As a grain trader would profess, efficient and effective trade is based on the principal of fungibility, allowing for the substitution of grain from source to source as market conditions dictate. Since the introduction of biotech crops, growers and traders have both benefitted from increases in yield and overall productivity, however, the patchwork map of regulatory systems for biotech crops has created significant hurdles in maintaining this fungibility.
More specifically, challenges have arisen through a combination of unpredictable and asynchronous approvals between import and export markets and the lack of clear policies governing instances of low-level presence (LLP) of unapproved biotech products. LLP refers to the presence of biotech products approved in a country of export but not import, while “adventitious presence” refers to the presence of biotech products not yet approved in either jurisdiction.
It’s important to note that the collective impact of unpredictable approvals in large import markets and the application of an effectively zero-tolerance policy is significant for both importers and exporters. For growers in cultivating countries, they forego technological advances and productivity year after year waiting for approvals in their major export markets – approvals where timing may be impacted as much by prevailing market conditions as the completion of a science-based safety assessment. In importing markets, buyers experience negative cost impacts through both the limitation of suppliers and price premiums, especially for large buyers for which finding alternative high-volume suppliers may be challenging.
While the preferred solution to this problem is ideally functional, science-based and punctual approvals for new biotech crops, this has proven to be continuously challenging given the complex political environment around biotechnology. Given this reality, the next best solution is the application of more formal, trade-friendly policies that allow tolerance of some LLP of unapproved biotech products provided they are approved in the export jurisdiction – explicitly a workable LLP policy. Tolerances are nothing new for the grain trade industry with thresholds set for topics like broken/damaged/sprouted kernels, off-color grain and unregistered varieties.
Despite many years of discussion and slow movement on this topic, there is new hope for action. Canada is expected to formally release its model policy on LLP in the coming months, which calls for a more focused assessment of biotech products entering commodity streams as a method to allow LLP below a certain threshold level before a full assessment is completed. Over the past year, Vietnam has been implementing a streamlined approach to food and feed safety approval, whereby any product approved in five or more member countries in the Organization for Economic Co-operation and Development is fast-tracked for approval domestically. And lastly, a collection of 16 countries, including the United States and Canada, continue their multilateral dialogue under the Global LLP Initiative, which aims to build upon these and other possible solutions to reduce the impact that LLP may have on international trade.
One could say it comes not a moment too soon. With the introduction of new biotech traits into new commodities (i.e., apple, potato, eggplant), the development of new traits by public and private sector entities in new countries and the onset of patent expiration for early traits and resulting appearance of generic traits, the mix of technology entering global trade continues to rapidly diversify. This crop, trait and geographic diversity makes the prospect of zero-tolerance even more unreasonable in the global food system – especially one that needs to keep functioning to feed a growing population.
John McMurdy is director of Emerging Market and Development Partnerships at CropLife International and coordinates the Global Alliance for AgBiotech Trade, a farm to fork industry coalition encouraging development of trade policies that facilitate movement of seed, grain and processing ingredients, and reduce the potential for trade disruptions.