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GM Seed Secrecy Threatens Organics

in 2023/GMO Updates/Seeds/Winter 2023

By Lucy Sharratt

WARNING: This seed packet could soon be full of undisclosed genetically modified (GM) seeds.

The biotechnology industry is pushing to take over the regulation of genetically engineered (genetically modified or GM) seeds and foods, and establish corporate self-regulation in place of government oversight. The Minister of Agriculture and Agri-Food is considering letting corporations conduct their own environmental safety assessments of many new gene-edited seeds with no government oversight, and decide if they want to disclose that their new product is genetically engineered. The Minister of Health has already decided that many gene edited foods don’t need any government safety checks. The proliferation of unknown genetically modified organisms (GMOs) in the food system is a serious threat to the future of organic farming.

Seed Packet Warning Sent to the Minister

At the end of last year, hundreds of farmers in the Prairies sent seed packets in the mail to the Minister of Agriculture and Agri-Food. These envelopes were empty of seeds but carried an important message to the Minister about the threat to organic farming if she allows the sale of unassessed, undisclosed genetically engineered seeds.

The Canadian Food Inspection Agency (CFIA) is proposing to allow companies to sell many new gene-edited GM seeds—those that have no foreign DNA—without notifying farmers, consumers, or even the federal government. This exemption will mean that companies will do their own environmental assessments and leave farmers dependent on companies to find out if seeds are gene-edited.

The biotechnology industry has launched a public relations campaign to characterize gene editing techniques as “plant breeding innovation” or “precision breeding,” and argue that gene-edited seeds should not even be defined as GMOs. However, gene editing is genetic engineering. This is the science, and it is also the definition in the Canada Organic Standards.

The Canada Organic Regime is overseen by the CFIA and includes the enforcement of the organic standards, which prohibit the use of genetic engineering. The Canada Organic Trade Association says, “It is the CFIA’s responsibility to ensure the environmental safety of all genetically engineered plants and the protection of the organic integrity. CFIA must continue to regulate all genetically engineered plants under the Seeds Act—including those produced through the new techniques of gene editing.”

CropLife Influence Exposed

A 2022 investigation by French-language CBC found that a CFIA document summarizing the agency’s proposals to remove regulation was actually authored by the biotechnology and pesticide industry lobby group CropLife Canada. The history of the Word file shows that CropLife’s executive director was the creator of the document.

This revelation led the National Farmers Union, CBAN, and 13 other groups to call for the CFIA President to be replaced. The groups said, “It appears that key aspects of the proposed guidance…were requested by self-interested industry groups and have been incorporated into the CFIA regulatory guidance.”

The CFIA has explained that CropLife authorship of the document was a technical mistake in the process of exchanging draft documents for comment. However, this mistake was only possible because the CFIA sent CropLife this proposal summary for their input. Farm groups such as the National Farmers Union were not asked to review it.

The CFIA consulted with farmer organizations in the summers of 2021 and 2022. However, as Garry Johnson, President of SaskOrganics said, “If the government is sincere about hearing from farmers, when their proposals would have such a major impact on organic farmers in particular, they should choose a time that is much less demanding on all of us.”

Minister Pledges GMO Transparency

In response to the media story, the Minister of Agriculture told organic farmers that they don’t need to worry; that she will make sure farmers have transparency about new GM seeds coming to the market. However, the Minister has not yet secured mandatory reporting and the CFIA continues to meet with CropLife to discuss the industry’s proposal for “voluntary transparency.”CropLife is pushing to be the arbiter of information for farmers. It wants to manage a public list that relies on biotech companies to voluntarily disclose their GM seeds. In fact, CropLife has its own private, voluntary product notification system ready to roll. This is a tactic to avoid regulation and mandatory reporting.
The biotech industry wants the Minister to accept voluntary corporate notification as sufficient transparency. However, there would be no way to know that this list was complete or to verify the information on the it.

This lack of transparency would go far beyond the existing problem of unlabelled GM foods in our grocery stores. Some GM foods and seeds would be sold, planted, and eaten without the public, farmers, and government knowing that they even exist.

Removing regulation would remove the ability of the federal government to request information from companies about their new unregulated GM foods and seeds. There would be no way to track and trace these secret, unregulated GMOs.

In an October 2022 letter to the Minister, SaskOrganics, the National Farmers Union, and the Canadian Biotechnology Action Network (CBAN) argued that “transparency and traceability will only be possible if the CFIA and Health Canada retain their regulatory authority over all genetically engineered products such that, prior to release into the environment or onto the market, the departments require submission of information from product developers and have the ability to provide it to Canadians in a timely, trusted, and accessible way.”

