DEPARTMENT OF PRIMARY INDUSTRIES
Issues Paper: Review of the Moratorium on Genetically Modified Canola
July 2007
Published by the Victorian Government Department of Primary Industries, Melbourne, July 2007
Also published on www.dpi.vic.gov.au
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ISBN 978-1-74199-673-9 (Print) ISBN 978-1-74199-674-6 (Online)
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Produced by: GM Canola Review Panel Secretariat Department of Primary Industries Level 19, 1 Spring Street GPO Box 4440 Melbourne VIC 3001
Telephone: (03) 9658 4872 Fax: (03) 9658 4472
Email: [email protected]
This paper is also available at www.dpi.vic.gov.au
ii Contents
Information for review contributors ...... 1 Issues paper...... 1 Timetable for the review process ...... 1 Key contact details...... 1
Purpose of the Review of the moratorium on genetically modified canola...... 2
Scope of the Review of the moratorium on genetically modified canola...... 2
Composition of the Review panel ...... 2
Terms of reference ...... 3
Process of the Review...... 4
How to make a submission...... 4
1. Introduction...... 5 1.1 Herbicide tolerant canola varieties...... 5 1.2 Genetically modified canola varieties in Australia...... 8 1.3 Genetically modified crops: an international perspective.....8 1.4 Genetically modified crops in Australia...... 9
2. Addressing risks of genetically modified organisms in Australia10 2.1 Australian regulation of genetically modified organisms .10 2.1.1 Safety of human health and the environment...... 10 2.1.2 Genetically modified food safety and labelling ...... 11 2.2 Regulation of genetically modified organisms in Victoria 11
3. The canola industry ...... 14 3.1 Global canola production and trade...... 14 3.2 The Australian canola industry...... 15 3.3 Additional uses of canola...... 17 3.4 Marketing in the grain industry ...... 18 3.4.1 Grain supply chain management...... 18 3.4.2 Meeting grain market requirements...... 19 3.5 International and Australian organic industries...... 20
iii 4. Economic impacts of the moratorium on genetically modified canola...... 22 4.1 Studies relevant to the terms of reference ...... 22 4.2 Economic benefits and costs of the moratorium ...... 23
5. Potential policy changes...... 25 5.1 Should the moratorium be extended or terminated?...... 25 5.2 Other measures?...... 25
6. Further reading ...... 27
Appendix 1. OGTR media releases ...... 29
Appendix 2. Moratorium announcement 2004...... 33
Appendix 3. Announcement of Review of GM canola moratorium.36
Appendix 4. Review submission cover sheet...... 38
Appendix 5. Federal agencies responsible for the regulation of gene technology in Australia ...... 39 Office of the Gene Technology Regulator...... 39 Food Standards Australia New Zealand ...... 40 Australian Pesticides and Veterinary Medicines Authority ...... 40 The Australian Quarantine and Inspection Service...... 41
iv Information for review contributors
Issues paper This issues paper is intended to assist the preparation of submissions to the Review of the moratorium on genetically modified (GM) canola. It outlines the scope of the Review and issues on which the Review panel is seeking comment and information. However, the paper is not intended to restrict comment, and respondents should include any information or views that they consider relevant to the Review’s terms of reference.
Timetable for the review process The current Moratorium Order on the commercial cultivation of GM canola in Victoria is due to expire on the 29 February 2008. The closing date for written submissions to the Review panel is 17 August 2007 . Following receipt of submissions and meetings with key stakeholders, the Review panel will prepare a report for the Minister for Agriculture, to be submitted in September 2007.
Key contact details All enquiries to the Review panel should be directed to the Review secretariat.
Review secretariat: Dr Robert Sward Telephone: (03) 9658 4872 Facsimile: (03) 9658 4472 Email address: [email protected] Website: www.dpi.vic.gov.au
Postal address for submissions: GM Canola Review Panel Secretariat Department of Primary Industries Level 19, 1 Spring Street GPO Box 4440 Melbourne VIC 3001
Issues Paper: Review of the Moratorium on Genetically Modified Canola 1 Purpose of the Review of the moratorium on genetically modified canola
In 2003, the Federal Office of the Gene Technology Regulator (OGTR) approved the commercial release of Bayer CropScience's InVigor® GM canola and Monsanto Australia's Roundup Ready® GM canola. The OGTR concluded that these canola varieties pose no greater risk to human health or the environment than do conventionally bred canola (for media release, see appendix 1). The Victorian Government in 2004 concluded that the timing was not appropriate for the full commercial release of the two varieties of GM canola, due to ‘divisions and uncertainty within industry, the farming sector and regional communities about the impact of GM canola on markets’ (for media release, see appendix 2). On 12 May 2004, the Minister for Agriculture thus issued an Order declaring a four year moratorium in Victoria on the commercial scale planting of GM canola. The moratorium is in place until 29 February 2008 and will be reviewed before the Order expires. All other Australian states and territories, except Queensland and the Northern Territory, have introduced moratoria on either GM canola or, more broadly, GM crops for various lengths of time. On 22 May 2007, the Premier of Victoria, the Hon. Steve Bracks MP, announced the establishment of an independent panel to review the moratorium on the commercial cultivation of GM canola in Victoria (for media release, see appendix 3).
Scope of the Review of the moratorium on genetically modified canola
Under a policy principle established within the Gene Technology Act 2000 (Commonwealth), the moratorium on the commercial cultivation of GM canola in Victoria was imposed in 2004 for trade and market access reasons. This Review focuses on trade and market access considerations. Matters of human health, safety and environmental impacts are not part of the terms of reference, because these matters are considered under federal legislation.
Composition of the Review panel
The Review will be conducted by a panel consisting of three members whose expertise covers science, agriculture, and rural and regional development. The Review panel may seek advice to support their investigation from other persons with relevant experience. Co-opted members of the panel cannot exercise voting rights.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 2 The Review panel members are: Sir Gustav Nossal (chair) Sir Gustav has internationally recognised expertise in science, and is a chief scientist for a number of government agencies, a partner in Foursight Associates, past president of the Australian Academy of Science and former Australian of the Year. Mrs Merna Curnow Mrs Curnow has recognised expertise in agriculture, and is a partner in a grain and prime lamb enterprise. Former chair of the Victorian Farmers' Federation's education committee, she is a current panel member of the Grains Research and Development Corporation. Mrs Christine Forster Mrs Forster is former chair of the Victorian Catchment Management Council, and a farmer in western Victoria, with extensive experience in regional development, rural adjustment issues, water quality and water resource management.
Terms of reference The Review findings and recommendations are to address the moratorium on the commercial cultivation of GM canola in Victoria. The Review’s terms of reference are to: • assess the economic impacts on Victoria of the moratorium on GM canola • assess the expected economic impacts of: — allowing the moratorium to expire — extending the moratorium • recommend whether Government should allow the moratorium to expire or be extended • recommend any complementary policies and practices required to address the consequences of the moratorium ending. To provide a context for its report, the Review will: • describe the existing regulatory framework governing the release of genetically modified organisms • summarise research findings on the extent of commercialisation of genetically modified organisms in Australia and overseas, and the assessments of the economic, health and environmental impacts that have resulted. The Review panel will submit its report to the Minister for Agriculture.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 3 Process of the Review
In undertaking the Review, the panel will arrange face-to-face discussions with relevant key stakeholders (including industry organisations, academic experts, community and special interest groups) to canvass their views on key issues. The panel will examine relevant literature, assess data and gather evidence from submissions and stakeholder discussions. This information will provide important input to the Review process.
How to make a submission
Any individual or group can make a submission to this Review. The Review panel invites written submissions on issues that respondents consider relevant to the Review’s terms of reference, and it particularly welcomes input on the issues raised in this paper (see sections 4 and 5). The deadline for submissions to the Review panel is 17 August 2007 . Submissions may range from a brief commentary on an aspect of the current status of commercial cultivation of GM canola in Victoria, to a substantial assessment of a range of relevant issues. No defined format is required for submissions. Where relevant, however, evidence should be provided to support views expressed, such as copies of reports, facts and figures, or case studies. Multiple identical submissions will not carry more weight than the merits of an argument in a single submission. As such, the Review panel supports joint submissions where applicable. The Review panel encourages respondents to make their submissions publicly available. Unless marked ‘IN CONFIDENCE’, all submissions to the Review panel will be treated as public documents and may be placed on the Internet for public access. Formal requests for confidentiality will be honoured, although Freedom of Information access requirements still apply to submissions treated as confidential. To assist the Review panel to comply with privacy laws, submitting individuals or organisations should provide their details on the submission cover sheet (available in appendix 4 of this issues paper and also on the Department of Primary Industries website at www.dpi.vic.gov.au ). Submissions can be made in electronic or printed format, although the Review panel would prefer submissions be lodged electronically via email or as a text or Microsoft Word document (.txt, .rtf, .doc). Please ensure the version sent to the Review panel is the final version and that any drafting notes, tracked changes and other hidden text (including any internal links, large logos and decorative graphics) are removed. Submissions may also be sent by mail or fax.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 4 1. Introduction
The controversy surrounding the use of gene technology to generate genetically modified (GM) crops has centred on potential risks to the health and safety of people, the environment and our ability to market and trade agricultural commodities (figure 1). Risks associated with the commercial cultivation and trade of GM canola depend on the type of product (whole seed, processed oil or protein meal), the intended use (for human or animal food, certified seed or biofuels) and the customer of the product (domestic or overseas countries). The Federal Office of the Gene Technology Regulator (OGTR) approved the commercial release of InVigor® and Roundup Ready® GM canola, concluding that these canola varieties pose no greater risk to human health or the environment than do conventionally bred canola. Similarly, Food Standards Australia and New Zealand (FSANZ) conducted pre-market safety assessments of InVigor® and Roundup Ready® GM canola, deeming them as safe and nutritious as conventional canola. But in 2004, the Government of Victoria imposed a moratorium on the commercial cultivation of GM canola in the state, citing ‘divisions and uncertainty within industry, the farming sector and regional communities about the impact of GM canola on markets’ (see media release, appendix 2). Some commentators remain concerned that the commercial cultivation of GM canola in Australia would damage its status as a ‘clean/green’ food and agriculture producer, and lead to a loss of both market access and price premiums for Australian canola export markets. These market access concerns also extend to the potential for the unintended presence of GM canola in other key export grains such as wheat and barley, potentially jeopardising these valuable markets. Similar unease about the unintended presence of GM canola in the supply chain has been expressed by some domestic customers that want the choice to grow and trade GM free varieties. Other issues concern the costs and liability that may be imposed on GM and non-GM farmers to segregate GM from non-GM crops so as to supply markets that are GM sensitive. This section outlines the new canola varieties and the increased trade of genetically modified (GM) crops. Following sections provide information on the current regulatory arrangements to address the risks associated with GM crops, and on characteristics of the canola industry. Sections 4 and 5 pose questions regarding the economic impact of the moratorium on GM canola in Victoria and whether the moratorium should be extended or allowed to lapse.
