Editing under provision

Our global food system is in need of a transition towards one that is sustainable, fair, and healthy. With the Farm to Fork Strategy, the EU aims to accelerate this transition and ensure a competitive European agriculture. But what constitutes such a system? And which role can technology play? These are relevant questions, and pertinent to the current debate on what role new genomic techniques (NGT) should play in the European plant breeding sector.

The European Commission (EC) is preparing a policy initiative for plants (and food and feed derived from these plants) obtained by new genomic techniques (NGTs). These are techniques capable of changing the DNA of an organism, developed after 2001, when the existing GMO legislation was adopted. Currently, food crops developed with NGTs are subject to the EU Directive on the deliberate release into the environment of genetically modified organisms (GMOs). A study by the EC concluded that there are strong indications that this legislation is not fit for purpose for some NGTs and their products.

Two policy options for the EU dominate the debate on the use of NGTs plant breeding. One option is to exempt NGT crops from the GMO Directive, if and only if there is no foreign DNA present in the end product. The other policy option is to uphold the GMO Directive for NGT crops. Both options come with societal consequences and challenges. A third policy option is increasingly receiving attention. This option attempts to unify the benefits of both options and entails a less elaborate risk assessment for NGT crops with lower anticipated risks than currently is the case. Moreover, the use of NGTs would be allowed only under specific conditions, depending on the level of genetic intervention and on broader social and ethical considerations.

Currently, the debate on using NGTs in plant breeding is held almost exclusively among scientists, scientific and industry organisations, and companies in the agri-food field, as well as a small number of NGOs. However, in shaping a new policy on NGTs, it is important to include the voice of citizens, not only because biotechnologies have the power to redesign life, but also because they offer the potential to reshape the practice of agriculture and the future of our food (system). The way we produce food involves questions of how we want to live on this planet and how we want to relate to other species. For purposes of democracy, citizens need to have a say on which public values are incorporated in a new policy for NGTs.

Aim of the study

In this study, we have engaged with Dutch citizens from several layers of society in open, constructive dialogue using focus group discussions to explore their views on the use of NGTs and older genetic modification (GM) techniques in crops, the factors shaping these views, and the conditions they deem necessary to introduce NGT crops onto the European market, if introduced at all. For this, we employed an anticipatory method, to explore how concerns and responses emerge in structured interaction. The six focus groups were made up of five to eight participants, each professionally recruited. To ensure a diversity of perspectives, and provide a reflection of Dutch society, we selected individuals representing broadly the Dutch public in terms of age, educational background, socio-economic class, and gender.

Our findings provide an insight into how the Dutch public is likely to respond when the proposal of the EC for a new regulatory framework for NGTs in plants becomes a public issue. This study therefore provides policymakers with a unique opportunity to understand and address public sensibilities towards the use of NGTs in crops, and to help develop democratic governance for NGTs in agricultural practice.

Findings

The attitudes of citizens in our focus groups towards the use of NGTs in crops diverge. Some believed these techniques will be necessary for dealing with current predicaments, like climate change, while others viewed the introduction of these techniques in practice as likely to aggravate current problems in agriculture and the food system. However, in general, citizens views converged towards reservation and hesitation about the use of NGTs and genetic modification in crops. Citizens raised doubts mainly about the plausibility that these crops will contribute meaningfully to the solving of our current societal challenges in the food system, and whether they are indeed the right approach for dealing with these challenges. They wondered if alternative solutions may be better, and how these may come with less unforeseen, long-term risks for human health and ecosystems. However, some participants expressed doubts whether alternatives are realistic, such as for example, in the fight against food shortage, eating less meat as a strategy to make agricultural land available for food instead of feed. Moreover, the citizens in our study questioned whether companies will in practice develop valuable varieties for society, as the logics of the corporate world tend to be focused on capital accumulation and on making profits.