The CFIA is stuck with an irreconcilable contradiction. The CFIA, federal government, and Minister have all publicly committed to “transparency,” but the CFIA is proposing to remove the very regulation that would ensure it.

Act Now to Stop Corporate Self-Regulation

In May 2022, Health Canada announced that it will not regulate gene-edited GM foods, and will propose amendments to the Novel Food Regulations to formalize these changes. This is an acknowledgement that the Minister of Health can still reverse Health Canada’s new regulatory guidance that exempts these foods.

In a January 2023 letter responding to SaskOrganics, the Minister of Agriculture said she has asked the CFIA and Agriculture Canada “to propose options to ensure traceability and transparency of genetically engineered plant varieties to maintain the integrity of Canada’s organic food production system.” However, the solution needed can only be secured if organic farmers, organic sector groups, and the public continue to communicate with the Minister.

The Endgame is Complete Corporate Control

CropLife members include the biggest seed and pesticide companies in the world. These companies would clearly be the beneficiaries of an open door to sell unregulated GMOs. These corporations would be free to put many GM products on the market without the costs of submitting safety data to regulators, could cut their confidential safety studies down to a bare minimum, and could keep their GMOs a market secret and thus avoid the risk of consumer boycotts. The proliferation of undisclosed GMOs would also remove the competition: by contaminating the entire food system with secret GMOs, over time, organic production and other non-GMO choices would become unviable.
Actions and updates are posted at: cban.ca/NoExemptions

Lucy Sharratt is Coordinator of the Canadian Biotechnology Action Network (CBAN), a project of the MakeWay Charitable Society.

Featured image: Letters and seed packets. Credit: Canadian Biotechnology Action Network.

Gene Editing: The End of GMOs?

in 2020/Fall 2020/GMO Updates/Organic Standards

Lucy Sharratt

There is a lot of excitement about “gene editing,” or genome editing, in the media and research community. In the farm press, genome editing techniques are being widely described as precise and, in some cases, non-GMO. Neither is correct.

Genome editing techniques can be used to alter the genetic material of plants, animals, and other organisms. They aim to insert, delete, or otherwise change a DNA sequence at a specific, targeted site in the genome. Genome editing techniques are a type of genetic engineering, resulting in the creation of genetically modified organisms (GMOs).

The techniques are powerful and could lead to the development of more genetically modified (GM) crop plants, and even GM farm animals. However, the hype surrounding genome editing is similar to what was seen with first-generation genetic engineering. Most news stories about new products are actually about experiments in very early stages, which may never lead to new foods on the market.

Just as with first-generation genetic engineering, genome editing techniques are moving quickly in the lab to create new GM foods, even while our knowledge about how genomes work remains incomplete. The techniques are powerful and speedy, but can be imprecise and lead to unexpected consequences.

The genome is the entire set of genetic material in an organism, including DNA.

What is Genome Editing?

Genome editing most often uses DNA “cutters” that are guided to a location within an organism’s DNA and used to cut the DNA. This cut DNA is then repaired by the cell’s own repair mechanism, which creates changes or “edits” to the organism. The most frequently used genome editing technique is called CRISPR, but other techniques follow similar principles.

First-generation genetic engineering techniques insert genes at random locations. These genes then permanently become part of the host organism’s genome, creating new DNA sequences. In contrast, new genome editing techniques insert genetic material that is then guided to a specific target site to perform “edits.” This means that, with genome editing, the inserted genetic material makes changes to the genome but does not necessarily have to become incorporated into the resulting GMO and can be bred out. This means that not all genome-edited GMOs are transgenic.

This also means that, unlike all first-generation GMOs, not all genome-edited GMOs are transgenic (have foreign DNA). The ability to create non-transgenic organisms is often stressed by the biotechnology industry as an advantage to using genome editing but, as discussed below, whether or not a GMO is transgenic is not the chief concern about genetic engineering.

There is one genome-edited organism on the market in Canada: an herbicide tolerant canola from the company Cibus (Falco brand). This GM canola, like all other GMOs, is prohibited in organic farming and excluded from “Non-GMO Project” verification. However, despite also being regulated as GM in Europe, the company Cibus still sometimes refers to this non-transgenic canola as “non-GMO.” This one example provides a glimpse into how the biotechnology industry would like to shape the regulation and public perception of genome editing to avoid the GMO controversy.

Unexpected and Unpredictable Effects

Genome editing can be imprecise, and cause unexpected and unpredictable effects. Many studies have now shown that genome editing can create genetic errors, such as “off-target” and “on-target” effects:

  • Genome editing techniques, such as the CRISPR-Cas9 system, can create unintended changes to genes that were not the target of the editing system. These are called “off-target effects.”
  • Genome editing can also result in unintended “on-target effects,” which occur when a technique succeeds in making the intended change at the target location, but also leads to other unexpected outcomes.
  • Genome editing can inadvertently cause extensive deletions and complex re-arrangements of DNA.
  • Unwanted DNA can unexpectedly integrate into the host organism during the genome editing process. For example, foreign DNA was unexpectedly found in genome-edited hornless cows.

