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Scientific analysis

European Network of Scientists for Social and Environmental Responsibility (ENSSER)The European Network of Scientists for Social and Environmental Responsibility (ENSSER) is a non-profit association registered under German law. ENSSER brings together independent scientific expertise to develop public-good knowledge for the critical assessment of existing and emerging technologies.

ENSSER has analysed new genetic modification techniques (NGMTs), which are increasingly being developed and applied to generate new varieties of food crops and livestock animals.

Read the full ENSSER statement at

ENSSER notes that the following key points are used to argue for deregulation of NGMTs:

  • Only the intended trait present in the end product of the NGMT “event(s)” should be considered by regulators, and no attention should be given to the processes by which these “events” were created within the entire organism, whether a virus, microbe, plant or animal.
  • In the majority of NGMT events, foreign DNA is not present at the end of the manipulation.
  • The small DNA base unit changes brought about by genome editing methods, which either knock-out (ablate, deactivate) a gene or modify the function of a gene’s protein or RNA product, can mimic what may occur naturally through random mutation, i.e. without human intervention.
  • The intended changes in the DNA or RNA are precise and singular, i.e. few or no other genome alterations occur in target organisms.
  • The outcome of the NGMT “event(s)” is predictable and the intended changes will not interact with other genes or pathways or the organism as a whole. Therefore, the products derived from these processes are safe, whether they are food products or organisms belonging to an agricultural or environmental system.

ENSSER challenges these claims as scientifically unjustified. They contend that NGMTs do modify genetic material or gene function regulation via epigenetic or other changes, and that organisms produced by these methods are therefore, logically, genetically modified organisms (GMOs).

  • These techniques may be applied in a series of incremental changes, any number of which could be indistinguishable from those arising individually in nature, but collectively be entirely unknown to Earth. Genome editing NGMTs are being developed to be used simultaneously and/or sequentially.
  • Even in cases where each change made is individually small, the totality of changes applied could produce an organism that is substantially different from the non-GM original. Such an organism may be as different from a parental line as any organism produced with “conventional” transgenic genetic modification techniques, or even more so.
  • The general claim that genomes changed using an NGMT are always identical to those that would arise without human intervention at the molecular level is unproven and undocumented scientifically.
  • Even if no foreign DNA remains in the end product, the intended genetic or epigenetic change in the organism’s own DNA or RNA is detectable.
  • Off-target, unintended changes in the genome occur frequently when these techniques are applied to some organisms and have not been excluded as happening in any organism. This has been documented in published research, especially in the case of the genome editing NGMTs.

The above facts are clear indications of potential serious and irreversible harm. In spite of the scientific uncertainty involved, action must urgently be taken to prevent such harm. This is precisely what constitutes the Precautionary Principle. The Precautionary Principle is a fundamental element not only of EU legislation but also of the Convention on Biological Diversity (CBD) and its Cartagena Protocol on Biosafety. The Protocol puts the Precautionary Principle into operation through its substantive provisions.