2002 report studied maize, oilseed rape and potatoes.
Status of regulations in EU countries
At the beginning of 2007, the status is that 7 EU member states – Denmark, Germany, Portugal, Austria, the Czech Republic, Slovakia and Hungary – have passed national legislation on co- existence.
Furthermore, Belgium, Latvia, Lithuania, Luxemburg, the Netherlands, Slovenia and Sweden have notified drafts for legislation on co-existence to the EU Commission. Most other countries were in the process of preparing regulations.
During recent years studies of pollen dispersal have been performed in Germany, the United Kingdom, France, Spain and Switzerland. Some of the cropping distances established nationally are based on studies of pollen dispersal performed in these countries among others.
According to the report from the EU Commission on national co-existence measures, the EU member states refer to implemented or planned research as a background to the preparation of regulation proposals. However, countries like Lithuania, Luxemburg and Poland have not referred to research results as the background to their proposals (EU Commission, 2006).
In its report the Commission mentions that certain member states have proposed measures that exceed that which is considered necessary to observe the 0.9% threshold value of adventitious presence. For example, the Commission has objected to the separation distances in Luxemburg.
The Commission specifically notes that certain member states propose separation distances significantly exceeding the distances that scientific studies in various member states consider sufficient.
An example of this is Spain. Even though Spain has had commercial growing of GM maize since 1998, the country has still not passed regulations on co-existence. A first draft for co-existence regulations included a proposed separation distance for GM maize of 50 m from fields with conventional or organic maize. In a later draft, this distance was increased to 220 m, which is the distance used for production of maize seed in Spain.
Table 4.3 shows a summary of the separation distances passed or known as proposals for production crops at the beginning of 2007. Some countries have chosen to have different distances for
conventional and organic fields, respectively, even though the threshold value for adventitious GMO presence is the same for conventional and organic farming (0.9%).
It appears from this that there is a considerable variation between member states with regard to the separation distances that are either passed or available as drafts. For example, the proposed distances for fully fertile oilseed rape vary from 35 m in England to 4000 or 6000 m in Latvia depending on whether the distance is to a conventional or an organic oilseed rape field. The values for oilseed rape included in the Danish 2003 Report were 150 m and 500 m for conventional and organic production respectively. However, these values are not included in the table because no regulations for the production of GM oilseed rape are established in Denmark as yet.
The differences for maize are also striking and vary from 25 m in the Netherlands to 800 m in Luxemburg; generally, however, the countries are more homogeneous in two groups of less than 100 m and between 200 and 400 m respectively. It should also be noted that in the Czech Republic it is possible to reduce the cropping distance with buffer rows of conventional maize. For each buffer row the distance can be reduced by 2 m. This means for example that a separation distance of 70 m can be replaced by 35 buffer rows. Similarly, Portuguese farmers can choose between a separation distance of 200 m and 24 buffer rows grown with conventional maize.
For potatoes and beets there are also differences, but these are generally less striking. Several countries maintain proposals/regulations with more extensive separation distances between GM crops and organic crops than to conventional crops, and the Netherlands have proposed stricter separation distances to so-called “GM free” crops. However, this term is not recognised in the EU.
Apart from Denmark, few countries have made regulations or proposals for regulations on cropping intervals, which are the number of years that have to pass from the growing of a GM crop until a similar conventional or organic crop is allowed in the same field. The proposals known up to now are shown in Table 4.4. The values for oilseed rape that were included in the 2003 Report for Denmark were 8 and 12 years for conventional and organic production respectively. However, these values are not included in the table because no regulations for the production of GM oilseed rape are established in Denmark as yet.