Despite these many potential impacts, there are no standard protocols yet to detect off-target and on-target effects of genome editing.

Sometimes intended changes that are created by genome editing techniques are described as “mutations,” because only very small parts of DNA are altered and no novel genes have been intentionally introduced. However, even small changes in a DNA sequence can have big effects.

The functioning of genes is coordinated by a complex regulatory network that is still poorly understood. This means that it is not possible to predict the nature and consequences of all the interactions between altered genetic material and other genes within an organism. For example, one small genetic change can impact an organism’s ability to express or suppress other genes.

An End to GMO Regulation?

Despite these risks, a number of researchers and companies are arguing that genome editing should be less regulated than first-generation genetic engineering, or not regulated at all.

It is commonly argued that regulation is an obstacle to innovation. In relation to genome-edited animals, the argument has been made that mandatory government safety assessment “makes no economic sense.”1 Instead, industry argues that the process by which new plants and animals are created should be irrelevant to safety considerations. This is why US government proposals to assess the safety of all genome-edited animals were called “insane” by one of the developers of genome-edited hornless cows2—three years before the cows were found by US government scientists to contain unexpected foreign DNA.

New genome editing techniques will challenge regulators with new traits and processes, with increasing complexity and ongoing uncertainty. Rather than assume their safety, these new technologies need to be met with precaution and increased independent scrutiny.

Even more fundamentally, our government must consider the question of social worth before
approving products of genetic engineering. Without consulting Canadian farmers, for example, companies can commercialize new GM products (such as glyphosate-tolerant alfalfa) that have few benefits but can, on the contrary, pose serious risks to farming systems and the environment.

For references and for more information and discussion about genome editing, read CBAN’s new report, “Genome Editing in Food and Farming: Risks and Unexpected Consequences.” The report and an introductory factsheet are available online.

For updates or to find out more, visit CBAN online.

Lucy Sharratt is the Coordinator of the Canadian Biotechnology Action Network (CBAN). CBAN brings together 16 groups (cban.ca/about-us/members/) to research, monitor and raise awareness about issues relating to genetic engineering in food and farming. CBAN members include farmer associations, environmental and social justice organizations, and regional coalitions of grassroots groups. CBAN is a project on MakeWay’s shared platform.

Featured image: Canola in bloom. Credit: Bellingen2454 (CC)

See CBAN’s report at cban.ca/GenomeEditingReport2020
Maxmen, A. (2017). Gene-edited animals face US regulatory crackdown. Nature (News).

Why Your Food Choices Matter

in 2020/Climate Change/GMO Updates/Grow Organic/Marketing/Organic Community/Organic Standards/Spring 2020

CBAN’s New Public Education Tool to Support the Organic Solution

Lucy Sharratt

The gravity and gathering speed of the global climate and biodiversity crises threaten to paralyze many people who want to make meaningful change but don’t know where to start. Thankfully, organic farmers are already implementing concrete solutions that everyone can support. In the face of climate emergency, organic farmers show us what is possible.

That’s why, at the beginning of this year, the Canadian Biotechnology Action Network (CBAN) started a new public education program to support organic farming. It centres around a new pamphlet called “Why Your Food Choices Matter,” which is designed for farmers to hand out at farm stands, farmers’ market tables, or in CSA boxes, and for distribution at health food stores and local events. The goal is to help people commit, or re-commit, to making organic food choices, and to buying locally and directly from farmers where possible.

In Canada and around the world, organic farmers are at the forefront of building real and lasting solutions to the climate and biodiversity crises. This is a global movement that relies on the support of an informed non-farming public. In this context, individual food choices are more important than ever because they support farmers who are, together, making profound change. At a time of ecological crisis, we are encouraging consumers to take heart from farmers who are already growing food for a better future.

Even consumers who are already making one or more ecological food choices need information to help them continue, and to help them share information with their family and friends. CBAN’s pamphlet says, “your food choices can help protect our environment, support your health, and build a better future for food and farming,” and it describes organic farming. We know this information is necessary because people still ask us if organic is non-genetically modified (GM). They also ask us if organic is sustainable, and if they can trust the organic label. The pamphlet is actually an update of a similar tool launched 10 years ago. People clearly still need this information.

In fact, this information is an important counterpoint to a new highly-organized and well-funded public relations campaign designed to win public trust or “social license” for conventional agriculture practices, including the use of pesticides and genetically modified organisms (GMOs). Coordinated by the Canadian Centre for Food Integrity and Farm & Food Care, the campaign is tracking public opinion and asking farmers to speak up to counter consumer mistrust.

