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HollandBIO’s feedback to public consultation NGTs


We are pleased to share HollandBIO’s feedback to the public consultation on plants produced by certain new genomic techniques (NGTs). So far more than 1300 respondents have delivered feedback to this public consultation. A targeted stakeholder consultation is still ongoing, to be finalized by the end of this month. We ask all biotech experts to express their opinion and provide input to this consultation before 21st of July via the European Commission website

Key messages HollandBIO

In line with our earlier input for the Inception Impact Assessment, HollandBIO stresses the need for a paradigm shift in order to realize the full potential of biotech innovation for health, sustainability and economy. Future-proof legislation should not discriminate against the technology used, but take into account the characteristics of the final product. A more thorough modernization of the GMO legislation is urgently needed by extending the modernisation’s scope to all genomic techniques and all organisms, including that of microorganisms.

There is no need for specific regulatory provisions on sustainability in this initiative. Sustainability should not create an additional hurdle during the product approval process, nor should it be an additional requirement for NGTs only. Allowing the application of NGTs will unlock a bigger potential to develop sustainable products. If any, sustainability criteria should be part of general (market) approval processes, regardless of the technique applied or product type.

Any regulation or addition to legislation should keep in mind startups, scaleups and SMEs. Given the great societal challenges of our time, the EU needs to embrace all solutions available.

Next steps European Commission

Input to this public consultation will be taken into account for further development and fine-tuning of a legal framework proposal for plants obtained by targeted mutagenesis and cisgenesis and for their food and feed products. The European Commission plans to present its proposal by the second quarter of 2023, followed by a legislative procedure with the European Council and European Parliament.