The following letter has been sent to key ALP shadow ministers and Senators in advance of a vote on disallowing the Government's deregulation of gene editing methods.
8 September 2019
Dear Senator
Our organic industry is deeply concerned that the Australian Government’s gene technology deregulation will compromise certified organic exports to the European Union and China, and will erode consumer confidence in Australian food producers and manufacturers.
These trading partners do not tolerate any risk of contamination from genetically modified (GM) products in their organic imports.
The Gene Technology Act 2000 currently requires all scientific and commercial activities using genetic modification processes and living products to be notified to the Office of Gene Technology Regulator for assessment and licensing. But the Government’s Gene Technology Amendment Regulations 2019 will exclude a class of methods known as SDN1 from any notification or scrutiny at all. The regulations will become law on 8th October 2019, unless the Senate disallows them, and Australia will become one of the first countries in the world to deregulate the use of these new genetic modification techniques.
Senator Rice has given notice for a disallowance motion for these regulations. The Australian organic industry is imploring your support of this motion, to protect the integrity of the organic industry, remove this risk to our export markets and to enshrine in law a consumer’s ‘right to know’.
Under the new regulations, nearly three decades of work by thousands of farmers is under threat because many GM products (as defined by our export markets) will no longer be registered, regulated or labelled in Australia, hampering traceability and making organic status almost impossible to verify in Australia.
Australian organic exports rely on our produce meeting the organic standards as set by the importing countries. In China, Europe and other markets, SDN1 and CRISPR–CAS9 technology does not comply with those standards. With the Government’s deregulation, Australian organic product may no longer be certified as organic in those and other premium export markets.
As shown in our recent Export Strategy, the organic industry continues to be a shining light of export market growth in Australia, and our industry is keen for this growth to continue.
We consider that the Government has not adequately considered the trade implications for organic products. How will our Government respond, should Australian exporters be caught selling compromised product, through no fault of their own? Will such an incident cause us to lose market access for conventional beef and other traded commodities, simply by association? Some of our most important export markets could be closed to Australian organic exporters but ominously, to conventional exporters as well.
In addition, we consider that Australian consumers have a ‘right to know’ and should have the ability to make an informed choice, about whether to consume genetically modified organisms. Have you ever stopped and looked at a product that makes a claim to being Australian made, and then wondered if it could contain ingredients which have been genetically modified? We don’t believe that GM products should be allowed to be hidden in plain sight.
The organic industry is perplexed by the lack of public discourse. We, as both organic industry participants and every-day consumers, have not been consulted on these regulatory changes, which will most certainly affect us. We are calling on the Government to be genuinely transparent with the public on the Gene Technology Amendment Regulations 2019. To date, only organisations which support the proposed amendments to the Act have been published. Does this mean that no objections have been raised?
The suggestion that we deregulate SDN1 and CRISPR–CAS9 technology, and remove any requirement to register or transparently label products as produced using these methods, is in marked contrast to the work by Government using Australian Consumer Law (ACL) to ensure consumers are afforded MORE transparency, not less. Part 5-3 of the ACL sets out the regime in determining whether a good or product which claims to be Australian, can make such an assertion, or whether the claims are actually false, misleading or deceptive.
We encourage you to consider:
- a Senate inquiry into the impacts of the deregulation, including detailed analysis of the trade implications and into the creation of a compensation fund for loss of export income;
- a comprehensive risk assessment and cost benefit-analysis of the deregulation;
- proper consideration given to the implications for Australian consumers of deregulation, with opinion given to the impact on Australian Consumer Law;
- no deregulation of new GMOs until they are accepted by all premium agricultural export markets; and
- keeping and strengthening the Gene Technology Act 2000, the cornerstone of Australia's evidence-based regulatory system for GM animals, plants and microbes.
Yours sincerely,
Dalene Wray
Acting Chair, Organic Industries of Australia Ltd
OIA Ltd (website) is the interim peak body representing all Australian organic operators, regardless of which certifier provides their organic certification. Our members include some of Australia’s largest organic certifiers, producers and exporters, including Bellamy’s Organic, NASAA Organic, OBE Organic, Hancock Agriculture, Paris Creek Farms, Rural Organics, Queen, Norco Foods, Rosnay Organics, Australian Organic Meats, Primal Foods Group, and Pure Harvest.
OIA Ltd was founded after the Australian Government Department of Agriculture and Water Resources led a process of preliminary discussions with the organic industry over the period of September – December 2016. This tested the waters on the interest of the industry in working together to increase the competitiveness of the Australian organics sector.
During 2017 and 2018, the Australian Organic Industry Working Group (AOIWG) was formed and developed a roadmap to improve the representation of Australia's organic industry. The AOIWG consisted of industry leaders from across Australia collaborating on establishing a harmonised national voice for all organic producers, certifiers and the supply chain.
In an expression of unity at the Love Organic symposium (14&15 February 2018 in Canberra), Australia’s organic industries agreed to establish a new peak body that is the voice for Australia’s organic industries in regard to policy and market access and OIA Ltd was born.