However, this campaign does not change the reality that, as described in “Why Your Food Choices Matter,” most of the food we eat is produced through a long chain of steps in a global system that contributes to the climate crisis, puts harmful toxins into our environment, and removes decision-making from farmers and consumers. This global food system is dominated by a few large companies that control the markets for seeds, pesticides, and other technologies, as well as much of the distribution and sale of food in our communities. But consumers don’t have to surrender to this reality—they can choose an organic path forward, with local farmers.

According to the International Panel on Climate Change, agricultural production contributes approximately 12% of human greenhouse gas emissions. This includes emissions of nitrous oxide from synthetic fertilizers and methane from livestock production. When we add emissions from other related activities in our global food system, such as food production, land-use changes such as clearing forests to make way for farming, manufacturing pesticides and fertilizers, and processing, packaging, and transporting food, this number increases to 21%-37% of all global emissions caused by human activities. Synthetic pesticides and chemical fertilizers are both petrochemical products, made from fossil fuels.

Canadians are increasingly becoming more aware about the use of synthetic pesticides in farming, or at least the use of glyphosate-based herbicides. For many consumers, glyphosate is a concern that is also associated with the use of genetically modified seeds. This connection is correct because almost all the GM seeds sold in Canada are engineered to be herbicide tolerant, and most of these are glyphosate tolerant. CBAN’s research has found that herbicide sales in Canada have increased by 199% since the introduction of GM crops (1994-2016).

However, glyphosate formulations are only one among many different types of synthetic herbicides, insecticides, and fungicides used to produce the majority of food on the market. In fact, the emergence of glyphosate-resistant weeds has meant that companies have started shifting their sales from glyphosate-tolerant GM crops to 2,4-D- and dicamba-tolerant GM crops.

Corporate consolidation is a defining feature of our global food system. Four companies control over half of both the global seed and pesticide markets. These same top companies also control the sales of genetically engineered seeds. For example, Bayer is now the largest seed company, the second largest pesticide company, and the largest seller of genetically engineered seed in the world. Following its acquisition of Monsanto, Bayer owns 33% of the global seed market and 23% of the global pesticides market.

This high level of corporate concentration in seeds and pesticides is unprecedented, and it means higher prices for farmers, fewer choices, and decreased seed diversity.  These inputs have environmental costs, and also take money out of farmers’ pockets. In 2018, Canadian farmers spent 94% of their gross farm income on farm inputs. This is why the National Farmers Union (NFU) has just launched a new discussion about how the farm crisis and the climate crisis are linked.

The NFU says, “The solutions to the farm crisis and the climate crisis are largely the same: reduce dependence on high-emission petro-industrial farm inputs, and rely more on ecological cycles, energy from the sun, and the knowledge and wisdom of farm families.” This conversation is in full swing due to a new alliance called Farmers for Climate Solutions, which is creating space for farmers to share stories about climate impacts, practical solutions and policy recommendations.

Organic farming provides a path forward, but encouraging organic consumption alone is not sufficient. This is why CBAN’s pamphlet encourages a range of complementary consumer food choices. For example, we know that small independent food manufacturers and stores are facing pressure in a marketplace dominated by the big grocery chains. Five grocery companies (Loblaw, Sobeys/Safeway, Costco, Metro, and Walmart) control 80% of the food retail market in Canada. This is why we also emphasize the importance of buying directly from farmers, and from local and independent businesses.

Along with all these issues, consumer concern over genetic engineering (genetic modification or GM) is also driving support to organics. New techniques of gene editing are the latest way that genetic engineering is being sold as the future of farming. However, the connection between the two issues of genetic engineering and organics is about more than just an option to buy non-GM via organics.

Genetic engineering and organics offer two different visions for farming, and two different visions for problem solving. Organic farmers reject GM seeds and GM animals as unnecessary and risky. Instead, organics values the diversity and bounty that nature already offers, and often replaces such corporate products with natural systems and human labour. This is why emerging and powerful new genetic engineering techniques such as gene editing will fail to provide the solutions needed. The real solutions are in the hands of organic farmers, and it is time to mobilize consumers to more fully support farmers’ work.

You can view the pamphlet “Why Your Food Choices Matter,” along with references for the information, and order your copies at cban.ca/orderpamphlets. You can also contact us at cban.ca/contact or call Lucy at 902.209.4906.

Copies are available free of charge, though your donations to help support printing and postage are gratefully accepted (and tax-deductible).