1.1 Herbicide tolerant canola varieties
Canola (Brassica napus L.) is a plant that originated from either the Mediterranean or northern Europe. It is also known as oilseed rape or rapeseed (Warwick et al. 2000). The crushing of canola seed produces canola oil —used in margarines, cooking oils and some processed foods such as biscuits, salad dressings, snacks and frozen foods —and canola meal —used as a feed supplement in livestock diets, mainly pig, poultry and dairy rations (Spragg & Mailer 2007). Demand for canola oil and canola meal (and thus canola seed) has been rapidly increasing in recent years. The canola industry is extremely competitive, and global production has increased by almost 50 per cent over the past five years.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 5 Risks to the health and safety of Risks to markets and trade people and the environment
Responsibility : Department of Health and Ageing Office of the Gene Technology Regulator Legislation: Gene Technology Act 2000 (Commonwealth) Gene Technology Act 2001 (Victoria) Human health & safety Responsibility : State and Territory Governments • Toxicity Legislation : Control of GM Crops Act 2004 (Victoria) • Allergenicity • Carcinogenicity • Impact on domestic trade performance • Pathogenicity • Impact on export trade performance • Endocrine and reproductive effects • Impacts on the markets of non-GM crops • Impacts on the markets associated with other agricultural Environmental risks industries • Harm to protected species • Dairy industry • Harm to non-target organisms • Effects on species diversity/genetic diversity • Pork industry • Creation of new weeds, pests or pathogens • Poultry industry • Beef feedlot industry • Exacerbating the effects of weeds, pests or pathogens • Honey industry • Disruption of biotic communities and ecosystems • Disruption of rare and endangered or highly valued ecosystems • Grains industry, • Harm to abiotic environments • Organics industry • Aquaculture industry • Food industry • Costs and liability associated with co-existence of GM and non-GM markets Safety of food and food products • Impact on our ‘clean green’ image Responsibility : Department of Health and Ageing; Food • Impact on growers choice to grow GM-free Standards Australia and New Zealand • Impact on industry competitiveness Legislation : Food Standards Australia and New • Impact on industry investment in research and development Zealand Act 1991
• Toxicity (using similar methods to those used for conventional foods) • Tendency to provoke any allergic reaction • Stability of the inserted gene • Whether there is any nutritional deficit or change in the GM food • Any other unintended effects of the gene insertion
Figure 1. Management of the risks associated with genetically modified canola in Australia
Issues Paper: Review of the Moratorium on Genetically Modified Canola 6 To compete globally, canola varieties have been bred to improve yields, reduce costs of production and improve oil content and quality. A particularly important development has been the breeding of herbicide tolerant crops, which allows chemical based weed control without affecting the crop. In canola, herbicide tolerance has been introduced using both conventional breeding methods and gene technology (see box 1).
Box 1: What is gene technology?
Biotechnology is a broad term used to describe any technique that uses living organisms or parts of organisms to make or modify products, or improve plants or animals, or to develop micro-organisms for specific uses in industry, technology, medicine or agriculture. Biotechnology is used, for example, in the production of foods and medicines, the removal of wastes and the creation of renewable energy sources.
Gene technology is one of a number of tools used in some biotechnology processes. The generation of genetically modified plants (for example, GM canola), whereby the genes of a plant are modified, is one of a number of applications of gene technology.
Production systems for canola in Australia are largely based on minimum tillage, whereby the land to be planted is sprayed with herbicide to eliminate weeds before seeding, rather than the land being ploughed. Estimates of the costs of weeds in agriculture vary, but one estimate puts the direct financial impact of weeds at $3.5 billion a year, covering both production losses and control costs (Plant Health Australia 2002). In Australia, the use of herbicide tolerant canola is a relatively new technology. Conventionally bred herbicide tolerant canola was introduced into commercial production in 1994 and has been readily adopted by Australian growers. The first commercial herbicide tolerant canola varieties contained inbred tolerance to triazine herbicides (for example, Gesaprim®). Triazine tolerant (TT) canola varieties were developed by conventional breeding methods from naturally mutated plants found in Canada. TT canola varieties are less energy efficient than non-triazine tolerant canola, yielding 10 –30 per cent less seed and lower oil content than conventional canola yields (Carmody, Page & Walton 2001). Compensating for this lower yield, however, is the ability of growers to better manage weeds and also sow their canola crop earlier (Carmody, Page & Walton 2001). In 2000, a canola variety with inbred tolerance to imidazolinone herbicides (for example, Clearfield®) was introduced. The seed of this variety is sold with the herbicide as ‘production units’. The Clearfield® trait can does not carry the inherent yield penalty of TT canola (Carmody, Page & Walton 2001).
Issues Paper: Review of the Moratorium on Genetically Modified Canola 7 The use of herbicide tolerant canola has produced a major shift in cropping in southern Australia, essentially due to superior weed control (Carmody, Page & Walton 2001). Effective weed control can increase yield and thus increase the value of the crop. The use of herbicide tolerant canola increases the weed management options available to growers, such as using fewer types of chemical and having greater flexibility in timing operations to adjust to variable climatic conditions. Additional weed management benefits include the chemical thinning of crops, increased seed purity and the cultivation of new areas of land where weed problems previously made growing the crop unmanageable and unprofitable. An estimated 80–90 per cent of the canola crop of Western Australia and 30– 40 per cent of the canola crop of the remaining states comprise conventionally bred herbicide tolerant canola (Norton 2003).
1.2 Genetically modified canola varieties in Australia
In July 2003, the Federal Office of the Gene Technology Regulator (OGTR) issued a licence (DIR 021/2002) to Bayer CropScience Pty Ltd, approving the commercial release of seven GM InVigor® hybrid canola lines. InVigor® canola consists of a unique hybrid breeding system using a male sterility gene ( barnase ) and a fertility restorer gene ( barstar ), both derived from a common soil bacterium. The InVigor® technology enables production of hybrid seed, which allows increased plant vigour and seed production. An additional gene ( bar ) confers resistance to the active ingredient in the herbicides Liberty®, Basta® and Finale®. The Australian Pesticides and Veterinary Medicines Authority (APVMA) has registered the herbicide Liberty® for use with InVigor® canola crops. In December 2003, the OGTR issued a licence (DIR 020/2002) to Monsanto Australia Ltd for the commercial release of GM Roundup Ready® canola. Herbicide tolerance is enabled by the introduction of two genes from a common soil bacterium. The Monsanto Roundup Ready® GM canola is tolerant to the herbicide glyphosate, which is the active constituent of a range of proprietary broad spectrum herbicides (including Roundup®) registered by the APVMA. Glyphosate is also registered for use in nonselective (general) weed control in broadacre agriculture, horticulture and non-cropped areas (including industrial areas and roadsides), and it is a widely used chemical in all these situations. It kills plants by inhibiting an enzyme in a biochemical pathway for the synthesis of aromatic amino acids. This pathway is not present in mammalian, avian or aquatic animals. Monsanto Australia Ltd has licenced Roundup Ready® canola technology to Pioneer Hi-Bred Pty Limited and Nufarm Limited, and has also sold Nufarm Limited its Roundup Ready® canola germplasm, developed specifically for the Australian market between 1996 and 2003.
1.3 Genetically modified crops: an international perspective
International agricultural commodity markets accept large volumes of GM crops in addition to canola: for example, soybeans, maize and cotton (see
Issues Paper: Review of the Moratorium on Genetically Modified Canola 8 Brookes & Barfoot 2006; Fernandez-Cornejo 2005; Gomez-Barbero & Rodriguez-Cerezo 2006; James 2006; Trigo & Cap 2006). In the three years to 2005-06, more than 60 per cent of the world trade in soybeans, maize, canola and cotton came from countries that grew GM varieties (USDA 2007). In the case of soybeans, world trade is dominated by GM varieties, with only 8 per cent of trade in certified non-GM soybeans (Foster & French 2007). In 2006, 10.6 million farmers in 22 countries (11 developing and 11 industrial) planted 102 million hectares of GM crops (James 2006). Six countries in the European Union (France, Germany, Spain, the Czech Republic, Portugal and Slovakia) are now planting commercial GM crops, predominantly insect tolerant maize. The global area planted to GM crops has increased more than 60-fold over the first 11 years of commercialisation, reputedly making GM crops the fastest adopted crop technology in recent history (James 2006).
