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Comment to the United States on Gene-Edited Crops

Seikatsu Club Consumers' Co-operative Union has submitted a public comment to the United States Department of Agriculture concerning the new regulatory framework for genome-edited crops proposed by the United States

In June, the United States Department of Agriculture proposed a new regulatory framework for genetically engineered (GE) crops and solicited public comments up to August 5.

The newly proposed rules would exempt many genome-edited crops from the GE crop safety screening. Further, genome-edited crop developers would have the option to make a self-determination as to whether their genetically engineered (GE) crop plant will be exempted from the regulations or not. There are concerns that if the new regulatory framework is implemented, the Japanese government and consumers would be unaware that genome-edited crops produced in the United States had entered the Japanese market. 

On August 5, Seikatsu Club Consumers' Co-operative Union (Headquarters: Shinjuku Ward, Tokyo; member co-operatives: 33 consumers’ co-operatives and one consumers’ co-operative union; total membership: roughly 40,000) submitted a comment to the United States Department of Agriculture demanding safety screening for genome-edited crops, information disclosure to the export market, and appropriate measures to ensure that notification to the Japanese government is implemented without fail. The submitted comment is as follows.


Seikatsu Club Consumers' Co-operative Union (SCCCU) is a consumers' co-operative in Japan with a membership of 400,000 households and annual sales of 90 billion yen (approximately 900 million dollars). At the annual general meeting (AGM) in 2018, SCCCU articulated four issues regarding genome-editing (food safety, biodiversity, seed monopoly, and regulatory restrictions) and expressed our concerns about commercialization. Then, in June in 2019, a special resolution titled "We Express Our Concern Regarding Commercial Distribution of Genome-Edited Food and Will Push Forward with Countermeasures Together with Consumers" was adopted by the AGM.

As a food importing country, Japan depends heavily on food produced in the United States. We are concerned that the proposed new regulatory framework would undermine Japanese consumers' confidence in food imported from the United States in general. In this context, we submit our comments on the proposed regulatory framework below.
 
1) Decisions should be made by USDA, instead of allowing developers make self-determinations.
Based on the proposed new regulatory framework, developers have the option to make a self-determination as to whether their genetically engineered (GE) crop plant will be exempted from the regulations or not. The decisions should be made only after assessments by regulators. We urge USDA to assess each crop plant and make decisions as a responsible regulatory authority, instead of relying on developers to regulate their own GE plants.
 
2) Information disclosure for the export market about any kind of GE crops, including genome-edited crops, should be implemented.
Based on the current proposal, developers have no duty to report to USDA on crop plants if the developers determine that the plants are exempted from the regulations. This would allow many genome-edited crop plants to enter the market without even the knowledge of USDA. Mandatory reporting of any GE crop plants including genome-edited plants to USDA before commercialization should be implemented. In addition, the information on those plants should be made public on the USDA website. Only such information disclosure would ensure the consumer confidence that would enable Japanese consumers to purchase food from the United States based on both trust and the consumers' right to choose.
 
3) USDA should take appropriate measures to inform the Japanese government of GE crops before developers and other operators in the United States export such crops to the Japanese market.
Japan's Ministry of Health, Labour and Welfare asks developers of genome-edited products to submit information on such products before commercialization. The Ministry clearly says that it will also request developers in other countries to do likewise through embassies and industry groups. Japan is one of the biggest importers of agricultural products from the United States. USDA should take appropriate measures to ensure developers and other operators in the United States provide information about their crops to the Japanese government before they are exported to the Japanese market.
Published on August 22, 2019

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