Lucy Sharratt is the Coordinator of the Canadian Biotechnology Action Network (CBAN). CBAN brings together 16 groups to research, monitor and raise awareness about issues relating to genetic engineering in food and farming. CBAN members include farmer associations, environmental and social justice organizations, and regional coalitions of grassroots groups. CBAN is a project on the shared platform of Tides Canada, a registered charity.

GM Updates: Pulling Solutions out of Thin Air

in 2019/Climate Change/Crop Production/GMO Updates/Grow Organic/Organic Standards/Pest Management/Winter 2019

The Dangers of Investing in the Promise of the Techno-Fix

Lucy Sharratt

For 20 years, the world’s biggest seed and pesticide companies have profited from selling genetically modified (GM, also called genetically engineered) seeds that are tied to their brand name herbicide formulations. In fact, almost 100% of the GM crops now grown in Canada are genetically modified to be herbicide-tolerant; 88% globally. This reality is far from the promises that were made for this powerful new technology.

Canadians are still being asked to throw their support behind genetic engineering in the name of innovation and progress, to solve the biggest problems of our time. We are being asked to forgo precautionary regulations and mandatory GM food labelling to clear the way, and to direct significant resources away from seed systems that serve organic farmers. Our experience with genetic engineering provides some important lessons about the impacts of focusing on the potential of techno-fixes.

GM’s Solution is More Pesticides

Five GM crops are grown in Canada: corn, canola, soy, white sugar beet, and a very small amount of alfalfa. All are herbicide-tolerant except for a few GM sweet corn varieties that are only insect-resistant. GM herbicide-tolerant crops are grown on 409.7 million acres around the world and most of this is GM glyphosate-tolerant soy grown for animal feed, processed food ingredients and fuel or other industrial uses. Seventy seven percent of the world’s soy crop is now herbicide-tolerant. This GM soy cultivation relies on pesticides derived from petrochemicals and it is literally eating into the Amazon.

Instead of reducing pesticide use, GM crops have protected the market share for brand name herbicide formulations such as Monsanto’s Roundup. In Canada, herbicides sales have increased by 199% since the introduction of GM crops (1994-2016).

GM crops have facilitated a recommitment to herbicide use, and the overuse of glyphosate in particular. At first, some herbicide-tolerant crops helped farmers more efficiently apply herbicides but ultimately their use sped up and entrenched the existing pesticide treadmill, with more chemicals and more GM traits stacked together. It is not enough anymore to sell glyphosate-tolerant seeds—now GM seeds are marketed with tolerance to multiple herbicides at once, to deal with glyphosate-resistant weeds.

The evolution and spread of glyphosate-resistant weeds since 1996 is now rendering glyphosate herbicides redundant. In 2010, Monsanto began offering rebates to farmers when its herbicide failed to kill all their weeds. Now DowDupont (Corteva) is warning that weeds with resistance to multiple herbicides may prevent some farmers from growing certain crops altogether.

The corporate response to the failure of GM herbicide-tolerant cropping systems is to sell more products into that same system. In 2017, Monsanto launched its Roundup Ready™ Xtend™ dicamba-tolerant plus glyphosate-tolerant GM soy and, in 2018, DowDupont sold its GM corn Enlist™ that is tolerant to 2,4-D plus glyphosate. Such stacking of GM traits for tolerance to multiple herbicides is now the norm and is a doubling down on chemical agriculture.

The contrast between this reality and the grand vision for genetic engineering warns that even the most exciting science can have serious limitations in real world application. The science of genetic engineering itself has limitations but the promise is also limited by who owns and controls the technology.

Corporate Techno-Solutions to the Rescue

Rather than provide innovative solutions, GM has, so far, propped up an existing production model that relies on expensive farm inputs sold by the biggest seed and pesticide companies in the world. Until 2016, the global market for GM crops was dominated by six companies, Monsanto, Dupont, Syngenta, Dow, Bayer and BASF, that, together, controlled around 75% of the global pesticide market and 62% of the commercial seed market. After a wave of mergers, these markets are now controlled by just four companies: Bayer bought Monsanto, Dow and Dupont merged, ChemChina bought Syngenta, and some of Bayer’s and Monsanto’s business was sold to BASF. This corporate concentration has also eliminated or constrained non-GM seed options for some farmers.

It is important to evaluate the promises that were made because they are still being used to argue for removing regulations and because these same promises are being repeated with the advent of new genetic engineering techniques. The techniques of gene editing, such as CRISPR, are being hyped with the promise of achieving everything that the earlier techniques could not. However, promoting a new technology relies on looking to the promise around the corner and overpromising is often also used to build investment interest. The danger is that we are building a vision for our future based on corporate investment strategies that often pull solutions out of thin air, instead of looking to the ground where farmers are already innovating.

