How Should We Regulate Genome-Edited Crops? | Opinion
Humans have been modifying crop genetics for millennia, but in recent years this practice has undergone a significant transformation. New laboratory techniques allow us to make precise changes to a plant’s DNA, and this opens up huge possibilities for crop development. The challenge for regulators is how to ensure that these don’t harm our health or the environment. The EU currently decides which crops undergo regulation based on the technology used to develop them, but is there a better approach?
What is a GMO?
Most of our crops have had their genetics altered by humans. Many are now unrecognisable from their wild ancestors – broccoli, cabbage and cauliflower, for example, are all descended from the same species of wild cabbage, yet now look very different.1 Despite these genetic changes induced by humans, we don’t consider them to be GMOs.
But even induced genetic changes in the lab aren’t always classed as a GMO. Since the mid-twentieth century crop breeders have been using techniques such as mutagenesis, in which a crop’s DNA is altered by treating seeds with chemicals or radiation. The mutations induced by these processes are often fatal to the plant, but a few seeds will grow into more resilient plants with new characteristics. These techniques are not defined as GMOs because they were used long before regulations were introduced for genetically-modified crops, so their history of safe use means they are exempt from regulation.2
It was only in the 1980s that scientists developed techniques classed as ‘genetic modification.’ These new techniques allowed DNA to be added into a crop’s genome, including whole new genes, which had been impossible to do up to that point. Since then, we’ve also seen another revolution in genetic technologies, which allows us to make very precise changes.
The most famous and ethically disputed of these new techniques is CRISPR.3 CRISPR technology enables sections of DNA to be added, edited or removed, allowing more refined control over changes than were available using older genetic engineering techniques. These techniques have been called ‘genome editing’ to distinguish them from ‘genetic modification’, and have raised a difficult question for regulators: are genome-edited crops to be considered safer than GMOs? And should they be subject to the same lengthy regulatory procedure as GMOs?
How does the EU regulate genome-edited crops?
When the first GM crops were released, government agencies developed regulatory systems to test whether each new variety was safe for both humans and the environment. When CRISPR was introduced, however, it was not clear how CRISPR genome-edited crops would fit into existing GMO regulations.
In 2018, The Court of Justice of the European Union (CJEU) was tasked with deciding whether genome-edited crops should be classified as GMOs – ruling that techniques should be regulated as GMOs if they “alter the genetic material of an organism in a way that does not occur naturally.”4 As a result, it was decided that crops developed with CRISPR must go through expensive and time-consuming regulations.5
The problem with GMO regulations
In reality, the problem isn’t so much about deciding what is GMO – it should be more fundamental than that. Currently, the basic premise of deciding whether crops need regulatory approval based on the technologies they were developed with. Of course, this is understandably so, as the public expressed early concerns that the process of adding new genes to a crop would cause problems to human health. However, there is now enough evidence to conclude that this is not the case. Extensive independent studies have found that genetically-modified foods are safe for human consumption.6
Instead, I’d like to argue that we should regulate a crop based on the risks that its genetically-modified features pose, not the technology that was used to create it. This is perfectly illustrated by the case of herbicide-resistant crops, which have been developed both through conventional breeding and genetic modification.
The challenge of herbicide-resistant ‘superweeds’
Normally, herbicides would not only be harmful to weeds, but also to the crops to which they are applied. That’s why herbicide-resistant crops have proved very popular – because they allow farmers to kill weeds without harming their crops. But they also come with challenges. For example, employing herbicide-resistant crops could give rise to superweeds that are resistant to herbicides.
The same concerns apply to all herbicide-resistant crops, regardless of how they were created – whether with the conventional ‘mutagenesis’ techniques or with CRISPR. The risk of ‘superweeds’ would therefore provide good enough reason for herbicide-resistant crops to require regulatory approval. Indeed, when herbicide-resistant crops are created through genetic modification they are indeed required to go through an extensive regulatory approval process. But the problem is most herbicide-resistant crops created in Europe are actually the result of conventional breeding – and such crops don’t require regulatory approval’.7
The limitations of current GM regulations
Now, think about the difference between a herbicide-resistant crop and a non-browning apple. The herbicide-resistant crop carries several risks to the environment – as we’ve seen, it could give rise to superweeds. The non-browning apple – according to scientific evidence – doesn’t come with any environmental or health risks. Yet, a herbicide-resistant crop created through traditional breeding doesn’t have to undergo strict regulations, but a genome-edited non-browning apple does. This example highlights that our current system could allow for potentially damaging crops to go through not as stringent regulatory processes compared to GMOs.
The future of GMO regulations
As things stand, the EU rules on GMOs may not even be enforceable. Genome-edited crops with only tiny genetic changes may in fact be indistinguishable from crops made with conventional mutagenesis – so it would be possible to bypass regulatory approval by passing off a genome-edited crop as conventional.
Of course, regulations are just part of the story. Even if a new genetically-modified crop variety poses no threat to human health or the environment, this doesn’t necessarily mean that it will benefit society. Its impact may depend on factors of an entirely different issue – such as the availability of such seeds at an affordable price for farmers. Issues of this kind are pervasive in our food system, and go well beyond genetic technologies. A solid regulatory system for new crop varieties is essential, but is just one small part of building a secure and healthy food system. Throughout all these debates we must not lose sight of our goal: building a just food system that harms neither humans nor the environment.