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. 2024 Jan 23;13(3):369.
doi: 10.3390/foods13030369.

Strategies for Traceability to Prevent Unauthorised GMOs (Including NGTs) in the EU: State of the Art and Possible Alternative Approaches

Jenny Teufel  1 , Viviana López Hernández  1 , Anita Greiter  2 , Nele Kampffmeyer  1 , Inga Hilbert  1 , Michael Eckerstorfer  2 , Frank Narendja  2 , Andreas Heissenberger  2 , Samson Simon  3
Affiliations

Strategies for Traceability to Prevent Unauthorised GMOs (Including NGTs) in the EU: State of the Art and Possible Alternative Approaches

Jenny Teufel et al. Foods. .

Abstract

The EU's regulatory framework for genetically modified organisms (GMOs) was developed for "classical" transgenic GMOs, yet advancements in so-called "new genomic techniques (NGTs)" have led to implementation challenges regarding detection and identification. As traceability can complement detection and identification strategies, improvements to the existing traceability strategy for GMOs are investigated in this study. Our results are based on a comprehensive analysis of existing traceability systems for globally traded agricultural products, with a focus on soy. Alternative traceability strategies in other sectors were also analysed. One focus was on traceability strategies for products with characteristics for which there are no analytical verification methods. Examples include imports of "conflict minerals" into the EU. The so-called EU Conflict Minerals Regulation requires importers of certain raw materials to carry out due diligence in the supply chain. Due diligence regulations, such as the EU's Conflict Minerals Regulation, can legally oblige companies to take responsibility for certain risks in their supply chains. They can also require the importer to prove the regional origin of imported goods. The insights from those alternative traceability systems are transferred to products that might contain GMOs. When applied to the issue of GMOs, we propose reversing the burden of proof: All companies importing agricultural commodities must endeavour to identify risks of unauthorised GMOs (including NGTs) in their supply chain and, where appropriate, take measures to minimise the risk to raw material imports. The publication concludes that traceability is a means to an end and serves as a prerequisite for due diligence in order to minimise the risk of GMO contamination in supply chains. The exemplary transfer of due diligence to a company in the food industry illustrates the potential benefits of mandatory due diligence, particularly for stakeholders actively managing non-GMO supply chains.

Keywords: European Union (EU); agri-food supply chains; alternative approaches; compliance; due diligence; genetically modified organisms (GMOs); new genomic techniques (NGTs); non-GMO; regulatory frameworks; risk assessment; sustainable development; traceability systems; transparency.

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Conflict of interest statement

The authors declare no conflict of interest. The funders had no role in the design of the study; in the collection, analyses or interpretation of data; in the writing of the manuscript; or in the decision to publish the results. S.S. is employed by the institution that commissioned the study.

Figures

Figure 1
Figure 1
The chain of custody of certified non-GM soy from Brazil imported into Europe (source: © Öko-Institut e.V. 2023).
Figure 2
Figure 2
Validation process for understanding the practical implications of the developed alternative traceability strategy to prevent the import of unauthorised GMOs into the EU (source: © Öko-Institut e.V. 2023).
See this image and copyright information in PMC

References

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