The GM solution continues to fail. At the end of 2018, the Government of South Africa rejected Monsanto’s request to approve GM drought-tolerant corn because the company’s data was insufficient to demonstrate that the corn was actually drought tolerant. Also, while the famed Vitamin-A enriched GM “Golden Rice” is getting closer to market, it still contains less than 10% of an equivalent amount of beta-carotene in carrots. Meanwhile, groups in the Philippines argue that, “securing small farmers’ control over resources such as seed, appropriate technologies, water, and land is the real key to improving food production and eradicating hunger and malnutrition.”(1) Such complicated solutions do not, however, provide the opportunity to sell new products.

Companies are promising technological solutions to “feed the world” and halt climate change. Such techno-fix silver-bullets are compelling—they appear simple and elegant—but if we rely on corporations to develop the solutions to our problems, we will be buying our solutions, if they ever materialize. We can also ill afford to wait for the perfect technology to solve our problems. This approach invites dependence and inertia.

In the meantime, organic solutions are already in the ground. Further agroecological progress is hindered by a system that is set up to facilitate and promote the GM techno-fix rather than support locally adapted seed and farmer control. Faced with the moral imperative to take urgent action to stop climate change, we need to support the nimble and diverse solutions already available to us—solutions in the hands of farmers in Canada and around the world.


Lucy Sharratt is the Coordinator of the Canadian Biotechnology Action Network (CBAN). CBAN brings together 16 groups to research, monitor and raise awareness about issues relating to genetic engineering in food and farming. CBAN members include farmer associations, environmental and social justice organizations, and regional coalitions of grassroots groups. CBAN is a project on the shared platform of Tides Canada, a registered charity.


GRAIN, MASIPAG, & Stop Golden Rice! Network. (2018). Don’t get fooled again! Unmasking two decades of lies about Golden Rice. grain.org/article/entries/6067-don-t-get-fooled-again-unmasking-two-decades-of-lies-about-golden-rice

Setting Up a Spiral of GMO Contamination

in 2018/GMO Updates/Winter 2018

Legalizing “Low-Level Presence” of Unapproved GMOs

Lucy Sharratt

Contamination from genetically modified organisms (GMOs) is a problem for some
crop types. For example, most organic grain farmers in the Prairies stopped growing canola after GM contamination of seed became widespread, and Canada’s flax industry is still recovering from GM contamination that closed export markets. Rather than taking all measures possible to stop contamination, the federal government has responded by proposing a policy that accepts it as unavoidable. This Low-Level Presence (LLP) policy asserts that the problem is not GM contamination, but rather our unwillingness to accept it.

What To Do About “Low-Level Presence” of Unapproved GMOs?

Agriculture Canada says, “Genetically modified (GM) grain that has not yet been approved by the importing country may unintentionally be present, at low levels, in grain shipments exported to that country. This is what is called low level presence (LLP).” For GMO-producing countries like Canada, acceptance of LLP by our trading partners is a priority.

LLP is contamination from GMOs that have not yet been assessed for safety by the national regulator in the importing country. An LLP policy would not apply to contamination from a GM crop that was assessed as unsafe or that was not yet approved in any jurisdiction. The industry calls this latter type of contamination “Adventitious Presence” or AP but the distinction only matters for moving an LLP policy forward. Until LLP policies are established, both AP and LLP are illegal in every country. The goal of a Low-Level Presence policy is to overturn this global norm of “zero-tolerance” for contamination.

Canada is the fourth biggest producer of GM crops in the world (GM corn, canola, soy, and a limited amount of GM alfalfa) and keeps exporting commodities contaminated with a Low Level Presence of GMOs that are not yet approved in our export markets, resulting in quarantined and rejected exports. CropLife Canada argues that acceptance of LLP will “provide stability” because “mixing can happen during cultivation, harvest, transportation, or storage of grain” and due to “modern, efficient bulk grain handling systems not designed for segregation of different grain segregation of different grain sources”.

Rather than implement controls and design grain segregation appropriately, the industry is asking national governments around the world to accept GMOs that they have not yet regulated. For example, Canada argues that other countries who had not evaluated the safety of GM flax should have accepted our GM flax contamination because Canadian regulators had approved it.

In 2011-2015, Agriculture Canada was proposing to make Canada the first country in the world to adopt an LLP policy, to lead by example. Canada’s progress on LLP is now more explicitly tied to progress internationally, with Canada acting as a leading global advocate. At the moment, Canada’s LLP policy proposal takes the form of a two-page policy model “designed to stimulate international discussions”.

Canada’s LLP Policy Model

While the industry also aims to establish LLP in seed, the current policy model from Agriculture Canada applies to whole grain, food, and feed products, not to seed for propagation, fruits and vegetables, or animals. The model proposes the following acceptable thresholds for LLP:

  • A 0.2% contamination threshold to address LLP resulting from dust (for example, GM corn dust in a soybean shipment)
  • A compliance threshold of 3% to address situations resulting from a foreign GM crop not yet approved in the importing country (for example, the GM flax that contaminated Canada’s flax exports to 36 countries).