1.4 Genetically modified crops in Australia
GM cotton, tolerant to herbicides and/or resistant to insects, is the only Australian broadacre GM crop grown by farmers. In 2005-06, more than 840 000 tonnes of Australian cotton were produced over 335 000 hectares in New South Wales and Queensland (Australian Bureau of Statistics 2006). The Australian cotton industry is valued at approximately $1.5 billion, with GM varieties making up 90 per cent of all cotton grown. This is the maximum proportion of GM cotton that can be grown, given the isolation and trap crops required for GM cotton production as part of sustainable pest management. Apart from cotton lint, the uses of GM cotton seed almost mirror those of canola: GM cotton seed protein meal is used in the animal feedlot industry and the dairy industry, and as drought feed for cattle, while cotton seed oil is used extensively in commercial cooking in Australia.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 9 2. Addressing risks of genetically modified organisms in Australia
This section outlines the current national and state regulatory approaches to addressing the risks of GM crops.
2.1 Australian regulation of genetically modified organisms
Through an Intergovernmental Gene Technology Agreement (IGA) on the regulation of gene technology, the Australian Government and the governments of all states and territories have implemented a national gene technology regulatory system. This agreement includes the Commonwealth Gene Technology Act 2000 and mirror legislation in all states and territories (for example, Victoria’s Gene Technology Act 2001 ), which underpin the regulatory system. Federal, state and local government agencies all have responsibilities in the national regulatory framework. The Australian Government is responsible for assessing any potential risks associated with a genetically modified organism (GMO), including GM crops, with respect to the safety of human health and the environment . Through the IGA and a policy principle established within the Commonwealth’s Gene Technology Act, the states and territories are responsible for identifying and managing risks posed to markets and trade . GMOs are assessed on a case- by-case basis. Four federal agencies have responsibility for the regulation of gene technology in Australia, including GM crops: the OGTR, FSANZ, the Australian Pesticides and Veterinary Medicines Authority (APVMA) and the Australian Quarantine and Inspection Service (AQIS). Appendix 5 contains further details on these bodies. Independent statutory reviews of the Australian Government’s Gene Technology Act and the mirror Victorian Gene Technology Act were recently completed. These reviews found that the Acts are achieving their purpose, but recommended refinements to streamline the operation of the Acts and their Regulations. These refinements will be implemented by amending the Acts. A copy of the statutory review of the Commonwealth Gene Technology Act can be found at www.health.gov.au/internet/wcms/publishing.nsf/ content/gtreview-report.htm . A copy of the statutory review of the Victorian Gene Technology Act can be found at www.health.vic.gov.au/biotechnology/ downloads/report_review_of_gene_act.pdf .
2.1.1 Safety of human health and the environment The OGTR has developed a risk analysis framework that describes the principles of risk analysis used to protect the safety of human health and the environment. A critical part of the risk analysis process provides for assessing the potential hazards of releasing a GMO into the environment. The types of hazard examined include the potential toxicity to humans or other organisms; the likelihood of the GMO producing a substance that causes an allergic reaction in humans; the unintended selection, invasion
Issues Paper: Review of the Moratorium on Genetically Modified Canola 10 and persistence (weediness) of the GMO on and off farm; and any unintentional effects on non-GM plants, pests or pathogens. Following the risk assessment, the regulator prepares a risk assessment risk management plan (RARMP), which is made available for expert scrutiny and public consultation. A copy of the OGTR’s risk analysis framework can be found at www.ogtr.gov.au/pdf/public/raffinal2.2.pdf . To date, the OGTR has approved nine licences for commercial or general release of GMOs. However, states may limit full commercial production on the basis of risks posed to markets and trade. A list of all regulator approved licences for intentional release into the environment can be found at www.ogtr.gov.au/gmorec/ir.htm .
2.1.2 Genetically modified food safety and labelling GM food safety in Australia is the responsibility of FSANZ. All GM food or ingredients to be sold in Australia must undergo a mandatory pre-market safety assessment by FSANZ to ensure they are safe for human consumption. Details of GM products, processing aids and food additives approved by FSANZ can be found at www.foodstandards.gov.au/foodmatters/gmfoods/ index.cfm . FSANZ’s process for assessing the safety of GM foods is based on concepts and principles developed by international organisations such as the World Health Organization (WHO), the Food and Agriculture Organization (FAO) of the United Nations, the Organisation for Economic Co-operation and Development (OECD) and the Codex Alimentarius Commission. FSANZ examines any differences between the existing food and the new GM products (that is, the ‘substantial equivalence’). The assessment investigates toxicity, any tendency to provoke an allergic reaction, the stability of the inserted gene, whether there is any nutritional deficit or change, and unintended effects of the inserted genes. A GM food will be approved for sale only if it is safe and as nutritious as its conventional counterparts. Since December 2001, Australia has had a mandatory labelling regime that requires all GM food sold in Australia to be labelled. If a food, food ingredient, additive or processing aid has come from an approved GM food, it must be labelled with the words ‘genetically modified’. Foods that do not need to be labelled include highly refined foods that contain no DNA or protein (for example, processed oil from GM soybeans or canola), and foods in which GM ingredients make up less than 1 per cent of the final food. Any GM foods (or ingredients derived from them) that have passed the FSANZ safety assessment and approval process can be sold in Australia and New Zealand, and used to make other foods. Details of these products can be found at www.foodstandards.gov.au/thecode/assistanceforindustry/ userguides/labellinggeneticallymodifiedfooduserguide/index.cfm .
2.2 Regulation of genetically modified organisms in Victoria
A policy principle established within the Commonwealth Gene Technology Act provides the state and territory governments with the ability to recognise areas, designated under state law, for preserving the identity of GM or non-
Issues Paper: Review of the Moratorium on Genetically Modified Canola 11 GM crops (or both) for marketing purposes. In 2003-04, all state and territory governments except Queensland and the Northern Territory introduced legislated moratoria on GM canola or, more broadly, GM crops, using this policy principle (see table 1). The Government of Victoria introduced the Control of Genetically Modified Crops Act 2004 (the GM Crops Act) to provide legislative control over the commercial cultivation of GM crops in Victoria. The purposes of the GM Crops Act are described in Part 1, Section 1 of the Act and are to: (a) Provide for the making or orders that – (i) designate areas of the State for the purpose of preserving the identity of GM crops or non-GM crops for marketing purposes; and (ii) prohibit or restrict the cultivation of GM crops, or other dealings with GM crops or GM crop related material; (b) Provide an offence for contravening those orders and certain other offences; (c) Allow authorised officers – (i) to monitor compliance with the Act; and (ii) to apply to the Magistrates’ Court for the forfeiture and destruction of GM crops or GM crop related material if an order has been contravened; (d) Deal with related matters.
The Minister for Agriculture created a moratorium Order prohibiting the commercial cultivation of GM canola in Victoria. The GM Crops Act provides, however, for exemptions to such an Order, as determined by the Minister for Agriculture. The exemption provision allows: • for the cultivation of a specified class of GM crop on a limited scale for the purposes of research or development • for dealing with GM crops or a specified class of GM crops, or with GM crops related material, in particular ways. Any request for an exemption is considered on a case-by-case basis; if approved, it must be conducted under conditions set and overseen by the Victorian Government. The Minister for Agriculture has used the exemption Order provisions following applications from Bayer CropScience, the Department of Primary Industries’ science, research and development arm, Nugrain and Pioneer Hi Bred. In Victoria, 12 small-scale research and development trials of GM canola have been conducted since 2004.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 12 Table 1. Summary of Commonwealth, state and territory genetic modification legislation and moratoria Sunset / expiry or review Responsibility Jurisdiction Legislation Moratorium on GM canola / crops date Australian Gene Technology Act 2000 Not applicable. The OGTR approved both GM Not applicable Not applicable Government canola varieties for general (commercial) release.
Victoria Control of GM Crops Act Yes. The commercial cultivation of OGTR The Moratorium Order (attached as Minister for Agriculture 2004 approved GM canola only is prohibited (by Order schedule to the Act) expires 29 under the Act). No other GM crops are affected. February 2008.
New South Wales* Gene Technology (GM Crop Yes. The commercial cultivation of specified GM The Act expires 3 March 2008. Minister for Primary Industries Moratorium) Act 2003 food crops (including GM canola, but excluding GM cotton) is prohibited.
South Australia GM Crops Management Act Yes. The commercial cultivation of all GM food The Act must be reviewed before 29 Minister for Agriculture, Food and 2004 crops is prohibited. April 2008. Fisheries
Western Australia GM Crops Free Areas Act Yes. The commercial cultivation of all GM crops is The Act is to be reviewed after five Minister for Agriculture and Food 2003 prohibited (by Order under the Act). years from 24 December 2003; there is no sunset clause.
Tasmania Genetically Modified Yes. The commercial cultivation of all GM crops is The Act expires five years after Minister for Primary Industries Organisms Control Act 2004 prohibited. commencement, on 16 November and Water 2009.
