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Most NGT plants will in future only require an entry into a register instead of mandatory risk assessment. This means that NGT plants would be legally equated to conventionally- bred
plants, i. e. extensively deregulated, even if they are biologically different

www.testbiotech.org/en/news/testbiotech-warns-about-far-reaching-deregulation-new-ge-plants

The new regulation will not only apply to annual arable plants. It will also apply to wild, non-domesticated species, such as trees, wild herbs, grasses, mosses or algae, which can
also spread in particularly sensitive ecosystems; all of these could be released into the environment without further controls. There would be no monitoring of the consequences that
the releases might have for nature and the environment, and no measures to remove the plants from the environment if necessary.

The legislative proposal made by the EU Commission does not have adequate scientific justification and, in particular, ignores the differences between new genetic engineering and
conventional breeding. It is true that many mutations can occur naturally in plants or arise during processes used in conventional breeding. However, most of these mutations have no
direct effect on the phenotype of the plants. If they do change the characteristics of the plants, this does not usually go beyond the natural range of characteristics of the
individual species. However, these biological limits do not apply to gene scissors, or only to a very limited extent. Even if no additional genes are inserted, new genetic engineering
techniques can be used to trigger intended and unintended changes that go beyond the known characteristics of the species.

• www.testbiotech.org/en/content/differences-between-new-genetic-engineering-and-conventional-breeding
• Set Limits to Biotech!

CRISPR/Cas in particular has the potential to alter gene functions and properties of plants in ways that would not be expected in conventional breeding. The associated risks to humans
and the environment are by no means lower compared to transgenic plants: The associated risks to humans and the environment are by no means lower compared to transgenic plants: whereas
previous genetic engineering involves the transfer of genes across species boundaries, the new genetic engineering techniques now make it possible to change the characteristics of a
species beyond the range of its natural characteristics, even without the insertion of additional genes. Both the technical potential and also the technical shortcomings of tools, e.
g. CRISPR/Cas, mean that in future it is still essential for all genetically engineered organisms to undergo in-depth risk assessment. This should include appropriate analytical
procedures to identify the intended and unintended genetic changes resulting from NGTs. These changes must then be evaluated for their direct and indirect, immediate or delayed, and
cumulative long-term effects.

/www.testbiotech.org/en/news/testbiotech-warns-about-far-reaching-deregulation-new-ge-plants

The demand for NGT deregulation is often justified by the fact that, in view of climate change, new solutions are needed to secure the global food supply. However, new solutions cannot
be considered sustainable if their use can result in ecosystems being overburdened by mass releases of non-adapted NGT organisms. Other unintended consequences include risks being
introduced unnoticed into the food chain, breeding being blocked by patents and consumer interests being disregarded. At the same time, many expectations in relation to the possible
benefits of NGT plants and animals seem to be far too high. Against this backdrop, a technology assessment (TA) is clearly needed in order to distinguish between empty promises and
realistic expectations, as well as for the early recognition of negative effects on breeding, agriculture and food production.

Assess the consequences!

NGT plants that have the potential to survive in the environment for several years, or to reproduce and spread, must be very closely examined, and they should not be released if there
are any uncertainties. In general, the introduction of genetically engineered organisms into the environment should be limited as far as possible. As is the rule elsewhere in sensitive
areas of nature conservation, interventions into the environment must be avoided as far as possible.

A large number of NGT organisms across many species and with a broad range of different properties could soon be released into the environment. Many of them could spread
uncontrollably, triggering complex interactions between the different NGT organisms. Similar to environmental pollution with plastics and chemicals, it is not necessarily a particular
NGT organism that causes problems; it is instead the totality of the effects of different NGT organisms and their interactions that may be critical. As this involves living organisms,
the environmental problems may be more diverse and complex compared pollution that has occurred in the past. Numerous genetically engineered organisms could also persist in the
environment for a very long time, and thus cause a problem for many future generations to come.

According to current EU laws, all genetically engineered organisms have to undergo risk assessment. This system must remain in place! This risk assessment must include the evaluation
of all intended and unintended genetic modifications specific to new genetic engineering, particularly in regard to risks to humans and the environment. In addition, a comprehensive
technology assessment (TA) must be carried out before plants and animals derived from NGTs are used in agriculture.

NGT plants that have the potential to persist in the environment for several years, or to reproduce and spread, must be particularly closely examined in this context. They must not be
released if there are any doubts. In general, the introduction of genetically engineered organisms into the environment should be limited as far as possible. As is the rule elsewhere
in sensitive areas of nature conservation, environmental interventions should be avoided as far as possible.