Low-Level Presence would only be accepted if:

  • the GM crop (GM event) is approved for food use in at least one country, in accordance with Codex Guidelines.

Canada also outlines two additional criteria for the 3% compliance thresholds to apply:

  • Application for authorization of the GM crop was provided to the importing country;
  • Applicable LLP risk assessment(s) conducted by the importing country have determined, in advance, that the GM crop is unlikely to pose a risk.

In Canada, this means that LLP would be accepted if one other government has approved the GM crop, if Health Canada has received a request to approve the GM crop, and if our regulators have already concluded some type of “LLP risk assessment”. This last criteria is worth noting: the federal government is proposing to also establish some form of, as yet undefined, partial risk assessment for LLP. This would create two tiers of risk assessment for GMOs.

An LLP policy would mean that Canadians would be eating at least two types of legal GMOs: 1) those evaluated as safe for human consumption by Health Canada and 2) a small percent of those not yet approved but partially assessed by Health Canada and also approved by another government. The assumption is that full safety evaluation of a GM food is only needed if Canadians are eating more than 3%.

Assumptions-Based VS Science-Based Policy

A Low-Level Presence policy would put an end to claims of “science-based” regulation for GM food and environmental safety and replace it with an assumptions-based policy.

Why is 3% of LLP consumption safe but not 4% or 5%? The threshold is set by what the grain trade says it is willing to control in exports and accept in imports, not by what Health Canada and Environment Canada determines as safe. And we can only expect the LLP percentage to increase as the policy allows for contamination to more widely take hold. The industry is already asking for 4-5%.

An LLP policy rests on three major assumptions: contamination is inevitable; more GMOs will be developed and approved; and GMOs are safe or, more precisely, that GM foods not approved by Health Canada are safe to eat if another government says so and if Canadians don’t eat too much of them.

Low-Level Presence relies on a new precedent-setting pitch to Canadians and people around the world: that we don’t always need our national regulators to assess the safety of the GM food we eat.


LLP acceptance would allow GM contamination to gradually expand over time, because industry will have less incentive to control it. It would also be a self-fulfilling prophecy that could lead to the approval of many new GMOs such as GM wheat that otherwise face powerful opposition due to fears of trade disruption over contamination.

Organic and conventional farmers together rejected the fiction of “coexistence” with GM alfalfa. However, the government and industry continue to promote coexistence strategies, at the same time that they develop a policy to accept and legalize its failure.

Click for more resources and updates, including a link to Canada’s policy model.

Lucy Sharratt is the Coordinator of the Canadian Biotechnology Action Network (CBAN). CBAN brings together 16 groups to research, monitor and raise awareness about issues relating to genetic engineering in food and farming. CBAN members include farmer associations, environmental and social justice organizations, and regional coalitions of grassroots groups. CBAN is a project on the shared platform of Tides Canada, a registered charity.

 [1] Ian Affleck, CropLife Canada Update, Presentation to the Canadian Seed Trade Association Annual Meeting, Windsor, July 13, 2015
 [2] Agriculture and Agri-Food Canada, Low-Level Presence http://www.agr.gc.ca/eng/industry-markets-and-trade/agri-food-trade-issues/technical-trade-issues-in-agriculture/low-level-presence/?id=1384370877312
 [3] CropLife, Coexistence https://croplife.org/plant-biotechnology/stewardship-2/co-existence/
 [4] Ian Affleck, CropLife Canada Update, Presentation to the Canadian Seed Trade Association Annual Meeting, Windsor, July 13, 2015
 [5] Canadian Biotechnology Action Network and National Farmers Union, “The Canadian Seed Trade Association’s so-called ‘Coexistence Plan’ is a Gateway to GM Alfalfa Contamination: Commentary and Technical Paper” July 2013. report https://cban.ca/wp-content/uploads/gm-alfalfa-rebuttal-to-industry-coexistence-plan-1.pdf

Where is the GM Apple?

in 2017/Crop Production/Organic Community/Organic Standards/Winter 2017
CBAN Bulletin on genetically engineered food in Canada

Lucy Sharatt

In March 2015, Okanagan Specialty Fruits (OSF) got approval for its GM non-browning Golden Delicious and Granny Smith apples in both Canada and the United States. The US government also just announced approval of the GM Fuji, and a GM Gala is coming next. After having said in August 2016 that 1,000-1,200, 40-pound boxes of GM Golden Delicious apples would be sliced and sold in grocery stores in the western US,(1) the company now says it will test markets in the US early this year. But where will these apples come from?