Australian Capital Gene Technology (GM Crop Yes. The commercial cultivation of all GM crops is The Act expires on a date (not earlier Minister for Health Territory Moratorium) Act 2004 prohibited. than 17 June 2006) to be fixed by the Minister by written notice.
Queensland* No legislation Nil Not applicable Not applicable
Northern Territory No legislation Nil Not applicable Not applicable
* Commercial crops of GM cotton are grown in these states.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 13 3. The canola industry
Canola production and trade have rapidly grown as demand for canola oil and meal has increased. Australia plays an important role in this trade, as the world’s second largest exporter of canola seed. Critical to the increasing trade are the systems of grain handling and storage required to segregate different products to meet the demands of the marketplace. This section outlines the characteristics of this supply chain.
3.1 Global canola production and trade
Global canola seed production has been rapidly increasing over the past five years (see table 2). Canola seed production for 2007-08 is estimated to be 51.4 million tonnes —an increase of 10 per cent on the previous year’s production (USDA 2007). Over the same period, global protein meal and processed oil production is estimated to be 28.6 and 18.8 million tonnes respectively. The majority of canola production is consumed in the country of origin, with an estimated 8 million tonnes of seed, 3 million tonnes of protein meal and 2 million tonnes of processed oil produced for the export market in 2007-08 (USDA 2007). Characteristics of the global production and trade of canola products are available at www.fas.usda.gov/psdonline/ .
Table 2. Global production of canola seed 2002-03 2003-04 2004-05 2005-06 2006-07 Country (’ 000 metric tonnes) Australia 871 a 1 703 1 496 1 441 500 a Bangladesh 233 218 230 248 255 Belarus 60 55 143 150 180 Canada 4 178 6 771 7 728 9 660 9 100 Chile 13 14 14 14 14 China, Peoples Republic 10 552 11 420 13 182 13 050 12 700 of EU-27 11 752 11 185 15 432 15 523 15 991 Ethiopia 17 17 17 17 17 India 4 050 6 800 6 500 7 000 5 800 Japan 1 1 1 1 1 Kazakhstan, Republic of 11 7 4 4 4 Korea, Republic of 2 2 2 2 1 Morocco 1 1 1 1 1 Norway 18 13 10 10 10 Pakistan 235 238 215 181 318 Paraguay 6 10 45 75 150 Russian Federation 115 192 276 303 525 Switzerland 49 44 54 54 50 Ukraine 61 51 149 285 600 United States 697 686 613 718 633 TOTAL 32 922 39 428 46 112 48 737 46 850 a In 2002-03 and 2006-07, canola production in Australia was reduced by the impacts of severe drought. Source: Data from the Foreign Agricultural Service of the US Department of Agriculture (www.fas.usda.gov/psdonline ).
Issues Paper: Review of the Moratorium on Genetically Modified Canola 14 Canada produces around 20 per cent of world canola, with other major producers including China and the European Union (see table 2). Canada and the United States are the only producers of GM canola to date (James 2006), with Canada typically accounting for over 70 per cent of world canola trade (see table 3). Canadian production of canola has reportedly doubled since the inclusion of GM varieties in 1996 (Statistics Canada 2007). In 2005, 4.3 million hectares of herbicide tolerant GM canola varieties were grown in that country, accounting for 82 per cent of Canadian canola production. In 2006, Canada produced 9.1 million tonnes (compared with 3.7 million tonnes in 1996) of canola over 5.3 million hectares, of which 63 per cent was exported (see table 3). Major destinations for Canadian canola include Japan, Mexico and the United States (see table 4). A peak industry body, the Canadian Canola Council, has targeted a 40 per cent increase in Canadian canola production by 2015, to 15 million tonnes.
Table 3. Canadian canola market 2002-03 2003-04 2004-05 2005-06 2006-07 Canola seed (’000 metric tonnes) Production 4178 (12.7) a 6771 (17.2) 7728 (16.8) 9660 (19.8) 9100 (19.4) Exports 2421(58.6) 3763 (68.7) 3493 (71.8) 5411 (77.6) 5750 (80.9) Imports 240 (5.9) 243 (4.7) 108 (2.2) 140 (2.1) 160 (2.3) Canola oil Production 920 (7.5) 1425 (10.1) 1273 (8.1) 1424 (8.3) 1530 (8.6) Exports 529 (59.0) 982 (74.8) 971 (75.3) 1093 (63.6) 1200 (60.7) Imports 27 38 42 61 45 Canola protein meal Production 1250 (6.6) 1935 (8.9) 1730 (7.2) 1935 (7.4) 2055 (7.6) Exports 823 (51.0) 1572 (64.0) 1414 (63.2) 1488 (57.7) 1597 (53.4) Imports 30 2 2 1 1 a The numbers in parentheses are the percentage of world production and trade. Source: Data from the Foreign Agricultural Service of the US Department of Agriculture (www.fas.usda.gov/psdonline ).
Table 4. Predominant destinations of Canadian canola exports 2002 2003 2004 2005 2006 Destination (’000 metric tonnes) Japan 1557 1682 1642 1915 1982 European Union 8 2 2 2 2 Bangladesh 0 13 22 23 87 China 66 319 324 367 543 United States 157 113 453 443 668 Pakistan 0 398 49 167 664 Mexico 489 693 1,066 1,049 1,109 Source: Data from ABARE ( www.abareconomics.com/ ).
3.2 The Australian canola industry
Canola is Australia’s third largest broadacre crop after wheat and barley, and it is widely grown across south east Australia and in Western Australia. During the 2004-05 season, 1.5 million tonnes of canola were produced over 1.3 million hectares, at a gross value to the economy of $503 million (Australian Bureau of Statistics 2006). Of this production, 60 per cent (896
Issues Paper: Review of the Moratorium on Genetically Modified Canola 15 000 tonnes) was exported as seed, with only small quantities of oil and virtually no canola meal exported (see tables 5 and 6). These exports accounted for 19 per cent of world canola (seeds and processed oil) trade. Almost half of Australia’s exported unprocessed canola is sent to Japan (Foster & French 2007).
Table 5. Australian canola market 2002-03 a 2003-04 2004-05 2005-06 2006-07 a Canola seed (’000 metric tonnes) Production 871 (2.6) b 1703 (4.3) 1496 (3.2) 1441 (2.9) 500 (1.1) Exports 502 (12.2) 1206 (22.0) 896 (18.4) 820 (11.7) 350 (4.9) Imports 0.21 0.23 0.11 0.14 57 Canola oil Production 161 (1.3) 175 (1.2) 184 (1.2) 184 (1.1) 184 (1.0) Exports 30 (3.3) 52 (4.0) 40 (3.1) 29 (1.7) 30 (1.5) Imports 10.48 1.27 1.22 2.10 20 Canola protein meal Production 230 (1.2) 250 (1.1) 264 (1.1) 264 (1.0) 265 (1.0) Exports 0 0 0 0 0 Imports 0 11 0 0 0 a In 2002-03 and 2006-07, canola production in Australia was reduced by the impacts of severe drought. b The numbers in parentheses are the percentage of world production and trade. Sources: Data from ABARE ( www.abareconomics.com/ ) and the Foreign Agricultural Service of the US Department of Agriculture ( www.fas.usda.gov/psdonline ).
Table 6. Destination of Australian canola exports 2002 2003 2004 2005 2006 Destination (’000 metric tonnes) Japan 446 379 681 396 312 European 63 1 94 0 287 Union Bangladesh 115 81 103 66 30 China 386 0 2 40 3 Malaysia 11 1 3 0 - Pakistan 307 142 289 326 50 Source: Data from ABARE ( www.abareconomics.com/ ).
Canola production in Victoria during the 2004-05 season was 342 500 tonnes, valued at $104.5 million (see table 7) (Australian Bureau of Statistics 2006). In 2005-06, Victoria accounted for 16 per cent of Australia’s canola exports (around 131 000 tonnes), with a combined value of exports to Japan and Germany close to $50 million (see table 8). The main domestic consumers of Australian canola are the oilseed processing industry (which includes the processed oil and protein meal markets) and the certified seed industry for re-planting. The certified seed industry in Australia is an important source of quality assured seed varieties, including hybrid seed (such as InVigor® GM canola) that must be sourced each season. Although the use of farmer saved seed is also common practice in Australia, Technology User Agreements associated with GM canola varieties may preclude this practice. In 2003-04, 132 tonnes of canola seed were certified under the Organisation for Economic Co-operation and Development’s (OECD) seed certification schemes. Detailed statistics on
Issues Paper: Review of the Moratorium on Genetically Modified Canola 16 certified seed production in Australia are available from the Australian Seeds Authority (2006).
Table 7. Production of canola in Australia, by state 2002-03 2003-04 2004-05 2005-06 State (’000 metric tonnes) New South Wales 184.0 438.0 468.0 253.8 Victoria 177.0 384.0 342.0 337.5 Queensland 0.0 0.0 1.0 1.0 Western Australia 299.0 527.0 488.0 630.0 South Australia 210.0 354.0 242.0 217.5 Tasmania 0.8 0.0 1.0 1.0 TOTAL 871.0 1703.0 1542.0 a 1440.8 a ABARE estimates differ from the US Foreign Agriculture Service estimates shown in tables 2 and 5. Source: Data from ABARE ( www.abareconomics.com/ ).