Citizens in our study were unanimous in their view that regulation of NGT crops is necessary for diverse reasons: to prevent harms to the environment and human health, to give consumers freedom of choice, to guard against the potential of the technology to increase inequalities, and to ensure that the technology is directed towards contributing to solutions to societal problems. The latter is viewed as an important pre-condition for the introduction of NGT products onto the marketplace. According to citizens, NGTs should not be developed purely for commercial motives driven by the logic of the market. There needs to be a clear societal purpose for their introduction. In terms of policy, this would necessitate a case-by-case assessment of NGT crops for broader considerations such as purpose, and value to society.

Values underlying citizen’s views

The views of citizens are shaped by underlying values that include those of safety, naturalness, justice, well-being, and feelings of unease about the pursuit of perfection and efficiency in our food system. Besides these underlying values, the context of the climate crisis, the corona crisis, and the nitrogen crisis also are formative of opinions. For citizens, there remains an underlying concern that the application of the technology is likely to exacerbate certain ongoing and unwelcome trends and developments in society, such as the increasingly unequal global food system and the concentration of power in large corporations. Economic and commercial purposes are by many dismissed as sufficient justification for introducing NGTs in plant breeding practices.

The key message that emerges from our research is that it is essential for the European Commission and national governments to increase their efforts to engage in regular and continuous open constructive dialogue with citizens about the upcoming EC policy initiative, and in subsequent discussions on the use of NGTs in crops and on alternatives.

The reasons for this are fourfold. First, changes to regulation are of public importance because biotechnologies have the potential to impact society, redesign life, and reshape the practice of agriculture and the future of our food system. Citizens therefore have a key interest to be involved in decision-making processes. Second, when citizens are involved in the development of a new policy, and public values are taken onboard, the chance of broad societal support becomes higher. Third, we have learned from our research that the views of Dutch citizens converge on the need for regulation of NGTs in agriculture, and that these views stand in direct contrast with the current dominant frame in the debate. Fourth, we have learned that Dutch citizens in our study emphasize the importance of transparency and of the governments duty to inform the public.

Based on our findings and building on previous research carried out by the Rathenau Instituut and by co-author Phil Macnaghten, we provide policymakers with three recommendations on public engagement.

Recommendation 1

Take into account cultural, ethical, and socio-economic considerations in policy discussions on the use of NGTs in crops. Investigate with all relevant parties, including the public, what broader concerns and interests merit a place on the public agenda.

To develop a new democratic policy on NGT crops, and to gain public trust in the process, it is important to avoid strategies that seek to convince the public of their importance or necessity. Citizens should be included in decision-making, not merely informed about upcoming technologies. It is important to provide space for citizens for deliberation on the dominant framings of the technology, and engagement with the broader considerations and the underlying values seen as important to citizens. When discussing NGTs in food and an upcoming change in regulation, citizens in our focus groups express concern about safety, increased corporate control, increased inequality in the food system, and a loss of consumer choice. These wider citizen considerations need to be taken seriously; citizens’ concerns need to be embraced in decision-making processes.

Recommendation 2

Build a relationship of trust with citizens by being open about the uncertain impacts of NGTs on society, both positive and negative. Discuss the alternatives available as well as the possible unfair distribution of benefits among parties in the agrifood system.

Trust in institutions is critical for the acceptance of a technology. Fully informing and entering into dialogue with citizens, including on matters of context, uncertainties, challenges, and alternative options for policy, are the most effective ways to respond to distrust. For NGTs specifically, this entails policymakers and scientists to be open about (the potential of) the technology to solve as well to aggravate current societal challenges, including issues associated with the patentability of NGT crops. This also means that scientists and policymakers avoid the exceptionalism that commonly attaches to discussions on NGTs by acknowledging that a sustainable agriculture system can be achieved by alternative methods. But more important than the practical reason of gaining societal support, is the prerogative that the regulation of technologies is democratically formed. This is only possible when all stakeholders, including citizens, are viewed as serious discussion partners. 

Recommendation 3

Communicate openly the scientific uncertainties on the use of NGTs in crops in public engagement initiatives.

