International Regulations on Genetically Modified Organisms: U.S., Europe, China and Japan
Fifteen years ago, a survey conducted on college students compared consumer acceptance of genetically modified organisms (GMOs) in Japan, Norway, Taiwan and the U.S., concluding that Americans were more willing to consume foods containing GMOs than were their international counterparts. Most survey participants would have liked to have mandatory labeling of GMOs and were willing to pay extra for non-GMO food.[1] Since the regulation of GMOs was first established in the early 1990s globally, countries have gone through initial formation, gradual modification and evolution of their own rules. Below is an overview of GMO regulations in the U.S., European Union (EU), China and Japan, a topic that is regularly debated by politicians, consumers, media and scientists.
U.S.: Mandatory-Labeling Voices Are Rising
On March 16, 2016, the U.S. Senate blocked a bill to nullify the mandatory labeling of GMOs at the state or local level, indicating that the debate on whether to label GMOs voluntarily or mandatorily had not ended yet.[2] Several states required mandatory labeling of GMOs before this bill, including Vermont, Connecticut, Maine and others. Vermont passed its legislation 2 years ago, and mandatory labeling is set to go into effect this summer. Connecticut passed legislation on mandatory labeling of infant formula containing GMOs in 2013, Maine approved legislation of mandatory labeling on foods containing 0.9 percent GMOs[3] and several other states have also expressed interest in implementing mandatory GMO labeling.[4]
American consumers have been increasingly expressing their concerns and demanding mandatory GMO labeling. Throughout 2015, the U.S. has been driving the launches of GMO-free claims worldwide; the U.S. accounted for 43 percent of global launches, even ahead of the EU at 4 percent. While in the EU, GMO labeling is mandatory, in the U.S., it is currently voluntary. In the past, there has been limited consumer resistance to GMOs in the U.S. But recently, dairy companies, as well as nondairy drink manufacturers using plant-source protein, have been expressing strong interest in non-GMO labeling because for those more “natural” brands, their identity as “natural” and organic is usually closely linked with GMO-free certification.[5]
According to the Grocery Manufacturers Association, 70–80 percent of processed food that Americans consume daily contains genetically engineered plants. A survey with 1,000 participants in 2014 concluded that 63 percent of Americans support the U.S. Food and Drug Administration’s current policy of voluntary labeling on GMOs, consistent with prior survey results. If GMO labeling becomes mandatory, as is the current situation in the EU, Japan and New Zealand, the U.S. food industry would be hugely impacted; most foods with GMOs may have to be eliminated from the shelf due to consumer aversions. Because non-GMO ingredients are more expensive than their genetically modified counterparts, companies switching to non-GMO ingredients would increase the prices of these food products, which would eventually result in rising food costs for consumers.[3]
EU: Currently and Historically Restrictive
Unlike the U.S., a major exporter of GMOs and leader in the biotechnology field, Europe remains conservative on GMOs. GMOs in the EU are regulated at two authoritative levels: The European Commission (EC) and European Food Safety Authority issue harmonized rules on GMOs; EU member states have individual rules and regulatory agencies within their territory. Companies hoping to sell and market their GMO-containing foods in a certain European country must apply for approval at the country level first; if approved, the company can proceed by notifying other countries via the EC. If there is any objection from other member states, additional evaluations will be conducted by the EC. A draft proposal is then submitted from the EC and voted on by representatives from EU member states. If vetoed, the proposal must be submitted to the EC for another round of votes.[6]
The EU’s cautionary attitude on GMOs is due to several different economic, political and societal reasons. Economically, limiting the sale of GMOs protects domestic agricultural business by setting a higher trade barrier for large GMO exporters. In European politics, environmental and often “anti-GMO” groups have been taking a larger role in policymaking at regional, state or even European levels. Finally, the rising consumer demand for “natural” or “organic,” which is often manipulated by social media, has led to a culture of distrust of GMOs. Some environmental groups and lobbies are reported to be active in attacking GMOs, trying to protect their own claims of being “natural” and “healthy.” Politicians, like those who passed a bill to ban foods directly containing GMOs from school lunches in Taiwan,[7] are often very sensitive to the opinions of their electorates. They carefully avoid any public rejections of these controversial issues, trying to stay aligned with their electorates for the benefit of their political careers. The impact of the EU’s restrictive policy on GMOs not only increases costs for manufacturers but also delays the development of modern biotechnology. Further, other countries considering the EU as a potential export market must wait and see, hoping to mirror policies from these large countries/regions with whom they heavily trade. Some of these “wait-and-see” countries choose to follow the EU as a model, whereas others may choose to mirror the U.S., a representative of a GMO “soft”-regulating country, to maximize benefits from exporting their crops.[8]