Table 8. Value of canola seed and oil exports from Victoria (A$) Export destination 2002-03 2003-04 2004-05 2005-06 Japan 9 984 040 73 988 724 93 923 053 26 003 778 Germany 0 0 0 22 826 452 Belgium 497 754 3 773 634 4 760 161 2 286 812 Pakistan 59 511 141 331 2 274 667 2 219 414 United Arab Emirates 579 423 197 361 913 225 537 454 Total $11 120 728 $78 101 050 $101 871 106 $53 873 910 Source: Data from Trade Data International (2007).
3.3 Additional uses of canola
Canola was first grown commercially in Australia in 1969 and is important in crop and livestock rotations. The use of canola as a ‘break crop’ in rotations with wheat can have environmental and economic benefits (see, for example, Angus, Kirkegaard & Peoples 2001). When canola roots start to decay, they produce residues (isothiocyanates) that suppress many soil borne fungal diseases of plants (sometimes referred to as biofumigation). Practically, this means fungal diseases are less prevalent in the cereals sown the following year because subsequent cereal crops develop healthier root systems. Biofumigation of major cereal root diseases by canola break crops has been reported to provide up to a 20 per cent yield benefit for wheat after a canola crop (Angus, Kirkegaard & Peoples 2001). Biodiesel is an emerging new use for canola. Globally, the European Union is the largest producer and consumer of biodiesel. Around 80 per cent of the biofuel produced in the European Union is biodiesel, of which the largest component is from canola oil (80 per cent) and the remainder is from sunflower and soybean oil (Bendz 2006).
Biodiesel production in the European Union was 2.9 million tonnes in 2005 — an increase of 65 per cent from 2004 production. The major producers of biodiesel are Germany, France and Italy. Biodiesel production is expected to increase to 6.1 million tonnes in 2007, with Germany estimated to produce 3 million tonnes (Bendz 2006). In March 2007, due to the increased demand for biodiesel, the European Commission authorised for the EU market three
Issues Paper: Review of the Moratorium on Genetically Modified Canola 17 Bayer CropScience canola varieties genetically modified for tolerance to the herbicide glufosinate-ammonium. The decision is valid for 10 years and covers seed imports of these canola varieties and their processing into animal feed or for industrial purposes such as biodiesel production. It includes measures (for example, monitoring and reporting practices) that Bayer CropScience must take to prevent any damage to health and the environment in the event of accidental spillage. Processed oil derived from GM canola was approved in the European Union for food and biofuel use in 1999 and 2000 respectively.
3.4 Marketing in the grain industry
Canola, like other grains produced in Victoria, is a bulk handled commodity and is passed through a grain handling and storage network from the farm to domestic and export markets. This network of trucks, trains, grain silos and container ships moves and stores all the major grains produced in the state, such as wheat, barley, canola and pulses such as field peas, faba beans, lentils and chickpeas. In the process from growing to bulk handling of grains, segregation, co-mingling and market requirements are important considerations. These considerations vary across grain products and markets. Although most cropping areas in the state grow canola, there are only four major bulk grain handlers and marketers: ABB Grain Limited (www.abb.com.au ), GrainCorp Limited ( www.graincorp.com.au ), AWB Limited (www.awb.com.au ) and Australian Bulk Alliance ( www.bulkalliance.com.au ). The grain supply chain in Victoria can be defined as a highly fragmented production base narrowing to a highly concentrated handling and marketing system (ACIL Tasman & Farm Horizons 2003). The grain supply chain in Victoria is summarised in figure 2 and detailed in Foster (2006) and ACIL Tasman and Farm Horizons (2003).
3.4.1 Grain supply chain management To fully accommodate market demand for product differentiation, it is important to segregate or preserve the identity of grain and grain products through the supply chain. As such, a range of management strategies exist along the supply chain to accommodate market demands. These include: • stewardship strategies underpinned by on-farm crop management plans that may consist of neighbour agreements, machinery and storage hygiene practices and technology user agreements • industry codes of practice that support market requirements for grain quality • regulation (such as regulated access to export grain handling and storage facilities in the ports of Geelong and Portland, overseen by the Essential Services Commission).
Issues Paper: Review of the Moratorium on Genetically Modified Canola 18 3.4.2 Meeting grain market requirements The Australian grains industry accommodates many segregated commodities. Typically, grain is graded and segregated to suit a particular market. Each year, more than 50 different wheat products are exported (www.awb.com.au/ ). Wheat is often graded and segregated, for example, based on protein content and quality, grain hardness, starch quality characteristics and grain handler/marketer receival standards. Australian wheat is classified into six major market grades, including Australian Prime Hard (APH), Australian Hard (AH), Australian Premium White (APW), Australian Standard White (ASW), Australian Soft (AS) and Australian Premium Durum (APDR). Several of Australia’s major wheat markets (for example, Japan and the Republic of Korea) require pesticide residue free (PRF) grain with organophosphate levels of less than 0.1 milligram per kilogram. To accommodate this demand, grain is tested and graded as PRF and kept in designated storages at bulk handling centres, and the identity is preserved through the export terminal. Similarly, barley is graded in each state as either malting or feed barley. In another example, the export of polished white rice to the highly sensitive Japanese market requires special segregation procedures developed to ensure the rice is virtually free from impurities. This process includes agreed cleaning procedures for the entire grain supply chain. Other examples of segregation include a 0.5 percent threshold of canola seed in wheat exports, the segregation of organic products from conventionally grown products, and the segregation of high erucic acid rape from canola. In 2005, the Primary Industries Ministerial Council (PIMC), comprised of ministers from the Australian Government and each state and territory, agreed to thresholds for the adventitious presence of GM canola in conventional grain and seed. The threshold levels of 0.9 per cent of GM in non-GM grain and 0.5 per cent of GM in non-GM seed for sowing were introduced in all Australian canola growing states except Tasmania. Major canola importing countries have specific laws that deal with the use, trade and labelling of GM products. Imports into Japan, for example, allow for the presence of up to 5 per cent of an individual approved GM ingredient in a product before labelling is required. A tolerance of 1 per cent adventitious presence of GM material is allowable where the GM variety has not been approved by Japanese authorities but has received safety approval from authorities in the exporting nation. Highly processed foods such as canola oils are exempt from labelling. In the European Union, all imports of GM products must gain Novel Foods Regulations approval. Following the EU moratorium on GM in 1998, several import approvals have been granted primarily for use in processing for animal feeds and more recently for use in biofuel production. Further, any intentional use of GM ingredients at any level above 1 per cent must be labelled.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 19 3.5 International and Australian organic industries
By definition, organic production excludes GM crops. With global certified organic production having increased by an estimated 8 million hectares since 2002, to over 31 million hectares in production in 2005 (Apted & Mazur 2007), the co-existence of GM crops and organic production is of interest. Although there are no official census data on the extent of the organics industry in Australia, an estimated 8–12 million hectares were under certified organic management in 2005, accounting for around 2.5 per cent of agricultural land (Yussefi & Willer 2007). The majority of the organic land is low rainfall pastoral lands used for the grazing of beef cattle on large expansive areas. A summary of the Australian organics industry can be found at www.daff.gov.au/__data/assets/pdf_file/0006/183192/australian_ organic_industry_summary.pdf . Australian exports of organic products were estimated at $50 million in 2002, with more than 50 per cent exported to the European Union and the remainder going to Japan, Switzerland and the United States (Apted & Mazur 2007). Organic cereals (predominantly wheat) accounted for over 70 per cent of exports, which also comprised oilseeds and oilseed products (sunflower and canola based) (10 percent), fruit and vegetables (7 per cent), meat and wine (3 per cent) and honey (1 per cent) (Apted & Mazur 2007).
Organic production in Victoria is worth about $32 million per year to the state economy and includes a broad range of organic fruit, vegetables, nuts, meat (beef, lamb, pork and poultry), wine grapes and grains. Victoria is Australia’s leading producer of organic milk and the leading organic food processor, particularly of dairy products, fruit juices, flour and flour mixes (Australian Bureau of Statistics 2006). Data on the extent and value of organic oilseed production in Victoria are limited. But details of certified organic producers and processors of oilseeds in Victoria can be found in the Victorian Organic Food Products Directory 2007 at www.business.vic.gov.au/busvicwr/_assets/main/lib60010/organicfooddirec tory.pdf .
Issues Paper: Review of the Moratorium on Genetically Modified Canola 20 Contract services • Sowing Schematic of the grain supply chain Export • Spraying customer • Harvesting • Storage
Sea Freight Grain accumulation On-farm • Receival Port terminal • Planting • Grain declaration Road Transport Road and Rail Transport • Grain quality testing • Harvesting • Quality testing • Segregation and/or • Storage • Grading co-mingling • Planting seed retention • Segregation and/or co-mingling • Storage and fumigation
Road Transport Road and Rail Transport
Seed supplier/retailer Grain processing • Certified seed ONLY Protein meals ‘the crush’ Road Transport
Road and Rail Transport Road Transport Grain production Grain accumulation
Road Transport Domestic market Processed oils Food industry Stock feed industry
Export market
Figure 2. Schematic representation of the grain supply chain. A more detailed description of the grain supply chain can be found in Foster (2006) and ACIL Tasman and Farm Horizons (2003).
Issues Paper: Review of the Moratorium on Genetically Modified Canola 21 4. Economic impacts of the moratorium on genetically modified canola
The moratorium on the commercial cultivation of genetically modified (GM) canola in Victoria was implemented for economic reasons, primarily to protect Victoria’s agricultural markets and international competitiveness, both for canola itself and for other products. The first term of reference for this review is thus to assess to date the economic impacts on Victoria of the moratorium. These economic effects are the benefits and costs to consumers and users, farmers and other producers along the supply chain, exporters and importers, both in Victoria and in the rest of Australia. They are felt at the individual level and also at the level of entire industries and the communities in which they operate.