The need for honest communication extends to the communication of current uncertainties and gaps in scientific knowledge. The scope and significance of the current state of scientific uncertainties is sometimes downplayed to prevent unrest. However, this tactic may prove counter-productive, especially in cases where long-term safety is impossible to prove, as is currently the case for gene editing. Being open and communicating scientific uncertainties allows citizens to formulate a well-balanced informed opinion and is more likely to instill trust.

We also provide policymakers with four recommendations on ways to translate the views and underlying values of citizens towards gene editing in crops into a new policy approach for NGTs in food.

Recommendation 1

Avoid the proposal of exempting NGTs from the current GMO Directive, but instead develop a differentiated, or level-based, policy approach.

Similar to other studies, citizens in our focus groups are unanimous in their view that NGTs needs to be regulated. Even with a formal risk assessment, the citizens we have spoken with are not keen on the introduction of NGT foods to the market. If the EC were to exempt NGTs from the GMO Directive, they would also be exempt from an environmental risk assessment and monitoring obligations, which assess the immediate and long-term effects of a GM crop on public health and the environment. Citizens in our study are unanimous in their view that an assessment for risks to human health and the environment should be a requirement prior for market approval.

In a previous report, we offered a way forward to modernize the current biotechnology policy with a level-based, or differentiated, approval policy. Such an approach would offer different levels of intensity or strictness of regulation with various levels of risk assessment. This approach would take into account the differences in expected risks associated with different ways in which the new genomic techniques can be used in practice. The assumed risks would determine the strictness and speed of the risk assessment procedure. Most citizens in our focus groups are open to such differentiation in risk assessment between crops altered with older genetic modification techniques and NGTs.

Recommendation 2

Move from a consumer-oriented to a society-oriented governance regime that incorporates ethical, cultural and socio-economic considerations into the market authorisation process.

Citizens in our focus groups expressed the view that assessing the goal of a specific innovation, its contribution to societal challenges, and the desirability of using the technology as a solution to these challenges, were important considerations for governance. Only within a broader assessment framework can these be taken into account. It is therefore important that policymakers think beyond a consideration of risks and economic benefits, seen as important for consumers, towards a focus on the ethical, cultural, and socio-economic aspects that citizens find important. By means of a case-by-case assessment of ethical, cultural and socio-economic considerations, public values can be brought into the design and selection of NGT-crops for market authorization. A policy initiative should thus combine a differentiation in risks assessment with an assessment of broader considerations, on a case-by-case basis.

Recommendation 3

Ensure that the ethical, cultural, and socio-economic aspects of NGT crops are assessed by an independent EU body.

An independent committee could be established with the dual tasks of developing broader democratic assessment criteria, and with assessing on a case-by-case basis market approvals of crops modified with NGTs. Such an authority could be founded in the European Union, or on a national level. In the latter scenario, member states can identify their own relevant cultural, ethical and societal considerations. Citizens in our study indicate that they would trust the formal assessment of risks and of broader considerations if they are performed by independent institutes. Nevertheless, outstanding questions remain on who decides what is ethical and valuable to society and what it entails for a crop to be sustainable.

Recommendation 4

Preserve the freedom of choice of citizens by maintaining the requirement to label GM food, including NGT food.

The citizens we spoke with in our focus group discussions emphasize the need for freedom of choice for citizens, and conclude that the labelling of NGT products is required. If the EC were to exempt NGTs from the GMO Directive, citizens would not be given the freedom of choice not to buy NGT foods, nor would there be a free market, as citizens cannot express their preferences through purchasing behavior. 

Concluding remark

The EU is currently looking for ways to transition towards a sustainable food system. NGTs are seen as having the potential to contribute to this transition. Citizens, however, are cautious, mainly because they seem to assess the new technology not by its potential power, but instead by the circumstances seen as likely to determine how the technology emerges and the interests shaping its use. Moreover, citizens are interested in alternative approaches and opportunity costs, and consider justice and fairness in the food system to be important guiding criteria. Citizens demonstrate an awareness of the entanglement of technologies with politics and the food system. We believe that the political debate on the role of NGTs and the upcoming regulatory change would benefit if policymakers make this entanglement explicit. This is necessary to help ensure a mature discussion on what role we want technology to play in a future agricultural and food system.