Establishing orchards of genetically modified (GM) apples will take time and like other GM products that have been approved by our government, the new GM non-browning “Arctic” apple will be hard to track down. The GM apple is already particularly difficult to trace: OSF itself does not know exactly what to do with it because the market for the apple is unknown. But orchardists in BC, particularly organic growers, need to know where it is cultivated.

The company intends to plant 300,000 to 500,000 new trees each year but it’s unclear if this plan is for the US, Canada, or both countries.(2) OSF now says that based on their current planting contracts, they will plant over 870,000 trees between 2016 and 2018 that at maturity will produce over 30 million pounds of GM apples every year.(3) These numbers will be difficult to verify independently.

In an August 2016 letter to CBAN, Okanagan Specialty Fruits said that it will roll out the production and consumer test marketing in the US first: “OSF commercial orchards are currently planted in the United States. OSF consumer product test markets, to be conducted using Arctic® Golden apples from the first commercial harvest, will be conducted in the United States. These test markets will highlight a sliced product featuring the Arctic® brand. Most other parameters, including the Canadian market introduction, have yet to be determined.”

Because BC orchardists protested the field-testing of the GM apple, all field trials took place in the US instead of Canada, leaving maturing orchards in Washington and New York State. OSF President Neal Carter says there are already 70 acres at one ranch in Washington.(4)

The location of any GM apple trees is important information for organic growers. OSF told COABC that no GM apple orchards are planted in Canada and it may be “several years” before BC plantings occur.(5) However, in January 2016, the Ottawa Citizen reported that “So far, only a handful of Arctic Apple trees are being grown in Canada, in a greenhouse in Summerland, B.C., where Carter owns his orchard”.(6) Carter may not have planted GM fruit trees yet but could have a nursery where he is growing his own rootstock. The company also told COABC that when plantings in BC do take place, all trees and fruit will be under the direct oversight of OSF on either our own land or that of growers specifically contracted to produce fruit for us”.(7)

Despite the name, Okanagan Specialty Fruits is no longer a small BC company. In 2015, it was bought by biotechnology/synthetic biology company Intrexon, which also owns the GM salmon and a GM mosquito.

Ultimately, growers will need to work together to track the GM apple trees. COABC is asking growers to talk to their nurseries and report any information so that growers in BC can be aware if and when the GM trees hit the market. Some growers are already getting verbal pledges from their nurseries that they will never sell the GM trees.

OSF says “The Perfect Fruit Got Even Better” but consumers will decide if this is the case. Most major grocery chains in Canada have already responded to consumer concerns by saying that they have no plans to carry the GM apple in their stores. In the meantime, growers can also decide how far the GM apple tree gets.

Visit CBAN for updates and more information on the Arctic Apple

Lucy Sharatt is the coordinator of the Canadian Biotech- nology Action Network (CBAN). CBAN brings together 16 organizations that research, monitor and raise aware- ness about issues relating to genetic engineering in food and farming. CBAN members include farmer associa- tions, environmental and social justice organizations, and regional coalitions of grassroots groups. CBAN is a project on Tides Canada’s shared platform.


(1) Dan Wheat, “Company Forges Ahead with GM Apples.” Capital Press, August 11, 2016. http://www.capitalpress.com/Orchards/20160811/company-forges-ahead-with-gm-apples

(2) Laura Robin, “From Tree to Table: The Arctic Apple is Ready to Blossom.” Ottawa Citizen, January 22, 2016. http://ottawacitizen.com/news/local-news/from-tree-to-table-the-arctic-apple-is-ready- to-blossom

(3) Intrexon’s (XON) CEO Randal Kirk on Q3 2016 Results – Earnings Call Transcript, November 9, 2016. http://seekingalpha.com/article/4021879-intrexons-xon-ceo-randal-kirk-q3-2016-results-earnings-call-transcript?part=single

(4) Fresh Fruit Portal, “US: GM Arctic Apple Ready for First Test Marketing in Early 2017” October 3, 2016. http://www.freshfruitportal.com/news/2016/10/03/us-gm-arctic-apples-ready-for-first-test-marketing-in-early-2017/

(5) Email correspondence between Eva-Lena Lang, Certified Organic Association of BC and Jessica Brady, Okanagan Specialty Fruits, June 10, 2016; Letter from Neal Carter, Okanagan Specialty Fruits to Walter Makepeace, Certified Organic Associations of BC , November 1, 2016.

(6) Letter from Neal Carter, Okanagan Specialty Fruits to Lucy Sharratt, Canadian Biotechnology Action Network, August 22, 2016.

(7) Letter from Neal Carter, Okanagan Specialty Fruits to Walter Makepeace, Certified Organic Associations of BC , November 1, 2016.

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