4.1 Studies relevant to the terms of reference
A number of studies are relevant to the terms of reference of this Review. In 2003, an independent review was commissioned by the Government of Victoria to consider the potential market impact of commercially releasing GM canola in Victoria, and to determine industry’s preparedness and capacity to segregate GM canola from non-GM canola and other grains, through the supply chain. The review was undertaken in two stages. In the first stage, independent consultants ACIL Tasman and Farm Horizons reviewed the technical matters, collected data and consulted with relevant stakeholders. This information was passed on to independent reviewer Professor (Emeritus) Peter Lloyd to undertake the second stage of the review. In his final report, Professor Lloyd detailed findings and recommendations to the State Government concerning the future of GM canola in Victoria, including the impacts on markets (Lloyd 2003). A copy of the reports can be found at www.dpi.vic.gov.au . The Agriculture and Food Policy Reference Group (chaired by Peter Corish) was established in March 2005 to review policies and develop recommendations for improving the profitability, competitiveness and sustainability of the Australian agriculture and food sector over the next 10– 15 years. A report, Creating our Future, Agriculture and Food Policy for the Next Generation , was submitted to the Australian Government Minister for Agriculture, Fisheries and Forestry in 2006 and outlined what the group identified as the principal issues and challenges facing the sector (Corish 2006). Recommendations were made to the Australian Government relating to each of the key issues and challenges requiring government attention, including access to opportunities offered through gene technology and GM crops. A copy of this report can be found at www.agfoodgroup.gov.au/next_generation.html . In March 2007, the Australian Bureau of Agricultural and Resource Economics (ABARE) released a report on the market acceptance of GM canola (Foster & French 2007). The purpose of the ABARE report was to identify the domestic and international market related issues relevant to any decision to adopt GM canola in Australia. The report assessed the market acceptance of GM canola in Australia’s domestic and export markets. It complements another ABARE report (on identity preservation) that addressed the costs of
Issues Paper: Review of the Moratorium on Genetically Modified Canola 22 keeping GM and non-GM grains separate throughout the Australian grain supply chain (Foster 2006). A copy of these reports can be found at www.abareconomics.com/ . ABARE also recently released a report on the potential impacts of the commercialisation of GM canola on the Australian organic canola, livestock and honey industries (Apted & Mazur 2007). The report addressed three questions relating to the organics industry if GM canola is commercialised in Australia: 1. What are the implications for Australia’s organic farm exports? 2. What will be the economic consequences of GM material avoidance measures? 3. Will those consequences be different if non-zero thresholds are set for the unintentional presence of GM material? A copy of this report can be found at www.abareconomics.com/ .
4.2 Economic benefits and costs of the moratorium
The Review panel is seeking information from participants about the moratorium’s economic benefits and costs that they have observed. Where possible, relevant copies of reports, facts and figures and/or case studies should be provided to support views. 1. For household consumers of canola products (for example, canola oil), what benefits and/or costs have been observed in relation to: • prices? • supply? • quality and range? • quality assurance? 2. For user industries, what benefits and/or costs have been observed in relation to the following canola inputs to production: • Prices for domestic and export products in various markets (for example, evidence of price premiums for goods produced using non-GM canola)? • Production costs and productivity? • Productivity and profitability in the short and long term? • Quality? • Quality assurance/documentation of GM status? • Export market reputation? Have you or others in your industry used imported GM canola or canola products, and if so, what were the effects on the matters listed above? 3. For farmers, what benefits and/or costs have been observed in relation to: • prices for domestic and export canola in various markets (for example, evidence of price premiums for non-GM canola)? • supply to the Australian and export markets? • production costs at all stages? • productivity and profitability in the short and long term? • the international competitiveness of Victorian canola? • quality and range? • quality assurance/documentation of GM status? • export market access?
Issues Paper: Review of the Moratorium on Genetically Modified Canola 23 • export market reputation? • contamination of other crops (for example, for growers using canola in crop rotation, or organic producers)? • access to new varieties? • research and development in canola? • sustainability on farm? 4. For others involved in the broader canola industry and associated industries such as wheat and barley (including technology suppliers of inputs and the downstream supply chain), what benefits and/or costs have been observed in relation to: • prices for domestic and export canola in various markets (for example, evidence of price premiums for non-GM canola)? • supply to the Australian and export markets? • production costs at all stages? • productivity and profitability in the short and long term? • the international competitiveness of Victorian canola? • quality? • quality assurance/documentation of GM status? • export market reputation? • export market access? • contamination of other crops and products (for example, wheat transport, storage and marketing)? • access to new varieties? • research and development in canola? • sustainability? 5. For the organic and certified GM-free food sectors, what benefits and/or costs have been observed in relation to any of the matters mentioned above? 6. For technology providers, what cost has the moratorium had on the research and development of canola? 7. For technology providers, what benefits and/or costs have been observed in relation to the provision of exemptions under the current moratorium Order? 8. For communities in canola producing and using regions, what benefits and/or costs have been observed in relation to any of the matters mentioned above?
Issues Paper: Review of the Moratorium on Genetically Modified Canola 24 5. Potential policy changes
The second term of reference is to recommend whether the Victorian moratorium should be allowed to expire, and if so, to recommend any complementary policies and practices required to address the likely consequences that are identified. Potential policy change must also be considered in relation to policy changes expected in other jurisdictions. Many other countries are reviewing their approaches to production and import of genetically modified (GM) canola. In a national context, other states that have prohibited the commercial cultivation of GM canola or, more broadly, GM food crops are also reviewing (or intend to review) their moratoria.
5.1 Should the moratorium be extended or terminated?
In considering whether the moratorium should be extended, the following questions must be addressed: 1. Has the moratorium achieved its objectives? 2. Have the benefits of the moratorium exceeded its costs? Has it been a net economic benefit or cost to the Victorian community and the industry? 3. What are the net benefits or costs likely to be in the future, particularly in the face of changes to import restrictions or public attitudes to GM crops in export markets? 4. If the economic costs are likely to exceed the benefits in the future, should the moratorium be allowed to expire? 5. What are the key areas of uncertainty that could affect decision-making? 6. If the moratorium were lifted, what would be the likely adoption of GM canola by Victorian farmers? Why? 7. Are the impacts of the moratorium likely to reduce growers’ profitability and competitiveness sufficiently to impede the growth of the industry? 8. What would be the likely impacts on canola research and development of extending the moratorium? 9. Regardless of the economic impact, is it feasible to continue the moratorium if the other canola producing states in Australia do not?
5.2 Other measures?
The terms of reference also ask that the Review panel recommend any complementary policies or practices required to address the likely consequences of the moratorium ending. 1. What production, transport, storage and handling measures would be required to ensure the integrity of non-GM canola and other crops if the moratorium were lifted? 2. If the moratorium were lifted, would current threshold levels for the unintended presence of GM canola in other crops or agricultural products be adequate?
Issues Paper: Review of the Moratorium on Genetically Modified Canola 25 3. What would be the costs of segregation, verification, tracking and documentation of GM canola? 4. Could the grain production and handling system be modified to accommodate the co-existence of GM and non-GM canola, and if so, at what cost? And who should pay the cost? 5. Is the price premium for non-GM canola sufficient to justify a dual handling and storage system? 6. Should financial measures such as performance bonds be required? 7. Would insurance against loss from the unintended presence of GM canola be available? And at what cost? 8. What other measures should be introduced? Why?
Issues Paper: Review of the Moratorium on Genetically Modified Canola 26 6. Further reading
ACIL Tasman & Farm Horizons (2003). Genetically modified Canola: Market Issues, Industry Preparedness and Capacity for Segregation in Victoria , Melbourne. Angus J.F., Kirkegaard J.A. & Peoples M.B. (2001). Rotation, Sequence and Phase: Research on Crop Pasture Systems , Proceedings of the Australian Agronomy Conference, Australian Society of Agronomy, Hobart. www.regional.org.au/au/asa/2001/index.htm Apted S. & Mazur K. (2007). Potential Economic Impacts from the Introduction of GM Canola on Organic Farming in Australia , ABARE Research Report 07.11, prepared for the Australian Government Department of Agriculture, Fisheries and Forestry, Canberra. Australian Seeds Authority (2006). Fourth Annual Report 2005-2006 , Melbourne ( www.asf.asn.au/pdf/ASA%20ANNUAL%20REPORT%202005-06%20 Final%208Aug06.pdf ). Australian Bureau of Statistics (2006). 2006 Year Book Australia . Cat. no. 1301.0, Canberra. Bendz K. (2006). EU-25 Oilseeds and Products Update 2006 , Grain Report no. E36146, Foreign Agricultural Service, US Department of Agriculture, Washington DC. Brookes G. & Barfoot P. (2006). GM Crops: the First Ten Years—Global Socio- Economic and Environmental Impacts , ISAAA Brief no. 36. International Service for the Acquisition of Agri-biotech Applications, Ithaca, New York. Carmody P., Page M. & Walton G. (2001). Canola Varieties for 2001 , Farmnote 12/2001, Western Australian Department of Agriculture, Perth. Corish P. (2006). Creating our Future: Agriculture and Food Policy for the Next Generation , Report to the Minister for Agriculture, Fisheries and Forestry, Agriculture and Food Policy Reference Group, Canberra. Fernandez-Cornejo J. (2005). ‘ Adoption of genetically engineered crops in the U.S’ , Economic Research Service, United States Department of Agriculture. Foster M. (2006). GM Grains in Australia: Identity Preservation , ABARE Research Report 06.25, prepared for the Australian Government Department of Agriculture, Fisheries and Forestry and the Grains Research and Development Corporation, Canberra. Foster M. & French S. (2007). Market Acceptance of GM Canola , ABARE Research Report 07.5, prepared for the Australian Government Department of Agriculture, Fisheries and Forestry, Canberra. Gomez-Barbero M. & Rodriguez-Cerezo E. (2006). Economic Impact of Dominant GM Crops Worldwide: a Review , European Commission, Joint Research Centre, Seville, Spain. James C. (2006). Global Status of Commercialised Biotech/GM Crops: 2006 , ISAAA Brief no. 35-2006, International Service for the Acquisition of Agri- biotech Applications, Ithaca, New York. Lloyd P.J. (2003). Review of Market Impacts of Genetically Modified Canola and Industry Preparedness , Report of the independent reviewer to the Victorian Government, Victorian Department of Primary Industries, Melbourne. Issues Paper: Review of the Moratorium on Genetically Modified Canola 27 Norton R. (2003). Conservation Farming Systems and Canola , University of Melbourne, Avcare. Plant Health Australia (2002) National Weeds Workshop—Workshop Proceedings. 19-20 February 2002 , Canberra, Australia. (www.planthealthaustralia.com.au/project_documents/uploads/Weeds_works hop_proceedings.pdf). Spragg J. & Mailer R. (2007). Canola Meal Value Chain Quality Improvement , Final report prepared for the Australian Oilseeds Federation and the Pork Co- operative Research Centre, Melbourne. Statistics Canada (2007). Field Crop Reporting Series 3. Catalogue No. 22- 002-XIB, Vol 86, no. 3, Seasonal/ISSN 1488-9900. Trade Data International (2007). Export Statistics. Australian Bureau of Statistics, Canberra. Trigo E.J. & Cap E.J. (2006). Ten Years of Genetically Modified Crops in Argentine Agriculture , Argentine Council for Information and Development of Biotechnology, Buenos Aires, Argentina. USDA (US Department of Agriculture) (2007). Production, Supply and Distribution Online. Foreign Agricultural Service, Washington DC (http://www.fas.usda.gov/psdonline ). Warwick SI, Francis A., La Fleche J. (2000) Guide to the Wild germplasm of Brassica and allied crops (tribe Brassiceae, Brassicaceae) 2nd Edition. www.brassica.info/resources/crucifer_genetics/guidewild.htm (editor Graham King) Rothamsted. Yussefi M. & Willer M (2007), The World of Organic Agriculture, Statistics and Emerging Trends 2005 , International Federation of Organic Agricultural Movements (IFOAM), Bonn, Germany.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 28 Appendix 1. OGTR media releases
GTR02/03 25 July 2003 Office of the Gene Technology Regulator
RIGOROUS ASSESSMENT CONFIRMS GM INVIGOR ® CANOLA SAFE AS NON-GM CANOLA
Following extensive evaluation and extended public consultation, the Australian Gene Technology Regulator, Dr Sue Meek, announced today that she has decided to issue a licence for the commercial release of Bayer CropScience’s InVigor ® hybrid canola.
“The Australian public can be assured that our rigorous independent assessment of potential health, safety and environmental impacts has found InVigor ® canola as safe to humans and the environment as conventional (non-GM) canola,” Dr Meek said.
This decision is the first step in the phased commercial release of InVigor ® canola in Australia. Bayer CropScience will continue to work with farmers, industry groups and State and Territory governments to ensure a staged and orderly commercial roll-out of InVigor ® canola.
InVigor ® canola has been genetically modified (GM) to contain two new characteristics – a hybrid breeding system and tolerance to the herbicide glufosinate ammonium.
Dr Meek paid tribute to the thoughtful feedback from the public on the Risk Assessment and Risk Management Plan released for public consultation in April 2003 and the input from expert groups and authorities.
“Many submissions raised concerns about the spread of genetically modified canola, the development of herbicide tolerant weeds and the consequences to herbicide use,” Dr Meek said.
“I assure the public that my office (the Office of the Gene Technology Regulator) and the Australian Pesticides & Veterinary Medicines Authority (APVMA) which regulates herbicide use, have comprehensively considered these issues.
“The final version of the Risk Assessment and Risk Management Plan has been expanded to more comprehensively address issues raised, to further explain the conclusions and to incorporate the most up-to-date international research.”
Dr Meek said a number of submissions questioned the feasibility of industry proposals to segregate GM canola from non-GM canola for marketing purposes.
“I reiterate that as Gene Technology Regulator, I am part of the Australian Department of Health and deal exclusively with risks that may be posed by genetically modified organisms (GMOs) to human health and safety or to the environment.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 29
“When the Gene Technology Act was created it was a deliberate measure, agreed to by all Australian governments and Opposition parties, to confine the Regulator’s powers to deal exclusively with health, safety and environment issues. This ensures that the assessment of health and environmental risks cannot be compromised by economic issues, matters that may impact on people’s incomes or the marketability of crops.
“Clearly the marketing implications of my decision regarding the commercial release of canola do not represent a risk to human health or the environment and these issues need to be addressed separately by industry and State governments.”
Dr Meek said the Office of the Gene Technology Regulator has reporting systems in place to identify any human health and safety or environmental issues with any GMO licence and also has the powers to investigate and redress them.
“The APVMA similarly has review systems to deal with chemical use issues should they arise,” she said.
“In addition to these safeguards, and because this is the first licence issued for the commercial release of GM canola in Australia, I intend to report on the implementation of the InVigor® canola release after three years of commercial plantings.
“I will call for public input to the proposed report which I consider to be part of the responsible oversight of the progress of this and other licences for genetically modified crops,” Dr Meek said.
The Regulator’s full determination on the Bayer licence can be found on the Office of the Gene Technology website: www.ogtr.gov.au.
Media inquiries: Kay McNiece, Media Adviser, OGTR 02 6289 5027 or mobile 0412 132 585
Issues Paper: Review of the Moratorium on Genetically Modified Canola 30 GTR004/03 19 December 2003 MEDIA RELEASE
JOINT REGULATORY DECISION ON MONSANTO GM CANOLA
Following rigorous evaluation and extended public consultation, the Australian Gene Technology Regulator, Dr Sue Meek, announced today that she has decided to issue a licence for the commercial release of Monsanto Australia’s Roundup Ready ® canola.
Roundup Ready ® canola has been modified to be tolerant to the herbicide glyphosate, which can then be used to control weeds while the crop is being grown.
Monsanto’s Roundup Ready ® canola has been previously trialed under limited and controlled conditions in Australia over a number of years and is approved for growing and food use in Japan, Canada and the United States of America.
The oil from Roundup Ready ® canola is highly processed which removes DNA and protein. Roundup Ready ® canola oil has been assessed and approved for human consumption in Australia by Food Standards Australia New Zealand (FSANZ).
“We prepared the risk assessment of Monsanto’s application in close consultation with a wide range of expert groups and authorities. I also received valuable input from the extended public feedback process,” Dr Meek said.
“The comprehensive risk assessment has demonstrated to me that the commercial scale release of Roundup Ready canola will not pose a risk to human health and safety or the environment.”
During the evaluation of Roundup Ready ® canola, the potential for development of herbicide-resistant weeds if glyphosate is used inappropriately was identified.
The Australian Pesticides and Veterinary Medicines Authority (APVMA), which is responsible for the registration of agricultural chemicals, has today also approved the use of Roundup Ready ® herbicide for weed control in Roundup Ready ® canola crops.
“The APVMA has also undertaken an extensive assessment of the Roundup Ready ® herbicide during which the potential for the development of herbicide resistance was evaluated,” Dr Meek said.
“As a result, the APVMA has applied a number of conditions on the registration of Roundup Ready ® herbicide to ensure responsible management of Roundup Ready ® herbicide use on Roundup Ready ® canola, and to minimise the risk of development of herbicide resistance.”
Issues Paper: Review of the Moratorium on Genetically Modified Canola 31
Dr Meek said that during the evaluation, concerns were expressed about possible economic and market impacts if Roundup Ready ® canola spreads to adjoining farms.
“I am advised that unwanted Roundup Ready ® canola plants can be effectively removed with a range of approved herbicides and mechanical weed control methods. Using a mixture of weed control options is consistent with integrated weed management practice,” she said.
“I also understand that a number of industry initiatives have also been developed to facilitate segregation of GM from non-GM canola. Industry and State governments are also consulting on the marketability and trade issues, as distinct from health, safety and environmental issues.”
Further information on the Risk Assessment and Risk Management Plan, the evaluation process and the licence is available from the OGTR website at www.ogtr.gov.au .
Media inquiries: Kay McNiece, OGTR Media Adviser 0412 132 585
Further information on the Australian regulatory approvals for Roundup Ready ® canola is available from: OGTR: www.ogtr.gov.au (under What’s New) APVMA: http://services.apvma.gov.au/PubcrisWebApp/ProductDetails?tab=General&prodCode=541 12 FSANZ: http://www.foodstandards.gov.au/standardsdevelopment/applications/applicationa363foodp9 51.cfm)
Issues Paper: Review of the Moratorium on Genetically Modified Canola 32 Appendix 2. Moratorium announcement 2004
Issues Paper: Review of the Moratorium on Genetically Modified Canola 33
Issues Paper: Review of the Moratorium on Genetically Modified Canola 34
Issues Paper: Review of the Moratorium on Genetically Modified Canola 35 Appendix 3. Announcement of Review of GM canola moratorium
FROM THE OFFICE OF THE PREMIER
DATE: Tuesday, May 22, 2007
VICTORIA ANNOUNCES REVIEW OF GM CANOLA MORATORIUM
An independent panel will review Victoria’s moratorium on the commercial planting of genetically modified (GM) canola, Premier Steve Bracks, announced today.
Mr Bracks said the three-person panel, to be chaired by Professor Sir Gustav Nossal, was the next step in the Government’s careful and considered approach to the use of gene technology.
“The panel will consult key stakeholders and invite public submissions before preparing a report to Government later this year,” Mr Bracks said.
“It is vital that we consider carefully, what impact permitting the commercial release of GM canola would have on our producers and exporters.
“The Bracks Government has always taken a cautious approach towards commercialisation of GM canola and this review continues on that course.”
The Victorian moratorium on GM canola was introduced in March 2004 under the Control of Genetically Modified Crops Act, 2004. It is set to expire on February 29, 2008, unless a new moratorium order is introduced.
The Government will appoint the following people to an independent panel to review the moratorium:
• Professor Sir Gustav Nossal (Chair) – Victorian Chief Scientist, prominent immunologist and former Australian of the Year.
• Ms Merna Curnow – Member of the Southern Regional Panel for the Grains Research and Development Corporation (GRDC) and former Chair of the Victorian Farmers Federation Education Committee.
• Christine Forster – Former recent Chairperson of the Victorian Catchment Management Council, a farmer in western Victoria with extensive experience in regional development, rural adjustment issues and water quality and water resources management.
Under a national agreement, the Federal Office of the Gene Technology Regulator (OGTR) has responsibility for assessing the potential human health and environmental risks associated with genetically modified crops. States are responsible for assessing potential trade and market issues.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 36 The Regulator approved the two canola varieties listed under the moratorium in 2003 after it found they posed no greater risk to human health or the environment than conventionally bred canola.
Mr Bracks said while GM canola had been approved at a federal level, the focus in Victoria had always been on what impact the use of GM technology would have on trading capacity and market access.
“The moratorium was put in place for four years in 2004 to allow regular assessment of market conditions,” he said.
“Victoria contributes a quarter of Australia’s food exports worth $5.75 billion, making up 23.7 per cent of Australia’s total agricultural production and it’s essential that we continue building on our strong record.”
Minister for Agriculture, Joe Helper, said the panel represented both expertise and experience across the fields of science, agriculture and rural and regional development issues.
“It brings together the crucial mix of views needed to provide Government with independent, expert, evidence-based advice,” Mr Helper said.
“This review is part of our ongoing research to support Victoria’s agriculture sector and any decision needs to be in the best interests of producers and exporters across the State.”
Sir Gus said he was honoured to be chosen to chair the panel.
“Although the Federal OGTR has approved GM canola for commercial release it is vital that we carefully consider market implications for Victorian producers and exporters,” he said.
“According to the terms of reference, the panel will assess the economic impact on Victoria of the moratorium and recommend whether the Government should allow the moratorium to expire or a new moratorium order be signed.”
Mr Helper said the panel’s report would outline its findings on what impact giving producers the option of planting GM canola would have on individual producers and Victoria’s reputation and success in international markets.
“The Government will use the recommendations to assist it in making a decision before the moratorium sunset date about whether or not to allow the commercialisation of GM canola,” he said.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 37 Appendix 4. Review submission cover sheet
Issues Paper: Review of the Moratorium on Genetically Modified Canola 38 Appendix 5. Federal agencies responsible for the regulation of gene technology in Australia
Office of the Gene Technology Regulator
The Office of the Gene Technology Regulator (OGTR, www.ogtr.gov.au/ ), which sits within the Commonwealth’s Department of Health and Ageing, is a statutory body that administers part of the gene technology regulatory framework. Its function is to assess any potential risks associated with the testing or release of a GMO with respect to human health and the environment. This involves licensing and monitoring of proposed research activities using gene technology, including OGTR regulated field trials, and enforcing the legislation, as well as licensing the general or commercial release of OGTR approved GMOs. ‘Dealings’ with GMOs regulated by the Act include research, production, manufacture, import, storage, transport and disposal of GMOs. For dealings involving intentional release of a GMO into the environment, the Regulator prepares a risk assessment and risk management plan (RARMP) in consultation with a wide range of scientific experts and key stakeholders, including the public. The RARMP forms the basis of the Regulator's decision to issue a licence allowing the release of a GMO into the environment. The Regulator consults with the community, research institutions and private enterprise. A Gene Technology Ministerial Council (GTMC) was established by the IGA to govern the activities of the Gene Technology Regulator. The Gene Technology Ministerial Council comprises representatives of Commonwealth, State and Territory Governments and oversees the implementation of the national scheme. The Gene Technology Act also established three independent committees to assist both the Regulator and the GTMC. The committees are: The Gene Technology Technical Advisory Committee (GTTAC) – a group of highly qualified experts who provide scientific and technical advice on applications The Gene Technology Ethics Committee (GTECCC) 1 – a group of expert ethicists and people representing the broad interests within the Australian community, including consumers, researchers and environmentalists who provide advice on ethical issues relating to gene technology and matters of general concern to the community regarding GMOs
1 The Gene Technology Amendment Bill 2007 was passed by Parliament and came into effect on 1 July 2007. At that time the Gene Technology Ethics Committee and Gene Technology Community Consultative Committee were merged to form the Gene Technology Ethics and Community Consultative Committee (GTECCC).
Issues Paper: Review of the Moratorium on Genetically Modified Canola 39 Food Standards Australia New Zealand
GM food safety in Australia is the responsibility of Food Standards Australia New Zealand (FSANZ, www.foodstandards.gov.au/ ), formerly the Australia New Zealand Food Authority (ANZFA). FSANZ requires that all GM food or ingredients to be sold in Australia must undergo a mandatory pre-market safety assessment to ensure that it is safe for human consumption. In addition, since December 2001, Australia has had in place a mandatory labelling regime that requires all GM food sold in Australia to be labelled if novel DNA or protein is present in the final product. The pre-market safety assessment is carried out by FSANZ on behalf of the Australian Government, the State and Territory Governments of Australia, and the Government of New Zealand based on internationally accepted principles, to ensure that they are as safe as conventional food. Since 2000, FSANZ have approved 33 different GM foods, including modifications of corn, cottonseed (the oil of which is edible), canola, soy, sugar beet and potato. The Australian Quarantine and Inspection Service (AQIS) administers the Imported Food Inspection Program jointly with FSANZ. FSANZ advises on food risk assessment policy for the program and AQIS has operational responsibility for inspection and sampling required by FSANZ in accordance with the Imported Food Control Act 1992 .
Australian Pesticides and Veterinary Medicines Authority
The Australian Pesticides and Veterinary Medicines Authority (APVMA, www.apvma.gov.au/ ) is responsible for the regulation of pesticides and veterinary medicines up to and including the point of retail sale. The APVMA administers the National Registration Scheme for Agricultural and Veterinary Chemicals in partnership with the States and Territories. The APVMA independently evaluates the safety and efficacy of chemical products intended for sale, making sure the health and safety of people, animals and the environment are protected. APVMA also assesses potential impacts on trade, as part of their evaluation. The APVMA is responsible for registering herbicides for use over Roundup Ready ® and Liberty ® crops such as GM canola. GM crops that have a pesticide resistance component (eg. Bollgard II ® cotton) are also regulated by the APVMA. In assessing applications involving GMOs, the APVMA liaises closely with the OGTR. The APVMA is required to assess applications associated with any of the following: (a) Approval of an active constituent that is, or contains, a GM product (b) Registration of a chemical product that is, or contains, a GM product (c) Approval of a label for containers for a chemical product that is, or contains, a GM product.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 40 The Australian Quarantine and Inspection Service
The Australian Quarantine and Inspection Service (AQIS, www.daffa.gov.au/aqis ) is responsible for ensuring that products imported into Australia do not lead to the introduction, establishment and spread of pests and diseases that may endanger plants, animals and human life or health. Products regulated by AQIS include animals and animal products, plants and plant products and biological products containing or derived from micro- organisms, animal, human or plant material. Genetically modified products imported into Australia that could potentially pose a pest and disease risk fall under the Quarantine Act 1908 administered by AQIS. In the first instance, an import application form must be completed for proposed importation of genetically modified material. AQIS assesses import proposals using an Import Risk Analysis process. AQIS also advises importers to contact the OGTR, as the importer must also comply with OGTR requirements. AQIS also certifies the export of agri-food products and commodities from Australia in accordance with the requirements of the Export Control Act 1982 . AQIS identifies and inspects products and commodities, then certifies that they meet the requirements of the importing country governments. In providing this certification, AQIS relies upon advice from a number of sources, mostly third-party State or Commonwealth Government agencies, to provide verification data to support certification. When an importing country has a requirement as to the GM status of a product or commodity as part of certification, AQIS will attach to its export certification a statement from the OGTR as to the commercial status of the product or commodity in Australia.
Issues Paper: Review of the Moratorium on Genetically Modified Canola 41